How the Quest for Huge Returns by Financial Institutions Trumps Prudent Risk Management: The Archegos Saga

Abstract

Competition in the financial services sector has always been fierce. In many respects financial services is a sophisticated borrower’s market. Sophisticated borrowers with a proven track record are able to mobilise significant amounts of financial resources as they pursue complex and innovative financial strategies which are regarded by the various lenders as so likely to be profitable, that the risk is worth taking. The risk is attached to a specific instrument, real or synthetic such as a total return swap, and is a bet on the direction of the value of the instrument. In the quest for business, especially “aggressive deal makers” like Bill Hwang of Archegos, securities financing institutions can and do compromise their own due diligence and risk management processes and procedures. Often, tension arises within firms when the dealmakers pushing hard to take on business come up against resistance from cautious risk managers. In a profit driven industry, risk managers are often overruled by management, in favour of deal makers. This case had an impact across borders. When the implosion eventually occurred securities financing firms were shown to have disregarded prudent risk management practices. The failure of Archegos compelled regulators to act in order to prevent similar possibly worse collapses in the future. Remedial measures included a direction to securities financing institutions to demonstrate a commitment to safe practices by adopting a risk based approach to their supervisory activities. The failure of Archegos highlights the importance of an understanding of the key inherent risks faced by entities offering equity financing transactions, and also the supervisor’s expectation for the mitigation of these risks. In the operational sphere, it is evident that risk mitigation can be enhanced by a clear demarcation and understanding of the roles of the first line of defense, second line of defense, senior management and the board.