Did FAS 166 and FAS 167 Improve The Transparency of Securitizing Banks? Seda Oz seda.oz@stern.nyu.edu Accounting Department Stern School of Business New York University Please do not circulate without permission Version: January 24, 2013 Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? Seda Oz I Abstract This study investigates whether changes in mandated Financial Accounting Standards No. 166 and 167 (FAS 166 and FAS 167) improved the transparency of securitizing banks. I use a difference-in-differences research design that compares four measures of information uncertainty (dispersion in analysts’ earnings forecasts, implied volatility, stock illiquidity, and bid-ask spread) in the pre- versus post-FAS 166 and FAS 167 periods for securitizing versus non-securitizing banks. I predict and find that information uncertainty of securitizing banks decreases from the pre- to the post-FAS 166 and FAS 167 periods compared to non-securitizing banks. I also show that information uncertainty of securitizing banks decreases more from the pre- to the post-FAS 166 and FAS 167 periods with their involvements with variable interest entities and implicit recourse practice. I exploit the later timing of the issuance of FAS 166 and FAS 167 than the financial crisis of 2007-2009 to rule out the confounding effects of the crisis. I conclude that FAS 166 and FAS 167 have improved the transparency of securitizing banks’ reporting. This study is the first to provide evidence for the disclosure and accounting implications of FAS 166 and FAS 167 for securitizations and banks’ transparency. I Contact E-mail: seda.oz@stern.nyu.edu. This paper is based on my dissertation at the New York University. I greatly appreciate the invaluable guidance and support from my dissertation committee members: Yakov Amihud, Mary Billings, Michael Jung, Joshua Ronen (chair), and Stephen Ryan. I also thank Karthik Balakrishnan, Massimiliano Bonacchi, Matthew Cedergren, Jing Chen, Justin Deng, Jamie Diaz, Yiwei Dou, Mike Gengrinovich, Begum Guney, Igor Kadach, Jessica Keeley, Seil Kim, Anya Kleymenova (discussant), Alina Lerman, Jianchuan Luo, Bugra Ozel, Sorah Park, Emiliya Schain, Michael Tang, Tuba Toksoz, Chris Williams (discussant), Xiaolu Xu (discussant), and seminar participants at the 2012 LBS Trans-Atlantic Doctoral Conference, 2012 AAA Northeast Region Meeting, 2013 FARS Meeting, and New York University for their helpful comments and suggestions. All errors are my own. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 1 1. Introduction This study examines whether Financial Accounting Standards No. 166 and 167 (FAS 166 and FAS 167) improve the transparency of reporting by bank holding companies’ (banks) with respect to their securitization activities. I define banks’ reporting transparency (bank transparency, hereafter) as the degree to which a bank’s value can be estimated using information available in the financial statements (e.g., Jiang, Lee and Zhang 2005). Securitizations are complex transactions and banks’ involvements with these transactions were not fully conveyed by prior accounting and disclosure requirements (e.g., Ryan 2007). Financial report disclosures for securitizations lacked crucial information (e.g. issuers’ risk retention, risk of the securitized assets) that was already available to management (U.S. Senate Committee on Banking, Housing, and Urban Affairs 2009). In June 2009, the Financial Accounting Standards Board (FASB) issued FAS 166, which provides amended guidance to determine whether securitizations and other transfers of financial assets should be treated as sales or secured borrowings, and FAS 167, which provides amended guidance to determine whether special purpose entities used in securitizations should be consolidated into the financial statements of one of the parties involved in the transactions. The Board’s objective in issuing these standards was to “[. . . ] enhance disclosures to provide financial statement users with greater transparency about transfers of financial assets and a transferor’s continuing involvement with transferred financial assets [. . . ] and improve transparency in financial reporting about an enterprise’s involvement with a variable interest entity [. . . ]” (FASB, 2009). Motivated in part by this objective, I explore whether FAS 166 and FAS 167 improved banks’ reporting transparency by estimating the association between measures of information uncertainty and measures of issuers’ risk retention in securitizations in the pre- and post-FAS 166 and FAS 167 periods. This study has four primary motivations. First, prior analytical studies show that bank transparency benefits banking and financial system stability (e.g. Boot and Thakor, 1998; Rosengren, 1998). For instance, Gorton and Huang (2004) present a model in which banks experience both macroeconomic and idiosyncratic shocks. If bank transparency enables investors to observe the idiosyncratic shock, the long-term impact of macroeconomic distress on these banks will be less severe than for banks with lower levels of transparency. Second, many S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 2 public sector institutions, such as the Basel Committee on Banking Supervision, G7 Finance Ministers, International Monetary Fund, and the World Bank, have campaigned for improved bank accounting and disclosure practices (e.g., Basel Committee 1998, 1999). For instance, due to the complex nature of securitizations, the SEC, the U.S. Senate Banking Subcommittee on Securities, Insurance, and Investments, The President’s Working Group on Financial Markets, the Financial Crisis Advisory Group (FCAG) and others requested the FASB to improve accounting and disclosure standards for banks’ securitization activities. Third, the structure of securitizations and the use of off-balance sheet securitization vehicles (i.e., special purpose entities) by banks represent two reasons why an inquiry about the impact of FAS 166 and FAS 167 on bank transparency is important. Securitization transactions have complex structures that make it difficult for investors to understand the risk and performance characteristics of the transactions. Prior literature suggests that the complexity of securitizations causes information uncertainty for market participants (e.g., Cheng, Dhaliwal, and Neamtiu 2011) and that these transactions require a certain level of expertise and sophistication to evaluate (e.g., Barth, Clinch and Shibano 2003; Schwarcz 2004). Fourth, the financial crisis of 2007-2009 demonstrated the potential adverse consequences of banks’ use of off-balance-sheet securitization vehicles, which contributed to illiquidity and financial losses for those banks (Ryan 2008). At the end of 2007, cash flows into the securitization vehicles declined as subprime mortgage defaults mounted. Many banks provided contractual and/or non-contractual recourse to securitization vehicles even though the probability of banks providing recourse was very low initially. Motivated by these reasons, I ask whether FAS 166 and FAS 167 provide financial statement users with greater transparency about banks’ securitization activities. While the FASB intends FAS 166 and FAS 167 to improve bank transparency, there are a number of reasons why this might not occur. First, banks may have voluntarily provided transparent information even before the implementation of the new standards (e.g., Gurun, Lerman, and Ronen 2009). Second, in light of the financial crisis of 2007-2009, users of financial reports may have forced banks to be more transparent prior to FAS 166 and FAS 167. Third, banks may have entered into (costly) restructuring arrangements to avoid consolidating off-balance S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 3 sheet securitization vehicles under the new accounting standards (Bens and Monahan, 2008). This may have the unintended consequences of complicating the securitization transactions and reduce bank transparency. Last, more extensive disclosure requirements do not necessarily mean more clear information for market participants; in particular the information could be too complex for equity market participants to determine the economic characteristics of securitizations. The first research question I address is how FAS 166 and FAS 167 affect the information environments of securitizing and non-securitizing banks differently. To control for banks’ reasons to securitize, I construct matched samples of securitizing (treatment) and non-securitizing (control) banks with similar propensity to securitize1 . Using a difference-in-differences research design I compare four measures of information uncertainty (dispersion in analysts’ earnings forecasts, implied volatility, stock illiquidity, and bid-ask spread) in the pre- versus post-FAS 166 and FAS 167 periods for securitizing versus non-securitizing banks. I predict a decrease in the information uncertainty of securitizing banks from the pre- to the post-FAS 166 and FAS 167 periods. I use four constructs to measure information uncertainty: analysts’ earnings forecast dispersion, implied volatility, stock illiquidity2 , and bid-ask spread and cover the period from 2005 through 2011, with the post FAS 166 and FAS 167 period beginning from the first quarter of 2010. Consistent with my prediction, I find that securitizing banks experience a decrease in information uncertainty that is larger than the decrease experienced by non-securitizing banks from the pre- to post-FAS 166 and FAS 167 periods. Further, I find that the association between information uncertainty of securitizing banks with total securitized assets decreases from the pre- to post-FAS 166 and FAS 167 periods relative to that association of non-securitizing banks. The second research question I address is to what extent accounting and disclosure changes in FAS 166 and FAS 167 affect securitizing banks. To address this question, I focus on my 1 The treatment and control samples have similar balance sheet structures that would result in similar probability of securitization, all else equal. The primary distinction between these two samples is that one made the choice to securitize for some endogenous and exogenous. 2 Also known as Amihud’s (2002) equity market liquidity measure. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 4 treatment sample (securitizing banks) and using a difference research design, examine the association between FAS 166 and FAS 167 and securitizing banks’ information uncertainty with regard to these banks’ risk retention in securitizations, relative to the association before the guidance. FAS 166 and FAS 167 eliminated the concept of qualifying special purpose entities3 that were immune from consolidation, clarified and tightened the requirements for consolidation of securitization vehicles. With these changes FAS 166 and FAS 167 should have generated consolidation of additional VIEs, showing significant increases on securitizing banks’ consolidated balance sheets. I hypothesize and find that information uncertainty of securitizing banks in the post-FAS 166 and FAS 167 period, is negatively associated with their involvements with variable interest entities (VIEs). I measure securitizing banks’ involvement with consolidated VIEs as the assets of consolidated VIEs scaled by the remaining total assets and find empirical support for my prediction. Securitizations raise an important information problem for investors through the practice of implicit recourse. Implicit recourse is the voluntary support, beyond at contractually required to a securitization vehicle. Prior literature shows that investors have little information to assess the probability that implicit recourse will provided (e.g., Mason 2009; Cheng, Dhaliwal, and Neamtiu 2011). Cheng, Dhaliwal, and Neamtiu (2011) examine the period prior to the issuance of FAS 166 and FAS 167 and document a positive association between a bank’s likelihood of providing implicit recourse and information uncertainty. I examine whether FAS 166 and FAS 167 mitigate the impact of implicit recourse on banks’ information uncertainty. I predict that information uncertainty of securitizing banks in the post-FAS 166 and FAS 167 period, is negatively associated with implicit recourse. Following Calomiris and Mason (2004), I use managed capital ratio to proxy for the likelihood of a bank providing implicit recourse. Additionally, I use revolving loans (sum of home equity lines and credit card receivables) as another proxy for implicit recourse. While prior literature shows implicit recourse is positively associated with banks’ information uncertainty, I find that this association decreases in the post-FAS 166 and 3 Please see Section 2 for a detailed explanation of qualified special purpose entities. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 5 FAS 167 period. This suggests that the impact of the implicit recourse on securitizing banks’ information uncertainty is mitigated in the post-FAS 166 and FAS 167 period. It is possible that my primary results are driven by the confounding effects of the financial crisis of 2007-2009. Beginning in mid-2009, the financial market started to recover from the adverse consequences of the crisis, presumably decreasing information uncertainty. Thus, the decrease I observe in the measures of information uncertainty in the post-FAS 166 and FAS 167 period might reflect the fading effects of the crisis. To rule out this possibility, I conduct four additional analyses. In the first two analyses, I use different variations of interactions between total securitized assets and time period covering the crisis effects. Both analyses reveal that information uncertainty of securitizing banks increases in 2007 and 2008 as opposed to nonsecuritizing banks. However, there is little evidence to show that information uncertainty of securitizing banks decreases in 2009 after the crisis as opposed to non-securitizing banks. In contrast, I find that the information uncertainty of securitizing banks decreases in the post-FAS 166 and FAS 167 period. In my third analysis, I use stock illiquidity as an independent variable to proxy for the effects of the financial crisis. I assume that any change in the information uncertainty, which can be attributed to the crisis will be captured by illiquidity measure. If so, the incremental decrease in the information uncertainty of securitizing banks in the post-FAS 166 and FAS 167 will be attributable to the effectiveness of FAS 166 and FAS 167. Last, I limit the pre-FAS 166 and FAS 167 period to between 2005:Q1 and 2007:Q1, and the post-FAS 166 and FAS 167 period to between 2010:Q1 and 2011:Q3. Similar to the first analysis, the negative association between information uncertainty and securitizations remains significant in the post-FAS 166/167 period. These analyses provide support for the idea that my main results are not driven by the financial crisis of 2007-2009. My paper makes three primary contributions. First, to the best of my knowledge, it is the first study to examine the consequences of FAS 166 and FAS 167. The results should be of interest to accounting regulators and investors, who want to understand whether FAS 166 and FAS 167 improve bank transparency by decreasing the information uncertainty associated with securitizations. Second, this study is relevant to the mandatory disclosure literature. It is debatable whether banks are better off with mandatory financial reporting regulations or not S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 6 (e.g., Levine 2005). I provide support for having mandatory regulations on banks by providing evidence for the beneficial impact of FAS 166 and FAS 167 on banks’ information environment. Third, this study contributes to the financial institutions literature by providing evidence that securitizing banks have greater information uncertainty, and that these effects diminished in the post-FAS 166 and FAS 167 period. The next section gives background information about special purpose entities, securitization, FAS 166 and FAS 167. Section 3 discusses the related literature. Section 4 develops testable hypotheses, while Section 5 describes the research design and reports the empirical results. Section 6 conducts the robustness tests and Section 7 concludes with future research ideas. 2. Background Information 2.1. Special Purpose Entities (SPEs) and Securitization SPEs are entities in the form of a trust or other legal vehicle designed to fulfill a specific limited need of the company that organized it. SPEs are restricted by contract to engage in specified and generally limited economic activities. Assuming that an SPE is not consolidated by the firms involved with it, the SPE enables those firms to obtain off-balance sheet financing of the assets held by the SPE and to recognize income on transactions with the SPE. SPEs used in securitizations generally are bankruptcy-remote entities; therefore the bankruptcy of the transferor of assets to the SPE and/or the user of the SPE’s assets cannot affect the activities of SPE. For this reason, SPEs often receive better credit ratings than the issuer and therefore can issue securities that pay lower interest rates than uncollateralized debt. There are also downsides to using SPEs. For instance, the issuer’s perceived credit quality might be adversely affected by the underperformance of an affiliated SPE. The poor performance of collateral in an SPE may cause market participants to interpret as similar. The vast majority of SPEs are used in securitization. The simplest form of securitization is the creation of asset-backed securities (ABS) through SPEs that involves the following steps: (i) the issuer sets up a SPE, and transfers financial assets to the SPE in a legal true sale; (ii) the SPE issues ABS that entail a proportional interest in the principal and interest payments on the financial assets, after fees are paid to the securitization sponsor; (iii) SPE collects payments on S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 7 the financial assets and distributes them to the appropriate parties; and (iv) when substantially all the payments are collected and disbursed, the SPE is dissolved (Gorton and Souleles 2006; Ryan 2007). If the requirements for sale accounting are met, then the assets are recorded on the balance sheet of the SPE not on the issuer’s balance sheet. Figure 1 shows how a typical securitization is structured. 2.2. FAS 166 and FAS 167 On June 12, 2009, the FASB issued two new accounting standards: FAS No. 166, “Accounting for Transfers of Financial Assets” and FAS No. 167, “Amendments to FASB Interpretation No. 46(R)”. These statements became effective on January 1, 2010. FAS 166 revises prior sale accounting criteria for transfers of financial assets and stipulates that these transfers need to be evaluated for relinquishment of control by the issuer over these assets. FAS 166 amends Financial Accounting Standards No. 140 (FAS 140), “Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities” (2000). FAS 140 used to determine if transfer of assets is a sale. According to FAS 166, a securitization of financial assets is accounted for as a sale when the transferring company surrenders control over the assets transferred and receives cash and other proceeds in return. Control is considered to be surrendered only if all three of the following conditions are met: (1) the assets have been legally isolated from the issuer/transferor; (2) the transferee has the ability to pledge or exchange the assets; and (3) the issuer does not maintain effective control over the assets. If the securitization does not qualify as a sale, it is accounted for a secured borrowing, which the assets remaining on the issuer’s balance sheet and no gain or loss being recognized. Additionally, FAS 166 (along with FAS 167) eliminates the concept of a Qualifying Special Purpose Entity (QSPE). QSPEs were defined under FAS 140 as passive entities distinct from the transfer or that only hold financial assets and distributed the cash flows generated by those assets. QSPEs were exempted from consolidation by the issuer. For securitizations that qualify for sale accounting, the use of a QSPE ensured the securitized assets and associated debt stay off the issuer’s books. Former QSPEs are now subject to consolidation like any other SPE. FAS 167 primarily addresses whether variable interest entities (VIEs) often used in securitization should be included in the consolidated financial statements of any particular interested S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 8 party. VIEs are entities whose equity ownership either is insufficient to finance their operations or does not involve the usual control rights or financial interest associated with equity (i.e., the ability to make significant decisions through voting rights, the right to receive the residual returns of the entity or the obligation to absorb the losses of the entity). Generally speaking, a SPE is also a VIE, because the equity investors in SPEs usually lack substantive control rights. The entity that consolidates a VIE is called its primary beneficiary. A primary beneficiary has a “controlling financial interest.” FAS 167 amends FIN 46(R), “Consolidation of Variable Interest Entities” (2003), which defined the characteristics of a controlling financial interest. Under FAS 167, an entity is deemed to have a controlling financial interest in a VIE if it has variable interests with both of the following characteristics: (a) the power to direct the activities of a VIE that most significantly impact the VIE’s economic performance; (b) the obligation to absorb losses of the VIE or the right to receive benefits from the VIE that could potentially be significant to the VIE. FAS 167 requires that an enterprise continually reconsider its conclusion regarding which interest holder, if any is the VIE’s primary beneficiary. If the enterprise determines that it is no longer the primary beneficiary of a VIE, it would need to deconsolidate the VIE on the date that the circumstances changed and recognize a gain or loss. Figure 2 presents a timeline summarizing the developments leading to FAS 166 and FAS 167. 3. Prior Research 3.1. Securitization Early theoretical work suggests that securitization provides a means of reducing bank risk (Greenbaum and Thakor 1987; Pavel and Phillis 1987; Hess and Smith 1988). Later research investigated the effect of securitization on banks focusing on three broad themes: (a) the quality of the assets securitized or retained, (b) recourse arrangements, and (c) the impact on overall bank risk. This first issue relates to the quality of the assets securitized. Cantor and Rouyer (2000) argue that the credit risk position of the issuer improves if the riskiness of the securities sold to investors is higher than that of the issuer prior to the securitization. Otherwise, the transaction might intensify the issuer’s net exposure to the default risk of its assets. In contrast, Ambrose, S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 9 LaCour-Little, and Sanders (2005) find evidence suggesting that, in response to regulatory capital incentives, lenders retain riskier loans in their portfolios while selling safer loans to the secondary market. The second issue relates to the recourse provided by the originating bank. Gorton and Pennacchi (1995) argue that originating banks retain a portion of the securitized assets on the balance sheet, or offer an implicit guarantee, to reduce moral hazard problems. Chen, Liu, and Ryan (2008) find that banks’ retained interests vary by type of securitization and are relatively low in the case of mortgages and relatively high for revolving loans such as credit card receivables. Calomiris and Mason (2004) find that in credit card securitizations, risk remains with the securitizing banks because of implicit recourse. Vermilyea, Webb, and Kish (2008) also find evidence of implicit recourse in credit card securitizations, where banks with poorly performing securitization portfolios claim higher fraud losses. Beneficial effects of recourse are found by Higgins and Mason (2004) in the form of increased short- and long-term stock returns and improved long-term performance. The final issue relates to the implications of securitization on overall bank risk. Dionne and Harchaoui (2003) find a positive association between securitization and bank credit risk. Krahnen and Franke (2008) and Haensel and Krahnen (2007) find evidence that the issuance of collateralized debt obligations increases the systematic risk of the issuing bank. Jiangli and Pritsker (2008), on the other hand, find that mortgage securitization reduces bank insolvency risk. Cebenoyan and Strahan (2004) suggest that securitization reduces bank risk; however, banks use the achieved risk reduction to take on new risks. Purnanandam (2011) also provides evidence that banks use the proceeds from securitizations to issue loans with higher than average default risk. Barth, Ormazabal, and Taylor (2011) examine the sources of credit risk associated with asset securitizations and whether credit rating agencies and the bond market differ in perceptions of this risk. They find that credit rating is positively related to the securitizing firm’s retained interest in the securitized assets, and is unrelated to the portion of the securitized assets not retained by the firm. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 10 3.2. Variable Interest Entities (VIEs) There is a relatively small amount of research discussing VIEs, and few papers in this literature examine the VIEs in the context of FIN 46 and FIN 46R, which are now no longer in effect. Beatty (2007) finds that financial institutions modify their economic behavior in response to accounting changes made in FAS 140 and FIN 46R. Callahan and Spencer (2008) examine the valuation and disclosure impact of FIN 46R on firms disclosing a synthetic lease involving a VIE. They find that disclosed future minimum lease payments are significantly valued by the market both pre- and post-adoption of FIN 46. Altamuro (2006) finds that firms are less likely to engage in synthetic lease financing after the issuance of FIN 46, which is consistent with the conjecture that the primary benefit of such transactions is the off-balance sheet treatment, made more difficult following the passage of FIN 46. Dickinson, Donohoe, and McGill (2010) examine the short-window market reaction to the regulatory actions resulting in the promulgation of FIN 46 and FIN 46R and conclude that, overall, the market exhibits a negative price reaction to the release of the first exposure draft proposing FIN 46. Finally, Gurun, Lerman, and Ronen (2009) find that FIN 46 reduced analysts’ incentives to gather private information. They also find that equity market participants act as if they perceived higher business risk, as evidenced by reduced earnings response coefficients after 2001 for FIN 46 firms. 4. Hypotheses To examine the impact of FAS 166/167 on the transparency of banks, it is necessary to establish (1) the importance of bank transparency, i.e., the extent to which bank stability is associated with transparency, and that (2) in the absence of efficient regulations, information available in the financial statements about securitizations is not clear to the investors, hence investors cannot efficiently estimate bank’s value, which leads deteriorated bank transparency. First, analytical literature provides evidence to establish the importance of bank transparency. Analytical research examined the idea that increased transparency could enhance market discipline on banks through bank’s risk taking behavior. Bank transparency increases the sensitivity of the bank’s funding terms to the risk it takes. This creates incentives for S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 11 the bank to control risk. For instance, Boot and Schmeits (2000) show that in the absence of transparency the bank will choose low levels of monitoring because committing to high levels of monitoring is costly. Thus, bank’s choice of low levels of monitoring will result in high risk because as transparency decreases, risk becomes less observable. Similarly, Cordella and Yeyati (1998) present a model, which shows how bank transparency impacts bank’s funding terms. According to the authors’ model, the funding terms are determined after the bank has chosen its risk of default and a bank’s funding terms are more favorable if the bank chooses lower levels of risk. When transparency is high and thus, depositors can observe the level of risk chosen by the bank, the bank chooses low levels of risk, since it would otherwise be punished by a high required interest rate on its funds. However, when the transparency is low, the level of risk cannot be observed by lenders. Then, the bank has no way to commit to a low level of risk because in equilibrium, lenders assume that the bank will choose a high level of risk and since the bank cannot be rewarded for a low level of risk it chooses a high level of risk in equilibrium. This line of analytical work suggests that improving bank transparency reduces bank risk-taking and this equilibrium improves market stability. My study extends this line of theoretical study using an empirical data by examining the impact of mandatory disclosure requirements on bank transparency ex post. To establish the second key point, it is important to understand whether and how banks’ economic leverage and risk arising from off-balance sheet securitization activities are observable to financial statement users from the banks’ financial reports. Chen, Liu, and Ryan (2008) find that attributes of the securitizations (e.g., the retention of credit-enhancing interest-only strips) are significantly associated with banks’ unsystematic risk. Cheng, Dhaliwal, and Neamtiu (2011) find that the magnitude of the loan securitizations is associated with various measures of banks’ information uncertainty. These studies, which cover the pre-FAS 166/167 period, indicate that off-balance sheet securitization positions are not fully understood by the financial statement users, and thus cause information uncertainty about securitization activities. This uncertainty about securitizations is attributable in part to the complex structure of securitizations, and in part to inadequate disclosure that failed to provide clear information to financial statement users. Previous accounting standards regarding securitizations did not S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 12 provide clear disclosure for investors to understand the true nature of securitizing banks’ offbalance sheet activities and were a limited attempt to describe complex securitization transactions (e.g., Ryan 2007). Financial analysts surveyed by the Chartered Financial Analyst (CFA) Institute in 1999, 2003, and 2007 consistently rated securitization-related disclosure as high in importance, yet assigned low ratings for the quality of such disclosure (CFA Institute 2008). Difficulty in understanding securitization transactions can lead to information uncertainty among market participants if some market participants have better information and/or better information-processing abilities. Barth, Clinch, and Shibano (2003) suggest that investors with a higher level of expertise are able to collect information from disclosures at a lower cost and/or a faster pace, thus obtain an informational advantage over investors with less expertise. Even more, Schwarcz (2004) suggests that securitization transactions are so complex that their disclosure requires a level of sophistication that is challenging even for institutional investors and security analysts. FAS 166 and FAS 167 aim to improve existing standards and address concerns about companies who are stretching the use of off-balance-sheet entities. FASB states: “The new standards eliminate existing exceptions, strengthen the standards relating to securitizations and specialpurpose entities, and enhance disclosure requirements. They’ll provide better transparency for investors about a company’s activities and risks in these areas” (FASB 2009). Requiring information disclosure as a regulatory tool implies the existence of underlying information uncertainty. As such, an effective regulatory system compels the disclosing party to provide information to end-users that somehow redresses this uncertainty. By forcing banks to disclose more and better securitization information about securitization activities FAS 166/167 are expected to decrease information uncertainty of securitizing banks. My first hypothesis (in alternative form) is: Hypothesis 1a (H1). Information uncertainty of securitizing banks decreases from the pre- to the post-FAS 166 and FAS 167 periods when compared to non-securitizing banks. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 13 In the pre-FAS 166/167 period, QSPEs were exempt from consolidation and banks would not consolidate VIEs unless they were the primary beneficiaries. FAS 166/167 eliminated QSPEs, making these entities eligible for consolidation, and changed the method of determining the primary beneficiaries of the VIEs to require less risk retention. These two key changes essentially led all QSPEs to be identified as VIEs, and banks to consolidate more VIEs. Thus, I expect the impact of FAS 166/167 on the information uncertainty of securitizing banks to be observable in these banks’ involvement with VIEs. My second hypothesis (in alternative form) is: Hypothesis 2 (H2). Information uncertainty of securitizing banks decreases MORE from the pre- to the post-FAS 166 and FAS 167 periods with their involvements with consolidated VIEs. In an asset securitization transaction, recourse refers to guaranties promised to investors in asset-backed securities that transfer some losses on the securitized assets to the guaranteeing bank when the performance of those assets deteriorates. Banks typically provide implicit recourse, as a means to protect their reputation, in situations where they perceive that the failure to provide this support, even though not contractually required, would damage future access to the asset-backed securities market (OCC Guidance, 2002). Loss of reputation exposes banks to decreased liquidity, increased interest rate risk, and burdensome regulatory supervision. On the other hand, implicit recourse can cause information uncertainty because investors might lack understanding about the allocation of losses to tranches of securitized assets absent recourse and the triggers and terms of this recourse (Mason 2009). Prior to FAS 166/167, companies provided insufficient and hard-to-interpret securitization disclosures for market participants to understand recourse fully. Cheng, Dhaliwal, and Neamtiu (2011) use five different measures of explicit and implicit recourse and illustrate that difficulty in estimating recourse is positively associated with banks’ information uncertainty. Consistent with my previous predictions, if FAS 166/167 decreases information uncertainty of securitization activities, I expect securitization recourse to be less opaque to market participants; given S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 14 that Cheng, Dhaliwal, and Neamtiu (2011) established recourse is opaque to investors. Thus, my third hypothesis (in alternative form) is: Hypothesis 3 (H3). Information uncertainty of securitizing banks decreases MORE from the pre- to the post-FAS 166 and FAS 167 periods with their involvements of implicit recourse practice. 5. Research Design and Empirical Results 5.1. Data Sources This study uses recently required disclosures about securitization vehicles mandated by FAS 166/167. To identify the sample, I start with all the bank holding companies that are required to submit regulatory Y-9C reports to the Federal Reserve Board 4 . This report collects basic financial data from a domestic bank holding company on a consolidated basis in the form of a balance sheet, an income statement, and detailed supporting schedules, including Schedule HC-S, a schedule of off-balance-sheet items arising from securitizations. The data are publicly available on the Federal Reserve Bank of Chicago’s website. I eliminate banks that do not have valid earnings data for at least five consecutive quarters. Further, I require firms to have daily return data for at least 90 consecutive trading days. Schedule HC-S, with securitized assets data, was first provided in Y-9C reports in the second quarter of 2001. It provides these data for seven types of loans: 1-4 family residential mortgages, credit card receivables, home equity lines of credit, automobile loans, other consumer loans, commercial and industrial loans, and all other loans and leases. I aggregate the data provided for these seven loan types into three categories: mortgages (1-4 family residential mortgages), consumer loans (credit card receivables, home equity lines of credit, automobile loans, and 4 Banks with total consolidated assets of $150 million ($500 million after March 2006) or more are required to file this report. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 15 other consumer loans), and commercial loans (commercial and industrial loans and all other loans and leases). Starting from the first quarter of 2011, Schedule HC-S provides assets and liabilities of three categories of VIEs: securitizations vehicles, asset-backed commercial paper conduits, and other. For the year of 2010, I hand-collect VIE data from the banks’ 10-Qs. I also gather several other bank-specific variables (total assets, total loans, charge-offs, securitization income, interest rate derivatives, tier 1 capital ratio, and nonperforming loans) from the Y-9C reports. I collect daily returns from the Center for Research in Security Prices (CRSP) and quarterly earnings per share from Bank Compustat. Additionally, I obtain analyst forecast data from the Institutional Brokers Estimate System (I/B/E/S) and collect implied volatility data from OptionMetrics. For each option price quote, OptionMetrics calculates the implied volatility, using American or European models where appropriate. All option calculations employ historical London Inter-Bank Offered Rate (LIBOR) /Eurodollar rates for interest rate inputs, and correctly incorporate discrete dividend payments. Lastly, I collect data on VIX, the Chicago Board Options Exchange Market Volatility Index, through the Chicago Board Options Exchange website. The VIX is a measure of the implied volatility of S&P 500 index options. 5.2. Sample This study focuses on two groups of banks: (i) securitizing banks, and (ii) non-securitizing banks. When building my sample I eliminate banks that do not have valid earnings, and assets data for at least five consecutive quarters. I also eliminate banks whose common equity is not traded on the NYSE, NASDAQ, or AMEX stock exchanges, as one of my measures of information uncertainty i.e., bid-ask spread are market-based. Further, I require firms to have daily return data for at least 90 consecutive trading days. The primary data set contains 8,325 banks from 2005:Q1 to 2011:Q4. I begin with a cross-sectional analysis of the full sample and compare the characteristics of banks that securitize, with those that do not. Table 1 reports means and standard deviations of the variables for the full sample, as well as for the securitizing and non-securitizing banks subsamples. There are 8,325 banks in the sample, of which 7,899 are non-securitizing banks and 426 are securitizing banks. Despite the significantly smaller number (5.11% of the sample), securitizing banks have a larger mean of S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 16 total assets than non-securitizing banks. The most significant difference is total assets. The mean value of the size of securitizing banks ($8.95 billion) is six times the mean of non-securitizing banks ($1.41 billion). This finding is consistent with previous research documenting that larger banks are more likely to securitize (e.g., Minton, Stulz, and Williamson 2009). Securitizing banks tend to hold less liquid assets (28% versus 35% of total assets), consistent with these banks having better access to external funding and thus needing a smaller liquidity buffer than non-securitizing banks. The loan ratio is higher for securitizing banks, with a mean of 72% versus 68% for non-securitizing banks. Both securitizing and non-securitizing banks are financed mainly by deposits; however, nonsecuritizing banks rely on this source of funding to a larger extent (83% of total assets versus 76%). Further, the percentage of total assets funded by equity capital is slightly higher for non-securitizing banks (13%) than for securitizing banks (11%). To test the hypotheses empirically, I need to observe information uncertainty of securitizing banks had they not securitized. As it is impossible to observe the same bank in both states, I use non-securitizing banks as a proxy. However, this approach would still entail selection problems (Heckman and Smith, 1995) because securitizing and non-securitizing banks likely are ex-ante different. Such differences could arise because securitizing banks have different balance sheet structure prior to securitizations or different consequences of securitizations. To address this issue, I use propensity score matching to build a control sample from the nonsecuritizing banks whose balance sheet structure is as close as possible to that of securitizing banks (e.g., Casu, Clare, Sarkisyan, and Thomas 2011). The balance sheet structures of securitizing and non-securitizing banks exhibit key differences. Cheng, Dhaliwal and Neamtiu (2011) show that larger banks are more likely to be securitizers. Prior studies also indicate that liquidity ratio of banks is an important determinant in securitization (e.g., Casu, Clare, Sarkisyan and Thomas 2011). Additionally, due to the nature of securitizations, securitizing banks likely have a lower deposits ratio while nonsecuritizing banks likely have a lower loan ratio (e.g., Casu, Clare, Sarkisyan, and Thomas 2011). Calomiris and Mason (2004) indicate that securitizing and non-securitizing banks have different tier 1 risk based capital ratio due to securitizing banks providing implicit recourse. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 17 They argue that according to efficient contracting (safety net abuse) hypothesis 5 , tier 1 ratio of securitizing banks will be higher (lower). The propensity score approach predicts securitization likelihood while balancing the covariates between the two groups; securitizing and non-securitizing banks. Therefore, I include six variables to consider differences in balance sheet characteristics: (1) size (SIZE), measured as the natural logarithm of total assets; (2) liquidity ratio (LIQIDUITY RATIO), measured as the sum of cash, available-for-sale securities, trading assets, federal funds sold, and securities purchased with intent to resell, scaled by total assets; (3) loan ratio (LOAN RATIO), measured as the proportion of on-balance-sheet net loans to total assets; (4) deposits ratio (DEPOSIT RATIO), measured as the quarterly average for all interest-bearing deposits, scaled by total assets; (5) equity ratio (EQUITY RATIO), measured as the total equity divided by total assets; (6) tier 1 risk based capital ratio (TIER1). Each quarter, I estimate the following ordered logistic model, for the banks in the overall sample: P (SecF irmi,t = 1|Xi , t − 1) where SecFIRM is a dummy variable, equal to 1 if a bank has securitization activities, 0 otherwise and Xi,t−1 is a vector of six balance sheet characteristics, lagged one quarter. Table 2 reports the results of the ordered logistic propensity-score regression of the likelihood of securitization. The first column presents the average of the coefficient estimates, and the second reports an aggregated t-statistic 6 . Consistent with prior research, I find that securitizing banks are larger, less liquid, and hold a higher loan ratio and lower deposits ratio. Consistent with the safety net abuse hypothesis, I find that securitizing banks have a lower tier 1 ratio. Table 2 indicates that the propensity-score model has reasonable explanatory power 5 According to the efficient contracting view, if banks establish contracts to satisfy the marketplace, they will hold adequate risk to absorb their risk. Banks may choose to maintain capital in excess of minimum regulatory requirements to satisfy market preferences. According to the safety net abuse view, banks that gain the most from increasing the value of the deposit insurance put option will securitize to a greater extent. Furthermore, if securitizing banks seek to maximize the value of these put options, then they would maintain capital levels close to minimum regulatory requirements (Calomiris and Mason, 2004). 6 The aggregated t-statistic is calculated as the mean coefficient divided by the aggregate standard deviation. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 18 (Adj. Pseudo R2 =22.3%). This is important, since a propensity score with lower explanatory power yields poorer matching, increasing the likelihood that inferences will be confounded by correlated omitted variables. The propensity score for each observation is the predicted probability from this logistic regression. I match securitizing banks with non-securitizing banks, employing nearest-neighbor matching, i.e. choosing the non-securitizing bank that has the closest propensity score to each securitizing bank. I impose a 1% tolerance level on the maximum propensity score distance allowed. I perform 1:1 treatment-control match on the overall bank data and match each observation from the treatment sample to an observation from the control sample quarterby-quarter. Once a match is made, I assume that match is the best match. Every quarter, previous matches are reconsidered before making the current match to minimize disjoint ranges of propensity scores. I allow each treatment-control match to have up to night missing quarterly observations but not more than four consecutive quarters. Matching process yields: 88 securitizing versus 88 non-securitizing banks (n=176). Covariate balance is achieved if the treatment and control groups exhibit similar levels of the explanatory variables. Adequate covariate balance is necessary to control for potential confounding effects. To assess covariate balance between the treatment and control groups, I estimate parametric t-tests of the difference in means of the explanatory variables between two samples. Table 3 presents these tests. None of the differences are statistically different, suggesting that the covariates are balanced across the treatment and control samples, mitigating the likelihood of confounding effects. 5.3. Testing Hypothesis 1 I test H1 by estimating the coefficients in the following three models using OLS: S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 19 Eq.(1) : U ncertaintyt = β0 + β1 SecF IRM + β2 SecF IRM ∗ P OST 2010 + Control V ariablest−1 + Eq.(2) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ P OST 2010 + Control V ariablest−1 + Eq.(3) : U ncertaintyt = β0 + β1 COM M BSt−1 + β2 COM M BSt−1 ∗ P OST 2010 + β3 CON SBSt−1 + β4 CON SBSt−1 ∗ P OST 2010 + β5 M BSt−1 + β6 M BSt−1 ∗ P OST 2010 + Control V ariablest−1 + 5.3.1. Primary Variables UNCERTAINTY is the information uncertainty of the firm. I use four constructs to measure information uncertainty: analyst forecast dispersion (DISPERSION), implied volatility (IMPLIED), stock illiquidity (ILLIQUIDITY) and bid-ask spread (SPREAD). DISPERSION is the degree of consensus among market participants and it is widely used as a proxy for information uncertainty in the prior literature (e.g., Lang and Lundholm 1996). The intuition for this proxy is the following: analysts have different functions of the amount of private information about the firm, holding the amount of public information constant (assuming positive). Different functions of private information mean that there is no consensus about the firm in the market which leads to information uncertainty (Barry and Jennings 1992; Bamber and Cheon 1998). When analysts use common public information more than their private information, the consensus among the forecasts will increase, and dispersion will decrease, all else being equal. I calculate DISPERSION as the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement. 7 7 In an alternative test, I calculate DISPERSION as the standard deviation of analysts’ one-quarter-ahead earnings forecasts in the month preceding the month of the earnings announcement, scaled by the absolute S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 20 My second proxy for information uncertainty is IMPLIED. Braun, Nelson, and Sunier (1995) propose that at the market level, realized volatility rises sharply in response to bad news and falls in response to good news. Their results suggest an association between investor sentiment and volatility. Fleming (1998) argues that IMPLIED measures market sentiment relating to perceived risk. Supported by these studies, I use IMPLIED to capture risk perception, an important component of information uncertainty. For each option price quote, OptionMetrics calculates the option’s implied volatility using, American or European models where appropriate. All option calculations use historical LIBOR/Eurodollar rates for interest rate inputs, and correctly incorporate discrete dividend payments. My third and fourth proxies for information uncertainty are ILLIQUIDITY, and SPREAD, respectively. The vast majority of literature uses bid-ask spread and stock illiquidity to measure information asymmetry among investors (traders) 8 . The justification for using these two measures in my study as proxies for information uncertainty is as follows: Information uncertainty in the market is likely to generate greater private information search, since private information is expected to resolve the uncertainty. This will lead to groups of investors or traders who are privately informed, relative to other investors. As such, the information uncertainty in the market will also generate information asymmetries among investors (traders). Additionally, analytical research provides support for the link between information uncertainty and asymmetry. For instance, Routledge and Zin (2009) present a model where there is uncertainty about the probability distribution for the underlying firm’s future cash-flows. Their model exhibits that when the investor is uncertain about the dynamic consequences of his trading activities, this uncertainty increases bid-ask spreads and reduces liquidity. I use the illiquidity measure described in Amihud (2002) to capture stock illiquidity. Amihud’s illiquidity measure is daily absolute stock return divided by the $ trading volume in value of the mean forecast. The results remain unchanged. 8 The intuition for using bid-ask spread and stock illiquidity as a proxy for information asymmetry is as follows: when information asymmetry among market participants is high, informed traders can exploit their informational advantage at the expense of uninformed traders. The market participants recognize the adverseselection problem, trading costs increase with the degree of information asymmetry between the uninformed and informed investors. This will result in a wider bid-ask spread and lower stock liquidity (e.g., Kyle 1985; Glosten and Milgrom 1985; Amihud and Mendelson 1991, 1986). S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 21 thousands calculated as: |RETi,m,d |/V OLi,m,d , where |RETi,m,d | is the absolute return on firm i on day d of month m, and V OLi,m,d is the respective daily volume in dollars. Following prior research (e.g., Balakrishnan, Billings, Kelly and Ljungqvist 2012), the cross-sectional study in this paper employs for each bank i the quarterly average of the Amihud’s measure as follows: ILLIQU IDIT Yi,t,q Di,t,q 1 X |RETi | = Di,t,q 1 V OLi I measure SPREAD as the quarterly average of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and bid, expressed in percentage terms (e.g., Ball, Jayaraman, and Shivakumar 2012). These are obtained from monthly data. Specifically, SP READi,t,q Mi,t,q 1 X (ASKi − BIDi ) ∗ 100 = Mi,t,q 1 (ASKi + BIDi )/2 Where Mi,t,q is the number of months in quarter q of year t for bank i for which closing monthly bids (BIDi ) and closing monthly asks (ASKi ) are available 9 . SecFIRM is a dummy variable equal to one for banks with securitization activities, and zero for control firms. ABS is total securitized assets scaled by the total assets. COMMBS is commercial securitized assets (commercial and industrial loans and all other loans and leases), CONSBS is consumer securitized assets (credit card receivables, home equity lines of credit, automobile loans, and other consumer loans), and MBS is mortgages (1-4 family residential mortgages). All three of them are scaled by total assets and for non-securitizing these variables take value of 0. For non-securitizing banks, it takes value of zero. POST2010 is a dummy variable equal to one if the observation falls in the post-FAS 166/167 period. I expect SecFIRM and ABS to be positively associated and POST2010 to be negatively associated with the dependent variables. I employ quarter-year fixed effects in my models. The quarter-year fixed effects subsume any non-interaction effect of POST2010 and control for time trends, allowing a clean identification 9 In an alternative analysis, I measure SPREAD as the quarterly mean of daily bid-ask spread, scaled by the closing stock price. The results remain unchanged. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 22 of the incremental effect of SecFIRM (ABS) through the coefficient on SecFIRM * POST2010 (ABS * POST2010). This coefficient can be interpreted as the incremental change in information uncertainty between the pre and post periods for banks with securitizing activities relative to those without. 5.3.2. Control Variables To ensure that results are not driven by differences in bank characteristics, I use nine control variables. First, reflecting findings in the previous literature, I control for market-to-book value (MTBV) and bank size (SIZE). I expect a negative association between my dependent variables. To control for risk retained through contractual obligations, I include total retained interest from all asset securitizations scaled by total assets (RETAINED). To control for differences in bank asset composition, I include the proportion of on-balance-sheet net loans to total assets (LOAN RATIO). To control the riskiness of on-balance-sheet loans, I include charge-offs on onbalance-sheet loans scaled by total assets (CHGOFF ONBS), and past due on-balance-sheet loans scaled by total assets (NPL ONBS). I expect these variables to be positively associated with my dependent variables. I include two variables to capture differences in banks’ (a) use of risk management products, (b) technical sophistication, and (c) dependence on securitization income. First, I use securitization income and servicing fees scaled by total net income (SECINC). Second, I use total notional amount of interest rate derivatives scaled by total assets (DERIVATIVES). I have no expectation for the coefficient on DERIVATIVES because they can be used for either hedging or speculation. I expect the coefficient on the SECINC to be positive if this variable captures the operational risks associated with securitizations incremental to my other securitization variables (Chen, Liu, and Ryan 2008). To control for bank regulatory capital, I include the tier 1 risk-based capital ratio (TIER1). Banks with lower risk tend to have higher capital (e.g., Dionne and Harchaoui 2003). Thus, I predict a negative association between TIER1 and UNCERTAINTY. Finally, to control for market sentiment, I include VIX- a measure of the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. A higher value of VIX indicates lower sentiment. Therefore, I expect VIX to be positively associated with my dependent S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 23 variables. 5.3.3. Results Table 4 presents the results from estimating Eq. (1). The first column of Table 4 shows results from using DISPERSION as the dependent variable. SecFIRM is significantly positive (t = 5.72). Thus, securitizing banks are positively associated with information uncertainty as opposed to non-securitizing banks in the pre-FAS 166/167 period. As predicted, the interaction variable (SecFIRM * POST2010) is significantly negative (t = -4.64). The signs of the coefficients on the control variables are mostly consistent with my predictions with two exceptions. I do not make any prediction of how derivatives would affect information uncertainty. Results show that DERIVATIVES is positively associated with information uncertainty (t = 6.59). Prior research (e.g., Minton, Stulz and Williamson 2009) finds that banks are more likely to use interest rate derivatives if they are engaged in asset securitization. Given the level of complexity and illiquidity of some derivatives, it is possible that the use of derivatives also leads to increased bank information uncertainty. Hence, a positive coefficient on DERIVATIVES is not surprising. On the other hand, I find an insignificant coefficient on LOAN RATIO (t = -1.55). Prior studies find mixed results with respect to whether more loans increase risk, and information uncertainty. It is more likely that in my analysis, the loan risk is captured by other bank attributes included in my models. The significance and the interpretation of the control variables generally do not change for the rest of my study. In the second column of Table 4, IMPLIED is the dependent variable. The coefficients on SecFIRM, and SecFIRM * POST2010 are statistically significant (t = 3.62, and t = -3.56, respectively). In the third column, I use ILLIQUIDITY as the dependent variable. While SecFIRM is significantly positive (t = 5.23), SecFIRM * POST2010 is significantly negative (t = -4.66) suggesting that information uncertainty of securitizing banks decrease in the post-FAS 166/167 period. In the fourth column, SPREAD is the dependent variable. The coefficient on SecFIRM is significantly positive (t = 4.55). The interaction variable, SecFIRM * POST2010, that is the focus of my study is significantly negative (t = -4.39). These results altogether support H1 in that information uncertainty decrease in the post-FAS 166/167 period as opposed to pre-FAS 166/167 period for banks with securitizing activities. Thus, I conclude that FAS S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 24 166/167 achieve the objective of improving transparency of securitizing banks through enhanced disclosure requirements in FAS 166/167. Table 5 presents the results from estimating Eq. (2). This analysis uses ABS to capture the volume of total securitized assets. The results are similar to the analysis of SecFIRM. In the first column of Table 5, ABS is positively associated with DISPERSION (t = 6.42), and ABS * POST2010 is negatively associated with DISPERSION (t = -4.28). In the second column of Table 5, SecFIRM is positively associated with IMPLIED (t = 4.24), and ABS * POST2010 is negatively associated with IMPLIED (t = -4.42). In the third column, ABS is positively associated with ILLIQUIDITY (t = 5.71), and ABS * POST2010 is negatively associated with ILLIQUIDITY (t = -4.11). In the fourth column of Table 5, with SPREAD as the dependent variable I find similar results. ABS is positively associated with SPREAD (t = 5.72), and as predicted this association becomes negative in the post-FAS 166/167 period (t = -4.62). Significance of control variable remains similar to the previous analysis. Results in both Table 5 is consistent with those in Table 4, and they support H1 that information uncertainty is positively associated with total securitized assets in the pre-FAS 166/167 period, but this association becomes negative in the post-FAS 166/167 period. Table 6 presents the results from estimating Eq. (3). This analysis uses three general characteristics of banks’ asset securitizations - COMMBS, CONSBS and MBS - to capture differences in banks’ securitizations portfolio. Chen, Liu and Ryan (2008) argue and provide evidence that commercial loans have relatively high and difficult to verify credit risk, consumer loans have relatively high but easier to verify credit risk, and mortgages have relatively low and easy to verify credit risk. Consistent with their evidence, I predict that commercial loans are more positively associated with information uncertainty than consumer loans and mortgages, while consumer loans are more positively associated with uncertainty than mortgages. The results are consistent with this prediction and also similar to the previous results. COMMBS, CONSBS and MBS are all positively associated with all four proxies of information uncertainty. The interaction variables between types of securitizations and POST2010 yield negative association, suggesting a decrease in the information uncertainty of securitizations. Consistent with previous literature, the coefficient on COMMBS is bigger than CONSBS, and the coefficient S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 25 on CONSBS is bigger than MBS. In accordance with this result, I observe a greater decrease in the information uncertainty of COMMBS while this decrease lessens more for COMNS and MBS. Results in Table 4,5 and 6 are all consistent with each other, and they support H1 that information uncertainty is positively associated with total securitized assets in the pre-FAS 166 and FAS 167 period, but this association becomes negative in the post-FAS 166 and FAS 167 period. Estimating three different OLS models allows me to observe the continuing impact of FAS 166 and FAS 167 on securitizing banks. The first model gives a broader result concerning securitizing and non-securitizing banks and documents the initial evidence of these standards on securitizing banks. The second and third models strengthen this result by providing evidence that decrease in the information uncertainty remain significant when I detangle securitizing banks’ loan portfolios. Overall, results in Table 4, 5 and 6 provide support for H1 that indicates FAS 166 and FAS 167’s effectiveness in decreasing information uncertainty about securitizations. A decrease in information uncertainty of securitizing banks from the pre- to the post-FAS 166 and FAS 167 periods suggests better and more information about securitizations to market participants and hence an improvement in bank transparency. An important caveat of my study is the potential confounding effects of the financial crisis of 2007-2009. The evidence of transparency improving for securitizing banks in the post-FAS 166 and FAS 167 might be (partially) caused by the fading effects of the crisis. In Section 6, I discuss this possibility and conduct additional analyses to rule out the possibility that my results are driven by the confounding effects of the crisis. After conducting robustness tests, my results still support my predictions that information uncertainty about securitizations decrease in the post-FAS 166/167 period. 5.4. Testing Hypothesis 2 I test H2 by estimating the following models using OLS: S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 26 Eq.(4) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ P OST 2010 + β3 V IEt−1 + β4 V IEt−1 ∗ P OST 2010 + Control V ariablest−1 + Eq.(5) : U ncertaintyt = β0 + β1 COM M BSt−1 + β2 COM M BSt−1 ∗ P OST 2010 + β3 CON SBSt−1 + β4 CON SBSt−1 ∗ P OST 2010 + β5 M BSt−1 + β6 M BSt−1 ∗ P OST 2010 + β7 V IEt−1 + β8 V IEt−1 ∗ P OST 2010 + Control V ariablest−1 + 5.4.1. Primary Variables Because banks with consolidated VIEs are mostly securitizing banks, I estimate Eq. (3) only for my treatment sample, for which ABS is always non-zero. VIE reflects a bank’s involvement with these entities. I measure this variable as the proportion of consolidated VIEs’ assets to remaining total assets. VIE * POST2010 is the interaction variable, reflecting the bank’s involvement with the VIEs in the post-FAS 166 and FAS 167 period. While I expect VIE to be positive if FAS 166/167 decrease the information uncertainty about securitizing banks’ involvement with VIEs, I expect VIE * POST2010 to be negative. Firm and quarter-year fixed effects are employed in the models. The quarter-year fixed effects subsume any non-interaction effect on POST2010. The rest of the variables are as defined in the previous models. 5.4.2. Results Table 7 presents the results from estimating Eq. (4). In the first column, I use DISPERSION as the dependent variable. The coefficient on ABS and ABS * POST2010 show a decrease in information uncertainty about total securitized assets from the pre-FAS 166/167 period to the post-FAS 166/167 period, as seen in previous results (t = 3.99, and t = -3.74). The coefficient on VIE is significantly positive (t = 3.13). The positive association between information uncertainty and VIE implies that market did not fully understand securitizing banks’ involvement with VIE in the pre-FAS 166/167 period. There are two reasons for this result. First, if a bank has consolidated VIEs, this might imply that the bank is involved with many off-balance-sheet S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 27 activities. There might be many nonconsolidated VIEs about which investors would have less information. Such perception will increase the information uncertainty for banks with consolidated VIEs. Second, when a bank consolidates VIEs, the information about these VIEs and their components (e.g., assets, liabilities) is disclosed in its financial statements. Investors can access this information easily; however, they might not have the level of sophistication required to analyze these entities (i.e., determine the risk involved with these entities). This can be partially caused by the insufficient regulations, which proves the validity of FAS 166/167. I find that the coefficient on VIE * POST2010 is significantly negative (t = -3.39). The second column presents a similar result when IMPLIED is the dependent variable. The coefficients on ABS is significantly positive (t = 3.16) while ABS * POST2010 is significantly negative (t = -3.41). VIE is significantly positive (t = 2.98). The coefficient on the interaction variable, VIE * POST2010, is significantly negative (t = -2.69). The result suggests that for securitizing banks, information uncertainty decreases in the consolidated VIEs from the preFAS 166/167 period to the post-FAS 166/167 period. Third column presents results when I use ILLIQUIDITY as the dependent variable. Results exhibit similar results for ABS and ABS * POST2010 to the previous ones (t = 3.30, t = -2.52, respectively). VIE is significantly positive (t = 3.51). As predicted the coefficient on VIE * POST2010 is negative (t = -3.03), suggesting a decrease in the information uncertainty from the pre-FAS 166/167 to the post-FAS 166/167 period. Parallel results occur when I use SPREAD as the dependent variable. The coefficient on ABS is significantly positive (t = 3.53), the coefficient on ABS * POST2010 is significantly negative (t = -2.73) and the coefficient on VIE is significantly positive (t = 3.14). The interaction variable is again significantly negative (t = -2.73). As a robustness test, I estimate Eq. (5) to examine whether the coefficient on VIE * POST2010 remains significantly negative when different loan characteristics are taken into account The results in Table 8 support my prediction. COMMBS, CONSBS and MBS are all positively associated with four proxies of information uncertainty in the pre-FAS 166 and FAS 167 period, but these associations become negative in the post-FAS 166 and FAS 167 period. As predicted in H2, I find a positive association between VIE and information uncertainty in the pre-FAS 166 and FAS 167 period, and the interaction variable between VIE * POST2010 S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 28 becomes negative. The evidence in Table 7 and 8 suggests that in the pre-FAS 166 and FAS 167 periods, information about VIEs were not entirely reflected in the financial statements, which caused information uncertainty because market participants couldn’t entirely assess banks’ involvement with these entities. My results provide evidence that information uncertainty of a securitizing bank decreases MORE from the pre- to the post-FAS 166 and FAS 167 period with their involvements with consolidated VIEs. My results support that FAS 166 and FAS 167 in fact improve financial reporting of securitizing banks with regard to VIEs. I conclude that the accounting changes about VIEs in FAS 166 and FAS 167 improve transparency of securitizing banks. 5.5. Testing Hypothesis 3 I test H3 by estimating the following model using OLS: Eq.(6) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ P OST 2010 + β3 RECOU RSE M CRt−1 (or RECOU RSE REVt−1 ) + β4 RECOU RSE M CRt−1 ∗ P OST 2010 (or RECOU RSE REVt−1 ∗ P OST 2010) + Control V ariablest−1 + 5.5.1. Primary Variables Implicit recourse is the non-contractual support that a securitizing bank provides to securitization vehicles. To capture the likelihood of a bank providing implicit recourse I use two different proxies 10 . First proxy is managed capital ratio (RECOURSE MCR). Capital ratio can be perceived as an emergency buffer to support on balance sheet loans. The idea in using managed capital ratio is to take off-balance sheet securitized loans into account, which gives a 10 Cheng et. al. (2011) uses a first factor from a principal component analysis using total securitized assets, securitization income, past due loans, charge-offs, and total retained interest from all asset securitizations. Their measure captures both explicit and implicit recourse, and for that reason it is not suitable for my study. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 29 better sense about the vulnerabilities of a bank’s means to support its loans. The intuition to use managed capital ratio as a proxy for implicit recourse proxy is as follows. Banks keep the risks of securitized assets on their balance sheets by providing implicit recourse to securitization vehicles. When a securitizing bank anticipates providing non-contractual support it may choose to increase its regulatory capital to ensure enough capital to support these vehicles. It is also likely that a bank provide implicit recourse to reduce its regulatory capital requirements without reducing their asset risk. To the best of my knowledge there are very few studies, which focus on implicit recourse practice, and none of them provide evidence in the banks’ behavioral dilemma mentioned above. Calomiris and Mason (2004) provide preliminary evidence that many banks adjust their capital ratio in the anticipation of implicit recourse rather than take advantage of reduced capital requirements. Therefore, I use managed capital ratio to capture the likelihood of a bank’s providing implicit recourse. I assume that a securitizing bank will adjust its capital requirements if there is an anticipation of implicit recourse practice, so I assume a positive relation between managed capital ratio and implicit recourse practice. I measure managed capital ratio by following Calomiris and Mason (2004). It is calculated as tier 1 capital ratio plus tier 2 capital ratio divided by on-balance-sheet assets plus off-balance sheet credit card receivables. It is likely that banks provide recourse to other securitized assets too, which are not included in this definition of managed capital ratio. In practice, credit card securitizations are a clear example of recourse. Calomiris and Mason (2004) establish that credit card securitizers maintain capital ratios relative to the sum of on- and off-balance-sheet assets that are lower than those of non-securitizing credit card banks or of all banks. Thus, to increase the homogeneity of my recourse proxy, I solely focus on credit card receivables. Second proxy is RECOURSE REV, which is calculated as the sum of all revolving loans (home equity lines and credit card receivables). Implicit recourse generally is an issue only for securitizations of revolving loans with no fixed maturity, in particular, credit card receivables and home equity lines of credit. Because the principal in revolving loan securitizations fluctuates with uncertain future borrowings and payments on the revolving loans, issuers typically must contribute or remove loans from the SPEs as needed to maintain the outstanding principal at the desired levels. Because of the ongoing relationship between issuers and the SPEs in S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 30 these securitizations, issuers have the incentive to maintain their reputation to facilitate future securitizations. Thus, the nature of revolving loans yields incentives for issuers to provide implicit recourse to avoid losing the financing provided by the ABS (Chen, Liu and Ryan 2008). When calculating RECOURSE REV, I don’t need to make any assumptions with regard to banks’ capital requirements. This allows me to analyze implicit recourse practice on a broader perspective. However, the problem with this proxy is that I dismiss other type loans. It might be less frequent for other type of loans to need non-contractual support but because of that it might cause even more information uncertainty. However, these drawbacks will only cause a bias against finding support for H3 by decreasing the power of my proxies. I estimate Eq. (6) only for my treatment sample. Prior literature establishes that securitization recourse is positively associated with information uncertainty, thus I expect both implicit recourse proxies to be positive. The main variable that my study is interested in is the interaction variable RECOURSE MCR * POST2010 (or RECOURSE REV * POST2010). If FAS 166 and FAS 167 mitigates the impact of implicit recourse on the information uncertainty of the securitizing banks, I expect the interaction variable to be negative. Both firm and quarter-year fixed effects are employed in my models. The quarter-year fixed effects subsume any non-interaction effect on POST2010. The rest of the variables are as defined in the previous models. 5.5.2. Results Table 9 presents the results from estimating Eq. (4). The first column presents the results with DISPERSION as the dependent variable. Consistent with my overall results, the coefficient on ABS is significantly positive (t = 4.00), and the coefficient on ABS * POST2010 is significantly negative (t = -2.74). The coefficient on RECOURSE MCR is significantly positive (t = 3.74). This result is consistent with the findings of Cheng, Dhaliwal and Neamtiu (2011). As predicted, I find that the coefficient on the interaction variable, RECOURSE MCR * POST2010, is significantly negative (t = -2.65). The result suggests that the information uncertainty about a securitizing bank providing recourse decrease in the post-FAS 166/167 period. The second column of Table 9 presents the results with IMPLIED as the dependent variable. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 31 The coefficients on ABS, ABS * POST2010, and RECOURSE are statistically significant (t = 3.71, t = -3.35, and t = 3.81, respectively). While the coefficient on RECOURSE MCR * POST2010 has the predicted negative sign, it is statistically insignificant (t = -1.45). However, this result does not contradict H3 hypothesis. The significant positive association between information uncertainty and RECOURSE in the pre-FAS 166 and FAS 167 period is now insignificant, which shows that information uncertainty about implicit recourse has lessened in the post-FAS 166 and FAS 167 period. The insignificant association is probably caused by the limited sample size. In the third column, I use ILLIQUIDITY as the dependent variable. I find that ABS is significantly positive (t = 5.34), and ABS * POST2010 is significantly negative (t = -3.13). I find a positive association between RECOURSE MCR and ILLIQUIDITY (t = 3.27). This suggests that RECOURSE MCR cause information uncertainty in the pre-FAS 166 and FAS 167, which is consistent with prior literature’s findings. However, what differs from the prior literature, this association becomes negative in the post-FAS 166 and FAS 167 period (t = -2.51). In the last column of Table 9, SPREAD is the dependent variable. The coefficients on ABS, ABS * POST2010, and RECOURSE are statistically significant (t = 3.23, t = -3.90, t = 2.85, respectively). On the other hand, the interaction variable RECOURSE * POST2010 is significantly negative (t = -3.72). These results provide statistical evidence that FAS 166 and FAS 167 mitigates the impact of implicit recourse on the information uncertainty about securitizing banks. Table 10 presents results from estimating Eq. (6) with RECOURSE REV. Since I use some portion of securitized asset in my recourse variable, I can’t include ABS as an independent variable. Instead I use OTHER ABS, which is all securitized assets except home equity lines and credit card receivables. The results in Table 10 are very similar with my previous analysis. RECOURSE REV is positively associated with all proxies of information uncertainty in the pre-FAS 166 and FAS 166 period but as predicted this association becomes negative in the post-FAS 166 and FAS 167 period. My analysis of implicit recourse show significant but relative to my other tests less strong results. Information uncertainty of securitizing banks decreases MORE from the pre- to the S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 32 post-FAS 166 and FAS 167 period with their involvement with implicit resource practice. Unfortunately my implicit recourse proxies are not perfect and they don’t capture all the angles of implicit recourse. However, I still provide compelling evidence that FAS 166 and FAS 167 decrease uncertainty caused by the banks’ practice of implicit recourse. 6. Robustness Tests My sample period runs from 2003 to 2011, so the financial crisis falls right in the sample period. Thus, an important caveat of the study is the potential confounding effects of the financial crisis of 2007-2009. A complete chronology of the recent financial crisis might start in February 2007, when several large subprime mortgage lenders started to report losses. However, most salient shock regarding market liquidity came on August 9, 2007, when the French bank BNP Paribas temporarily halted redemptions from three of its funds because it could not reliably value assets backed by U.S. subprime mortgages held in the funds. Financial firms worldwide began to question the value of a variety of collateral they had been accepting in their lending operations. The result was a sudden hoarding of cash and cessation of interbank lending, which led to severe liquidity constraints on many financial institutions (Cecchetti 2009). Distress in this market is evident from the behavior of the (London Inter-Bank Offered Rate) LIBOR . It is a key interest rate used to price various consumer and business loans, including a variety of mortgages. LIBOR can be compared to the federal funds market because both involve uncollateralized loans. Figure 3 plots the difference between the one-month fixedrate LIBOR and the monthly average federal funds rate. The divergence between these two rates is typically less than 20 basis points. This small gap arises from an arbitrage that allows a bank to borrow at LIBOR, lend for one month, and hedge the risk that the overnight rate will move in the federal funds futures market, leaving only a small residual level of credit and liquidity risk that accounts for the usually small spread. However, on August 9, 2007, the difference between these two interest rates jumped to 40 basis points. The “LIBOR spread” continued to deteriorate with investor and institution flight into safe securities through the winter of 2008. In 2009, the fluctuations in LIBOR spread started to diminish. Starting in S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 33 June 2009, the spread was again less than 20 basis points like before the financial crisis. This evidence indicates that the effects of the financial crisis diminished in 2009 before the effective date of FAS 166/167. I conduct four alternate analyses to take the financial crisis into effect. First, to test the possibility that the previously presented results might be driven by the financial crisis of 20072009, I estimate the following model using OLS for the treatment and control samples: Eq.(7) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ BEG CRISIS + β3 ABSt−1 ∗ EN D CRISIS + β4 ABSt−1 ∗ P OST 2010 + Control V ariablest−1 + Based on the LIBOR spread, I create two crisis dummy variables. BEG CRISIS is a dummy variable, which takes value 1 if the observation falls between 2007:Q3 and 2008:Q4. END CRISIS is a dummy variable, which takes value 1 if the observation falls between 2009:Q1 and 2009:Q4. The expectation is that uncertainty is positively associated with BEG CRISIS dummy variable but negatively associated with END CRISIS dummy variable. If my main results presented in Tables 4, 5 and 6 are driven by the confounding effects of the financial crisis no significant association between information uncertainty and POST2010 * ABS should occur. I employ f quarter-year fixed effects in my model. The quarter-year fixed effects subsume any non-interaction effect of time dummy variables. The rest of the variables are as defined in the previous models. Table 11 presents the results from estimating Eq. (7). ABS is significantly positive for all four dependent variables. The key point in this analysis is the interaction between ABS and crisis dummy variables. Using all four dependent variables; DISPERSION, IMPLIED, ILLIQUIDITY and SPREAD I present a significantly positive association between the dependent variables and ABS * BEG CRISIS (t = 1.98, t = 2.11, t = 2.14, t = 2.01, respectively) at 5% level, and a significantly negative association between the dependent variables and ABS * END CRISIS (t = -1.65, t = -1.65, t = -1.88, t = -1.67, respectively) at 10 Second, I estimate the following model: S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 34 Eq.(8) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ 2007Q1 + β3 ABSt−1 ∗ 2007Q2 + [. . .]+ + β12 ABSt−1 ∗ 2009Q3 + β13 ABSt−1 ∗ 2009Q4 + β14 ABSt−1 ∗ P OST 2010 + Control V ariablest−1 + I create a time dummy variables for each quarter between 2007 and 2010. If my results presented in Tables 4, 5 and 6 are driven by the confounding effects of the financial crisis I should not observe any significant association between information uncertainty and POST2010 * ABS interaction variable and interaction variables between 2009 time dummy variables and ABS should capture the decrease in information uncertainty. I employ quarter-year fixed effects in my models. The quarter-year fixed effects subsume any non-interaction effect of time dummy variables. The rest of the variables are as defined in the previous models. Table 12 presents the results from estimating Eq. (8). ABS is significantly positive for all four dependent variables. The analysis reveals that information uncertainty about total securitized assets increase from 2007 to 2008 in every quarter. This increase stops in 2009, and most interactions variables between ABS and 2009 time dummy variables become statistically insignificant. As expected, these results show that information uncertainty about total securitized assets increase from 2007Q3 until 2008Q4 and even it starts diminishing in the last quarters of 2009, the most significant decrease in information uncertainty starts after 2010. I find that the coefficients on ABS * POST2010 are negative for all four dependent variables (t = -3.77, t = -3.30, t = -3.20, t = -3.38, respectively) at 1% level. These results support my primary findings. While 2009 quarter time dummy variables are insignificant and ABS * POST2010 is significantly negative the magnitude and the sign of the coefficients are very similar. One can interpret this result as such that the decrease in information uncertainty of securitizing banks partially starts in 2009. Such an interpretation is not entirely implausible. In 2009, FASB issued FSP (FASB Staff Position FIN 140-4) on disclosures about transfers of financial assets S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? and interests in variable interest entities transactions 11 35 . FAS 166 and FAS 167 superseded FSP. While most of the disclosures in FAS 166 and FAS 167 are identical to those included in the FSP, the FASB decided to enhance certain disclosures included in the FSP and expand their scope to all transfers of financial assets and not just for securitizations and asset-backed financing arrangements, as required by the FSP. Additionally, unlike the FSP, which applies only to public entities, the disclosure requirements of FAS 166 and FAS 167 apply to both public and non-public entities. The issuance of FSP suggests an anticipation period for the disclosures mandated by FAS 166 and FAS167 in the market. Such anticipation might cause a partial decrease in the information uncertainty of securitizing banks in 2009. This result does not contradict with my primary results since FSP included similar disclosures about the transfer of financial assets to FAS 166 and FAS 167. In fact, a decrease in information uncertainty of securitizing banks following FSP supports my conjecture that changes in disclosures about the transferred of financial assets and variable interest entities improved information environment of securitizing banks. Third, I estimate the following model: Eq.(9) : U ncertaintyt = β0 + β1 ABSt−1 + β2 ABSt−1 ∗ P OST 2009 + β3 ABSt−1 ∗ P OST 2010 + β4 ILLIQU IDIT Yt−1 + β5 ILLIQU IDIT Yt−1 ∗ P OST 2009 + β5 ILLIQU IDIT Yt−1 ∗ P OST 2010 + Control V ariablest−1 + In this model, I only use DISPERSION and IMPLIED as two proxies of information uncertainty.. Financial crisis of 2007-2009 caused serious illiquidity problems on banks. It is fair to assume that the impact of financial crisis started to lessen when banks started getting relief on their illiquidity problems. I include ILLIQUIDTY as an independent variable to capture ‘the lessening impact of the financial crisis’. I assume that ILLIQUIDITY will capture any 11 Please see Figure 2 S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 36 portion of information uncertainty attributable to the financial crisis, and then if I still find a significantly negative association between UNCERTAINTY and BAS in the post-FAS 166 and FAS 167 period, I can attribute this incremental decrease to the effectiveness of FAS 166 and FAS 167. Table 13 presents results from estimating Eq. (9). As expected, ILLIQUIDTY is positively associated with UNCERTAINTY at all time periods. But ILLIQUIDTY is less positively associated with UNCERTAINTY in the post-crisis and FAS 166 and FAS 167 periods. This is consistent with the fact that the effects of the financial crisis started to fade away after 2009. I find ABS to be positively associated with DISPERSION and IMPLIED in the preFAS 166 and FAS 167 period (t = 4.65, t = 4.19, respectively). In the post 2009 period, ABS is negatively associated with DISPERSION and IMPLIED, but these associations are not statistically significant (t = -0.75, t = -1.08, respectively). Most importantly, ABS has significant negative association between DISPERSION and IMPLIED in the post-FAS 166 and FAS 167 period (t= -2.87, t=-2.49, respectively). All together, these results suggest that the decrease in the information uncertainty of securitizing banks in the post-FAS 166 and FAS 167 period is in fact not attributable to the financial crisis, but mainly to the effectiveness of these standards. In the last analysis to rule out the effect of the financial crisis of 2007-2009, I exclude the financial crisis from my sample period. Therefore, I limit the pre-FAS 166/167 period between 2005:Q1 and 2007:Q2, and the post-FAS 166/167 period between 2010:Q1 and 2011:Q4. Then, I estimate Eq. (2) with the adjusted sample period. The results presented in Table 8, Panel B remain very similar to previously presented analysis in Table 5. ABS * POST2010 remains significantly negative for all four dependent variables. All four analyses provide enough evidence that my main results presented in Tables 4, 5 and 6 are not driven by the fading effects of the financial crisis of 2007-2009, and thus H1 has sufficient support. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 37 7. Concluding Remarks In this study, I examine whether information uncertainty about banks’ securitization activities decreases in the post- versus pre-FAS 166 and FAS 167 period. I use dispersion in analysts’ earnings forecasts, implied volatility, stock illiquidity, and bid-ask spread to capture different aspects of information uncertainty. I predict and find that (i) securitizing banks experience a decrease in information uncertainty compared to non-securitizing banks from the pre- to the post-FAS 166 and FAS 167 periods; (ii) information uncertainty of total securitized assets decreases from the pre- to the post-FAS 166 and FAS 167 periods; (iii) information uncertainty of securitizing banks is negatively associated with their involvement with consolidated VIEs in the post-FAS 166 and FAS 167 period; and (iv) information uncertainty of securitizing banks is negatively associated with implicit recourse in the post-FAS 166 and FAS 167 period. Additional analyses conducted to rule out the confounding effects of the financial crisis of 2007-2009 confirm the findings. In the empirical models, I control for a host of variables that prior research shows to be associated with banks’ equity risk, banks’ loan portfolio composition, banks’ regulatory capital, and banks’ operating performance. My study has direct implications for equity market participants. The results highlight the benefits of FAS 166 and FAS 167 for the market participants and provide evidence that these standards bring more clear information about securitizations to market participants. Also, this study has direct implications for accounting regulators. These results indicate that reporting standards improve the bank transparency. My study also brings up new research questions for future. One avenue for future research is to examine whether FAS 166 and FAS 167 change banks’ risk taking behavior. Prior theoretical research suggests that less information uncertainty in the market leads less risk taking by managers, but securitizing banks exhibit more risk taking ex ante. Thus, it is open empirical question how FAS 166 and FAS 167 would affect risk taking behavior of banks. Last, research to further our understanding of implicit recourse is necessary. While implicit recourse is very crucial part of securitizations, because it is difficult to empirical measure, its implications are not very well understood. S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 38 References Altamuro, J. L. M. (2006). The Determinants of Synthetic Lease Financing and the Impact on the Cost of Future Debt. SSRN eLibrary. Retrieved from http://ssrn.com/paper=951514 Ambrose, B., LaCour-Little, M., & Sanders, A. (2005). Does Regulatory Capital Arbitrage, Reputation, or Asymmetric Information Drive Securitization? Journal of Financial Services Research, 28(1), 113-133. doi: 10.1007/s10693-005-4358-2 Amihud, Y. (2002). Illiquidity and stock returns: cross-section and time-series effects. 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Retrieved from http://eprints.law.duke.edu/1538/1/2004_U._Ill._L._Rev._1.pdf Vermilyea, T. A., Webb, E. R., & Kish, A. A. (2008). Implicit recourse and credit card securitizations: What do fraud losses reveal? Journal of Banking & Finance, 32(7), 1198-1208. doi: 10.1016/j.jbankfin.2007.10.004 Figure 1: Structure of a SPE in a Securitization S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 43 Figure 2: Timeline of FAS 166 and FAS 167 S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 44 Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? Figure 3: LIBOR Spread During the Financial Crisis of 2007-2009 S. Oz 45 5.066 0.133 0.328 0.831 0.677 0.005 0.010 0.203 SIZE EQU IT Y RAT IO LIQU IDIT Y RAT IO DEP OSIT RAT IO LOAN RAT IO CHGOF F RAT IO N P L RAT IO T IER1 U nique Banks N umber of M ean V ariables 8325 0.349 0.021 0.246 0.164 0.123 0.133 0.133 4.225 Std.Dev. All Banks 0.142 0.011 0.003 0.715 0.757 0.284 0.116 16.949 426 0.093 0.009 0.032 0.158 0.168 0.168 0.074 62.229 Std.Dev. 0.213 0.010 0.061 0.676 0.830 0.348 0.133 1.413 M ean 7899 0.328 0.020 1.106 0.164 0.113 0.174 0.092 2.797 Std.Dev. Banks Banks M ean Non-Securitizing Securitizing -0.071 0.000 -0.058 0.039 -0.072 -0.064 -0.017 15.536 M ean 0.0000 0.3458 0.2967 0.0093 0.0000 0.0003 0.0001 0.0000 Std.Dev. (Percentage) Difference in Means Descriptive Statistics for Securitizing and Non-Securitizing Banks SIZE is the natural logarithm of total assets. EQUITY RATIO is the total equity divided by total assets. LIQUIDITY RATIO is the sum of cash, available-for-sale securities, trading assets, federal funds sold, and securities purchased with intent to resell, scaled by total assets. DEPOSIT RATIO is the quarterly average for all interest-bearing deposits, scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. TIER1 is the tier 1 risk based capital ratio. Table 1: Descriptive Statistics S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 46 233, 454 0.223 Adj. R − squared N umber of Observations Y es -0.569 Bank Dummies +/− + EQU IT Y RAT IO T IER1 -1.030 − DEP OSIT RAT IO 0.501 0.394 -0.156 0.227 Coef f icient Avg. + +/− + P rediction LOAN RAT IO LIQU IDIT Y RAT IO SIZE = SecF IRM Dependent V ariable -2.16 6.42 -6.76 7.07 -2.11 233, 454 0.187 No -1.423 1.211 -1.877 0.477 -0.218 0.329 Coef f icient t − statistic 8.08 Avg. Aggr. -2.44 7.73 -6.81 8.02 -2.54 9.47 t − statistic Aggr. Aggregated estimates of the ordered logistic propensity-score regression of the securitization likelihood SIZE is the natural logarithm of total assets. LIQUIDITY RATIO is the sum of cash, available-for-sale securities, trading assets, federal funds sold, and securities purchased with intent to resell, scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. DEPOSIT RATIO is the quarterly average for all interest-bearing deposits, scaled by total assets. EQUITY RATIO is the total equity divided by total assets. TIER1 is the tier 1 risk based capital ratio. Table 2: Propensity Score Regression S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 47 0.774 0.842 0.187 0.196 LOAN RAT IO DEP OSIT RAT IO EQU IT Y RAT IO T IER1 U nique Banks 88 0.273 LIQU IDIT Y RAT IO N umber of 8.339 88 0.201 0.187 0.844 0.778 0.273 8.357 Control T reatment SIZE M ean M ean M atchedSample -0.005 0.000 -0.002 -0.004 0.000 -0.018 Dif f erence 0.9112 0.9945 0.9874 0.9712 0.9961 0.7872 values p− Test statistics of covariate distributions for the treatment (Securitizers) and the control (Non-securitizers) samples SIZE is the natural logarithm of total assets. LIQUIDITY RATIO is the sum of cash, available-for-sale securities, trading assets, federal funds sold, and securities purchased with intent to resell, scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. DEPOSIT RATIO is the quarterly average for all interest-bearing deposits, scaled by total assets. EQUITY RATIO is the total equity divided by total assets. TIER1 is the tier 1 risk based capital ratio. Table 3: Covariate Balance S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 48 2.804 *** − + + + + RET AIN ED LOAN RAT IO CHGOF F RAT IO N P L ON BS SECIN C + V IX 0.472 0.498 4, 827 Adj. R − squared N umber of Observations 3, 184 Y es 0.183 *** -0.251 *** 0.895 *** 2.020 *** 6.407 *** 3.618 ** -0.210 3.393 *** -0.684 *** -0.452 *** -0.943 *** 2.062 *** 0.692 ** 10.45 -4.50 2.69 5.41 3.33 2.43 -0.78 3.17 -9.89 -2.68 -3.56 3.62 2.05 Estimates t − value Y es 15.48 -5.39 6.59 2.64 2.39 2.53 -1.55 3.42 -5.15 -1.83 -4.64 5.72 2.15 t − value Implied 4, 189 0.488 Y es 0.228 *** -0.518 *** 0.680 *** 2.505 *** 5.481 *** 3.937 *** -0.441 3.002 *** -0.586 *** -0.346 ** -1.348 *** 2.354 *** 0.454 ** Estimates 11.56 -3.72 6.81 5.97 3.97 4.90 -0.56 5.74 -3.02 -2.49 -4.66 5.23 2.07 t − value Illiquidity 4, 189 0.512 Y es 0.245 *** -0.161 *** 0.354 *** 3.885 *** 4.795 *** 4.472 *** -0.933 2.686 *** -0.685 *** -0.121 ** -1.003 *** 2.821 *** 0.789 ** Estimates 12.41 -5.19 8.63 6.66 2.86 3.56 -0.71 5.37 -3.26 -2.12 -4.39 4.55 1.97 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects -0.802 *** − T IER1 0.075 *** 0.062 *** 1.801 *** 5.499 ** 5.143 ** +/− DERIV AT IV ES -0.201 *** − M T BV -0.348 -0.072 * − SIZE 2.308 *** -1.711 *** + − SecF IRM ∗ P OST 2010 0.709 ** Estimates SecF IRM +/− Intercept P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on SecFIRM (dummy variable for securitizing banks), POST2010 (dummy variable for the post-FAS 166 and FAS 167 period), and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: SecFIRM is a dummy variable equal to 1 if a bank is a securitizing bank. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 4: SecFIRM Analysis, OLS Estimation of Equation (1) S. Oz 49 4.016 *** − + + + + RET AIN ED LOAN RAT IO CHGOF F RAT IO N P L ON BS SECIN C + V IX 0.461 0.522 4, 827 Adj. R − squared N umber of Observations 3, 184 Y es 0.237 *** -0.286 *** 0.934 ** 1.309 *** 6.065 *** 1.445 ** -0.708 4.836 *** -0.488 *** -0.053 *** -1.890 *** 3.762 *** 0.795 ** 10.54 -4.78 2.57 5.33 4.19 2.55 -1.04 9.05 -10.06 -3.35 -4.42 4.24 3.19 Estimates t − value Y es 16.09 -5.91 2.66 3.11 2.61 2.24 -0.13 3.52 -4.06 -2.14 -4.28 6.42 2.49 t − value Implied 4, 189 0.508 Y es 0.182 *** -0.210 *** 1.041 *** 2.094 *** 5.927 *** 2.553 *** -0.340 2.029 *** -0.149 *** -0.063 ** -1.346 *** 2.639 *** 0.830 ** Estimates 12.95 -4.58 2.75 6.12 3.71 4.26 1.47 5.63 -3.15 -2.18 -4.11 5.71 2.55 t − value Illiquidity 4, 189 0.512 Y es 0.093 *** -0.343 *** 0.651 *** 2.266 *** 4.286 *** 1.723 *** -0.124 3.110 *** -0.331 ** -0.088 ** -1.232 *** 2.786 *** 0.335 ** Estimates 12.53 -5.00 8.16 4.20 3.04 3.75 0.96 5.24 -2.45 -2.22 -4.62 5.72 2.24 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects -0.283 *** − T IER1 0.087 *** 0.690 *** 1.794 *** 5.003 *** 1.527 ** +/− DERIV AT IV ES -0.113 *** − M T BV -0.662 -0.038 ** − SIZE 2.488 *** -1.392 *** + − 0.680 ** ABS ∗ P OST 2010 +/− Estimates ABS Intercept P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on ABS (total securitized assets), POST2010 (dummy variable for the post-FAS 166 and FAS 167 period), and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets scaled by total assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 5: ABS Analysis, OLS Estimation of Equation (2) S. Oz 50 The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on COMMBS, CONSBS, MBS (total securitized assets by loan type), POST2010 (dummy variable for the post-FAS 166 and FAS 167 period), and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: COMMBS is securitized commercial loans (commercial and industrial loans and all other loans, leases, and assets) scaled by total assets. CONSBS is securitized consumer loans (home equity lines of credit, credit card receivables, automobile loans, and other consumer loans) scaled by total assets. MBS is securitized 1-4 family residential mortgages scaled by total assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. CONTINUED Table 6: COMMBS, CONSBS, and MBS Analysis, OLS Estimation of Equation (3) S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 51 − + +/− M T BV RET AIN ED LOAN RAT IO -0.043 *** − + T IER1 V IX Y es 0.561 4, 827 T ime F ixed Ef f ects Adj. R − squared N umber of Observations 0.074 *** 0.364 *** 0.361 ** 2.791 ** 1.148 *** -0.667 1.935 *** 0.982 *** -1.521 *** 1.071 *** -1.750 *** +/− DERIV AT IV ES + − SIZE + − M BS ∗ P OST 2010 SECIN C + M BS N P L ON BS -0.117 *** − CON SBS ∗ P OST 2010 + -0.081 ** + CON SBS CHGOF F ON BS -1.174 *** − COM M BS ∗ P OST 2010 0.619 ** + 2.336 *** +/− COM M BS 15.83 -5.05 4.51 2.36 2.24 2.69 1.16 3.58 -3.71 -2.11 -3.20 4.51 -3.84 4.33 -3.21 4.38 2.31 3, 184 0.487 Y es 0.062 *** -0.123 *** 1.378 ** 1.521 *** 3.687 *** 0.245 ** -0.007 3.763 *** -0.096 *** -0.022 *** -0.790 *** 1.400 *** -1.368 *** 1.913 *** -1.247 *** 2.125 *** 0.552 *** 10.23 -3.87 2.48 4.67 3.79 2.09 -0.18 5.92 -4.19 -2.87 -2.90 4.16 -3.28 4.23 -3.28 4.95 3.06 Estimates t − value Estimates t − value Intercept P rediction Implied Dispersion Table 6, continued 4, 189 0.488 Y es 0.201 *** -0.015 *** 0.417 *** 1.248 *** 2.379 *** 0.422 *** 0.278 * 3.393 *** -0.050 ** -0.028 ** -1.037 *** 0.910 *** -1.164 *** 1.610 *** -1.242 *** 2.209 *** 0.483 *** Estimates 13.09 -2.98 3.25 3.92 3.94 4.04 1.93 5.29 -2.02 -2.01 -3.54 5.44 -2.97 5.33 -2.86 5.10 3.13 t − value Illiquidity 4, 189 0.467 Y es 0.047 *** -0.032 *** 0.271 *** 1.298 *** 2.777 *** 0.349 *** 0.822 * 2.955 *** -0.025 ** -0.027 ** -1.591 *** 0.887 *** -1.692 *** 0.927 *** -1.715 *** 2.305 *** 0.060 ** Estimates 12.77 -3.58 3.56 2.83 2.79 3.61 1.65 5.60 -2.09 -1.97 -3.52 5.45 -3.30 5.51 -3.27 5.63 2.77 t − value Spread S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 52 +/− + − + − − − − + + + + +/− − + Y es 0.524 2, 455 0.565 * 2.611 *** -1.032 *** 1.873 *** -0.975 *** -0.400 * -0.303 *** 3.264 *** -0.206 4.349 ** 3.779 ** 1.998 ** 0.973 * -0.822 ** 0.387 ** Estimates 1.88 3.99 -3.74 3.13 -3.39 -1.93 -4.72 3.31 -0.75 2.39 2.55 1.96 1.66 -2.22 2.12 t − value Y es 0.501 1, 456 0.794 ** 2.337 *** -1.070 *** 1.903 *** -1.093 *** -0.981 ** -0.642 *** 2.055 *** -0.666 2.743 * 4.060 ** 1.829 *** 0.560 ** -0.929 ** 0.309 *** 2.45 3.16 -3.41 2.98 -2.69 -2.49 -6.18 2.92 -0.87 1.65 2.28 2.82 2.39 -2.43 4.07 Estimates t − value Implied Y es 0.499 2, 098 0.668 ** 2.243 *** -1.188 ** 2.093 *** -1.094 *** -0.841 ** -0.420 *** 3.235 *** -0.224 3.337 ** 4.769 *** 1.038 *** 0.848 ** -0.154 ** 0.265 ** Estimates 2.01 3.30 -2.52 3.51 -3.03 -2.53 -3.02 3.49 -1.37 2.46 2.81 2.01 2.55 -2.08 4.11 t − value Illiquidity Y es 0.496 2, 098 0.604 ** 2.986 *** -1.181 *** 2.088 *** -0.937 *** -0.431 ** -0.737 ** 3.803 *** -0.140 3.695 ** 4.013 *** 2.026 *** 0.650 ** -0.161 ** 0.130 ** Estimates 2.11 3.53 -2.73 3.14 -2.73 -2.57 -3.41 3.03 -1.23 2.34 2.84 2.94 2.32 -2.18 3.97 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects Adj. R − squared N umber of Observations Intercept ABS ABS ∗ P OST 2010 V IE V IE ∗ P OST 2010 SIZE M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C DERIV AT IV ES T IER1 V IX P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on VIE (a securitizing bank’s involvement with variable interest entities), POST2010 (dummy variable for the post-FAS 166 and FAS 167 period), and control variables for the treatment sample. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets scaled by total assets. VIE is a securitizing bank’s involvement with VIEs (variable interest entities), calculated as the total assets of consolidated VIEs scaled by total assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 7: VIE Analysis, OLS Estimation of Equation (4) S. Oz 53 The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on VIE (a securitizing bank’s involvement with variable interest entities), POST2010 (dummy variable for the post-FAS 166 and FAS 167 period), and control variables for the treatment sample. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: COMMBS is securitized commercial loans (commercial and industrial loans and all other loans, leases, and assets) scaled by total assets. CONSBS is securitized consumer loans (home equity lines of credit, credit card receivables, automobile loans, and other consumer loans) scaled by total assets. MBS is securitized 1-4 family residential mortgages scaled by total assets. VIE is a securitizing bank’s involvement with VIEs (variable interest entities), calculated as the total assets of consolidated VIEs scaled by total assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. CONTINUED Table 8: VIE Analysis - Robustness, OLS Estimation of Equation (5) S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 54 T ime F ixed Ef f ects Adj. R − squared N umber of Observations Intercept COM M BS COM M BS ∗ P OST 2010 CON SBS CON SBS ∗ P OST 2010 M BS M BS ∗ P OST 2010 V IE V IE ∗ P OST 2010 SIZE M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C DERIV AT IV ES T IER1 V IX +/− + − + − + − + − − − + +/− + + + +/− − + P rediction Y es 0.501 2, 455 3.26 4.77 -2.94 5.08 -3.30 5.26 -3.05 3.84 -3.83 -2.55 -2.71 4.33 -1.52 3.02 2.51 2.36 5.00 -4.69 16.11 Y es 0.492 1, 456 0.052 *** 1.907 *** -1.226 *** 1.420 *** -0.632 *** 1.102 *** -0.426 *** 1.301 *** -0.541 *** -0.015 ** -0.390 *** 2.802 *** -0.003 3.056 ** 2.508 *** 0.861 *** 0.853 *** -0.090 *** 0.049 *** 3.85 5.28 -3.03 5.17 -2.28 4.71 -2.58 3.30 -3.84 -2.40 -3.53 5.93 -1.02 2.57 3.85 5.34 3.07 -3.05 11.12 Estimates t − value Estimates t − value 0.025 *** 2.083 *** -0.949 *** 1.699 *** -0.747 *** 1.369 *** -0.493 *** 1.691 *** -0.789 *** -0.054 ** -0.444 *** 2.695 *** -0.254 3.427 *** 1.503 ** 0.123 ** 0.289 *** -0.006 *** 0.031 *** Implied Dispersion Table 8, continued Y es 0.454 2, 098 0.385 *** 1.923 *** -0.992 *** 1.500 *** -0.691 *** 1.459 *** -0.594 *** 1.406 *** -0.662 *** -0.020 ** -0.342 ** 2.442 *** 0.085 ** 3.243 *** 2.235 *** 1.153 *** 0.093 *** -0.007 *** 0.172 *** Estimates 4.01 5.79 -3.47 5.94 -2.21 5.52 -3.45 3.56 -2.59 -2.51 -2.01 5.59 2.28 4.29 4.54 4.10 3.86 -3.40 13.65 t − value Illiquidity Y es 0.495 2, 098 0.035 *** 1.809 *** -1.236 *** 1.785 *** -0.729 *** 1.438 *** -0.630 *** 1.306 *** -0.612 *** -0.007 ** -0.003 ** 2.199 *** 0.233 * 3.122 *** 2.665 *** 0.879 *** 0.262 *** -0.080 *** 0.037 *** Estimates 3.11 5.75 -3.55 5.64 -2.40 5.11 -2.65 3.75 -2.59 -1.99 -1.37 5.94 1.95 4.13 3.80 3.22 4.32 -3.32 13.69 t − value Spread S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 55 +/− + − + − − − − + + + + +/− + Y es 0.521 2, 455 0.554 1.932 *** -1.013 *** 0.086 *** -0.028 *** -0.549 ** -0.891 *** 2.380 *** -0.771 1.095 1.148 0.878 * 0.154 * 0.059 ** 1.43 4.00 -2.74 3.74 -2.65 -2.21 -4.03 3.89 -1.45 0.33 0.35 1.70 1.65 1.99 Y es 0.514 1, 456 0.283 1.376 *** -0.927 *** 0.113 *** -0.079 -0.192 ** -0.528 *** 2.820 *** -0.974 2.026 1.963 1.785 * 0.836 ** 0.168 ** 1.01 3.71 -3.35 3.81 -1.45 -2.51 -3.91 3.13 -0.84 0.31 0.91 1.77 2.45 1.95 Estimates t − value Estimates t − value Y es 0.497 0, 098 0.626 1.644 *** -0.634 *** 0.093 *** -0.058 ** -0.640 *** -0.490 *** 2.726 *** -0.534 0.400 3.823 1.607 * 0.319 * -0.156 *** Estimates 0.54 5.34 -3.13 3.27 -2.51 -2.63 -3.16 3.60 1.43 0.08 0.64 1.67 1.85 2.79 t − value Illiquidity Y es 0.503 2, 098 0.623 1.919 *** -0.813 *** 0.214 *** -0.030 *** -0.108 ** -0.134 *** 0.918 *** -0.587 0.963 4.012 2.687 * 0.241 *** -0.390 ** Estimates 0.80 3.23 -3.90 2.85 -3.72 -2.25 -3.58 3.76 -1.11 0.41 0.42 1.79 2.60 2.00 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects Adj. R − squared N umber of Observations Intercept ABS ABS ∗ P OST 2010 RECOU RSE M CR RECOU RSE M CR ∗ P OST 2010 SIZE M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C DERIV AT IV ES V IX P rediction Implied Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on RECOURSE (a securitizing bank’s likelihood of providing implicit recourse), POST2010 (dummy variable for the post-FAS 166/167 period), and control variables for the treatment sample. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets. RECOURSE MCR is the likelihood of a securitizing bank providing implicit recourse, calculated as tier 1 capital ratio plus tier 2 capital ratio divided by on-balance-sheet assets plus off-balance sheet credit card receivables. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 9: RECOURSE Analysis 1, OLS Estimation of Equation (6) S. Oz 56 +/− + − + − − − + +/− + + + +/− − + Y es 0.521 2, 455 0.015 1.557 *** -0.689 *** 1.102 *** -0.272 *** -0.331 * -0.226 *** 2.255 *** 0.884 * -0.029 0.566 -0.307 * 0.020 ** -0.124 *** 0.009 *** 1.47 5.98 -3.41 6.75 -2.71 -1.89 -2.63 3.06 1.87 -0.34 0.63 -1.65 2.48 -5.32 2.72 Estimates t − value Y es 0.495 1, 456 0.315 ** 1.406 *** -0.444 *** 1.396 *** -0.278 *** -0.085 * -0.301 *** 0.248 *** 0.424 ** -0.067 0.947 -0.175 * 0.246 ** -0.178 *** 0.008 ** Estimates 2.03 4.34 -2.85 4.09 -2.77 -1.94 -2.62 3.89 2.07 -0.03 0.55 -1.77 2.30 -4.01 2.12 t − value Implied Y es 0.487 2, 098 0.240 *** 1.811 *** -0.592 *** 1.311 *** -0.364 ** -0.428 * -0.002 ** 2.840 *** 0.972 ** -0.034 0.054 -0.116 * 0.109 *** -0.214 *** 0.054 *** Estimates 3.32 5.91 -2.88 5.32 -2.50 -1.78 -2.69 3.74 2.52 -0.56 0.97 -1.70 2.69 -4.11 2.85 t − value Illiquidity Y es 0.511 2, 098 0.023 *** 1.853 *** -0.530 *** 1.215 *** -0.352 ** -0.007 * -0.287 *** 2.478 *** 0.404 * -0.163 0.994 -0.137 * 0.286 * -0.091 *** 0.017 *** Estimates 5.65 5.51 -3.79 5.50 -2.48 -1.86 -2.78 3.32 1.74 -0.08 0.83 -1.83 1.71 -4.32 2.83 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects Adj. R − squared N umber of Observations Intercept OT HER ABS OT HER ABS ∗ P OST 2010 RECOU RSE REV RECOU RSE REV ∗ P OST 2010 SIZE M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C DERIV AT IV ES T IER1 V IX P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on RECOURSE (a securitizing bank’s likelihood of providing implicit recourse), POST2010 (dummy variable for the post-FAS 166/167 period), and control variables for the treatment sample. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: OTHER ABS is the total securitized assets minus revolving securitized loans (total of home quity lines of credit and credit card receivables) scaled by total assets. RECOURSE REV is the likelihood of a securitizing bank providing implicit recourse, calculated as the revolving securitized loans (total of home quity lines of credit and credit card receivables) scaled by total assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 10: RECOURSE Analysis 2, OLS Estimation of Equation (6) S. Oz 57 6.100 * + V IX Y es 0.458 4, 827 T ime F ixed Ef f ects Adj. R − squared N umber of Observations 11.35 -5.55 5.48 1.97 1.85 1.85 -0.25 3.23 -4.35 -1.64 -3.01 -1.65 1.98 4.27 1.74 3, 184 0.412 Y es 0.022 *** -0.180 *** 2.120 ** 1.960 *** 10.060 *** 1.890 ** -0.023 10.290 *** -0.240 *** -0.060 ** -2.030 *** -1.000 * 2.010 ** 1.030 *** 0.533 ** Estimates 8.74 -4.12 1.96 4.66 3.30 1.97 -0.96 3.01 -9.42 -2.11 -3.03 -1.65 2.11 3.57 1.96 t − value Implied 4, 189 0.435 Y es 0.447 *** -0.317 *** 0.508 *** 3.607 *** 5.577 *** 1.120 *** 1.437 * 3.557 *** -0.376 *** -0.389 *** -1.233 *** -0.663 * 2.537 ** 1.497 *** 0.862 ** Estimates 9.66 -4.53 8.78 6.61 2.72 3.12 1.63 4.38 -2.83 -3.09 -3.87 -1.88 2.14 4.26 1.88 t − value Illiquidity 4, 189 0.417 Y es 0.024 *** -0.110 *** 0.081 *** 3.180 *** 5.150 *** 0.693 *** 1.010 3.130 *** -0.051 *** -0.038 ** -1.660 *** -1.090 * 2.110 ** 1.070 *** 0.435 ** Estimates 9.53 -4.66 8.65 6.48 2.59 2.99 1.10 4.25 -2.96 -2.22 -3.00 -1.67 2.01 4.13 1.75 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 0.021 *** -0.140 *** − T IER1 1.120 ** 0.020 *** + SECIN C -0.870 6.280 * +/− + N P L ON BS DERIV AT IV ES + +/− LOAN RAT IO CHGOF F ON BS + RET AIN ED 3.330 *** -0.060 * -0.480 *** − − -1.678 *** − ABS ∗ P OST 2010 SIZE -1.100 * M T BV 2.130 ** + − ABS ∗ EN D CRISIS 1.267 *** 0.735 * Estimates t − value ABS ∗ BEG CRISIS + +/− ABS Intercept P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on ABS (total securitized assets), crisis related time dummy variables, and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets scaled by total assets. BEG CRISIS. END CRISIS. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 11: Additional Analysis 1 - Financial Crisis of 2007-2009 , OLS Estimation of Equation (7) S. Oz 58 The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on ABS (total securitized assets), crisis related time dummy variables, and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets scaled by total assets. 2007Q1, 2007Q2, [. . . ], 2009Q4 represent time dummy variables for each quarter for 2007, 2008 and 2009. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. CONTINUED Table 12: Additional Analysis 2 - Financial Crisis of 2007-2009 , OLS Estimation of Equation (8) S. Oz Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? 59 -1.211 -1.232 * − − − − − − − − − − ABS ∗ 2007Q2 ABS ∗ 2007Q3 ABS ∗ 2007Q4 ABS ∗ 2008Q1 ABS ∗ 2008Q2 ABS ∗ 2008Q3 ABS ∗ 2008Q4 ABS ∗ 2009Q1 ABS ∗ 2009Q2 ABS ∗ 2009Q3 -0.541 *** 2.737 *** − − + + + + M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C -0.153 *** − + T IER1 V IX Y es 0.433 4, 827 Adj. R − squared N umber of Observations 2.31 11.46 -5.64 6.34 1.98 2.60 2.26 -0.51 3.10 -2.88 -2.03 -3.77 1.56 1.52 1.52 1.12 2.40 2.30 2.40 2.56 2.56 2.55 2.41 2.98 4.82 0.408 *** 3, 184 0.451 Y es 0.079 *** -0.198 *** 0.058 ** 1.897 ** 3.373 *** 3.872 ** -0.559 1.851 *** -0.778 *** -0.096 *** -1.517 *** -1.763 * -1.724 * -0.833 -0.967 1.772 *** 0.333 *** 1.885 ** 1.756 *** 2.998 *** 1.086 *** 2.481 *** 2.605 *** 2.164 *** 2.80 8.91 -4.86 2.54 2.16 3.79 2.48 -1.04 3.30 -2.66 -2.98 -3.30 1.57 1.56 1.18 1.51 3.23 2.85 2.42 2.95 3.34 2.70 3.35 3.02 5.16 4, 189 0.421 Y es 0.094 *** -0.131 *** 0.268 *** 0.840 *** 2.353 *** 2.350 *** -0.279 * 1.581 *** -0.277 *** -0.128 *** -1.339 *** -0.145 * -0.720 -1.715 -1.301 0.890 *** 3.424 *** 0.268 *** 3.182 *** 1.601 *** 1.142 *** 1.365 ** 0.361 *** 2.998 *** 0.752 *** Estimates 10.19 -4.16 3.14 3.08 3.20 3.83 -1.12 3.14 -3.69 -3.35 -3.20 1.58 1.55 0.59 0.61 3.13 2.65 2.94 2.56 3.23 3.20 2.48 3.87 4.90 2.98 t − value Illiquidity 4, 189 0.412 Y es 0.096 *** -0.263 *** 0.530 *** 0.759 *** 2.818 *** 2.821 *** -0.526 2.848 *** -0.755 *** -0.026 ** -1.455 *** -1.318 * -0.172 -0.960 -0.450 0.467 *** 0.218 ** 2.125 *** 3.066 ** 1.508 ** 1.477 ** 1.277 *** 0.056 *** 1.150 *** 0.453 ** Estimates 9.94 -5.09 3.51 3.73 2.95 3.13 -0.13 4.73 -3.29 -3.11 -3.38 1.57 1.52 0.93 1.23 2.62 2.51 3.00 2.27 2.08 2.17 2.75 3.36 5.74 2.30 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects 0.043 *** 0.021 *** 1.252 ** 4.126 *** 4.452 ** +/− DERIV AT IV ES -0.055 ** − SIZE -0.835 -1.280 *** − − ABS ∗ 2009Q4 ABS ∗ P OST 2010 -1.266 -1.211 1.044 ** 0.365 ** 2.111 ** 2.496 *** 1.495 *** 1.543 ** 2.903 ** 1.820 *** − ABS ∗ 2007Q1 0.065 ** 2.882 *** + +/− Estimates t − value Estimates t − value ABS Intercept P rediction Implied Dispersion Table 12, continued S. Oz 60 +/− + − − + − +/− − − + +/− + + + +/− − + Y es 0.458 4, 827 0.827 * 2.685 *** -0.720 -0.956 *** 3.124 *** 1.312 *** 0.992 *** -0.590 -0.237 *** 4.192 *** 0.093 6.673 *** 6.685 ** 2.064 ** 0.341 *** -0.133 *** 0.152 *** Estimates 2.68 4.65 -0.75 -2.87 3.88 3.09 3.84 -1.33 -3.91 3.66 0.35 2.66 2.04 2.28 6.27 -5.24 11.78 t − value Y es 0.412 3, 184 0.910 ** 2.838 *** -0.624 -0.857 *** 2.984 *** 1.213 *** 0.942 *** -0.099 * -0.040 *** 10.696 *** -0.703 2.062 ** 10.076 *** 1.993 *** 2.566 *** -0.166 *** 0.582 *** Estimates 2.89 4.19 -1.08 -2.69 4.15 3.34 3.33 -1.75 -8.94 3.67 -0.64 2.32 3.65 5.19 2.65 -3.75 9.09 t − value Implied Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects Adj. R − squared N umber of Observations Intercept ABS ABS ∗ P OST 2009 ABS ∗ P OST 2010 ILLIQU IDIT Y ILLIQU IDIT Y ∗ P OST 2009 ILLIQU IDIT Y ∗ P OST 2010 SIZE M T BV RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C DERIV AT IV ES T IER1 V IX P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED) on ABS (total securitized assets), crisis related time dummy variables, and control variables for the treatment and control samples. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics. Independent variables: ABS is the total securitized assets scaled by total assets. ILLIQUIDITY is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume). POST2009 is a dummy variable equal to 1 if the observation falls between XX. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. CONTINUED Table 13: Additional Analysis 3 - Financial Crisis of 2007-2009 , OLS Estimation of Equation (9) S. Oz 61 2.280 *** − + + + + RET AIN ED LOAN RAT IO CHGOF F ON BS N P L ON BS SECIN C + V IX 0.398 0.421 2, 822 Adj. R − squared N umber of Observations 1, 870 Y es 0.049 *** -0.618 *** 0.307 *** 0.108 *** 4.744 *** 2.282 ** -0.186 2.882 *** -0.014 ** -0.057 ** -1.147 *** 2.208 *** 0.230 * 10.56 -5.21 2.68 4.84 3.54 2.42 -1.57 3.17 -2.59 -2.05 -3.10 4.04 1.83 Estimates t − value Y es 16.09 -3.62 2.90 2.17 2.24 2.66 -1.03 3.86 -3.52 -2.46 -3.60 5.53 2.23 t − value Implied 2, 550 0.411 Y es 0.089 *** -0.231 *** 0.846 ** 0.116 *** 3.865 *** 4.027 *** -0.093 3.012 *** -0.086 *** -0.175 ** -1.268 *** 2.435 *** 0.189 ** Estimates 12.48 -4.93 2.49 3.34 3.53 3.48 -1.37 4.91 -2.87 -2.40 -3.89 5.45 2.52 t − value Illiquidity 2, 550 0.386 Y es 0.027 *** -0.409 *** 0.274 *** 0.297 *** 3.404 ** 4.592 *** -0.701 2.106 *** -0.092 *** -0.177 ** -1.231 *** 2.780 *** 0.388 *** Estimates 12.76 -5.07 2.89 4.52 2.54 3.68 -1.36 5.26 -3.09 -2.43 -3.15 5.05 2.80 t − value Spread Did FAS 166 and FAS 167 Improve the Transparency of Securitizing Banks? T ime F ixed Ef f ects -0.474 *** − T IER1 0.134 *** 0.149 *** 0.157 ** 3.642 ** 3.810 *** +/− DERIV AT IV ES -0.313 *** − M T BV -0.666 -0.086 ** − SIZE 2.815 *** -1.086 *** + − 0.420 ** ABS ∗ P OST 2010 +/− Estimates ABS Intercept P rediction Dispersion The OLS regression of information uncertainty measures (DISPERSION, IMPLIED, ILLIQUIDITY, SPREAD) on ABS (total securitized assets), and control variables for the treatment and control samples. For this analysis, the sample period covers 2005:Q1-2006:Q4 vs. 2010:Q1-2011:Q4. Dependent variables are: (1) analysts’ earnings forecast dispersion (DISPERSION) is the standard deviation of quarterly analyst forecasts (with only the latest forecast retained per analyst) issued from one day after the prior earnings announcement to 1 day before the current on, scaled by the absolute value of the actual measure at the earnings announcement; (2) implied volatility (IMPLIED) is the given value in OptionMetrics; (3) Stock illiquidity (ILLIQUIDITY) is the quarterly average of the Amihud (2002) illiquidity measure (daily absolute return divided by the $ trading volume); (4) bid-ask spread (SPREAD) is the quarterly mean of the difference between the closing ask and the closing bid quotes scaled by the average of the ask and the bid, expressed in percentage terms. Independent variables: ABS is the total securitized assets. POST2010 is a dummy variable equal to 1 if the observation falls between 2010Q1 and 2011Q3. SIZE is the natural logarithm of total assets. MTBV is the market-to-book ratio. RETAINED is the total retained interest from all asset securitizations scaled by total assets. LOAN RATIO is the proportion of on-balance sheet net loans to total assets. CHGOFF ONBS is the charge-offs on on-balance sheet scaled by total assets. NPL ONBS is past due on-balance sheet loans scaled by total assets. SECINC is the securitization income and servicing fees scaled by total net income. DERIVATIVES is the total notional amount of interest rate derivatives scaled by total assets. TIER1 is the tier 1 risk based capital ratio. VIX is the implied volatility of S&P 500 index options by the Chicago Board Options Exchange. t-statistics are based on standard errors clustered by firm and quarter-year to correct for time-series and cross-sectional dependence respectively. ***, **, * represent statistical significance at 1%, 5%, 10% levels. Table 14: Additional Analysis 4 - Financial Crisis of 2007-2009, OLS Estimation of Equation (2) S. Oz 62