The collapse of Neil Woodford

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AlohaJoe
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The collapse of Neil Woodford

Post by AlohaJoe » Mon Jun 10, 2019 7:01 pm

US investors are unlikely to know the name Neil Woodford but UK investors certainly do. The name also comes up from time to time in Boglehead posts by UK investors, especially those who are convinced that active management works in the UK and that Woodford was exhibit #1 of that.

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The short version is: Woodford went from the top of the leaderboard to the bottom. Part of that is because Woodford began dabbling in holding shares of unlisted (e.g illiquid) companies[6]. Now a spiral has begun, the underperformance is causing investors to pull out but the large illiquid holding can't be unloaded except at firesale prices. At this point it seems plausible that Woodford's investing career is largely over. Woodford's fund has collapsed going from £10 billion to £3.7 billion[1]. And it is only that high because they suspended redemptions last week[4], so investors aren't allowed to take their money out. He is under investigation by UK regulators[2] and MPs[3]. His biggest investor abandoned him[5].

If you don't have a Financial Times account a free summary -- that argues this is evidence that even UK investors should stick with index funds -- can be read at:
https://www.evidenceinvestor.com/todays ... d-a-horse/

[1]: https://www.ft.com/content/6520fff2-879 ... ac2431f453
[2]: https://www.ft.com/content/583af87c-87a ... cea8523dc2
[3]: https://www.ft.com/content/7d1ed1f8-884 ... ac2431f453
[4]: https://www.ft.com/content/3cf0f180-883 ... cea8523dc2
[5]: https://www.ft.com/content/310c2164-87b ... ac2431f453
[6]: https://www.ft.com/content/275261ee-ebf ... 6339d835c0

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Re: The collapse of Neil Woodford

Post by Grt2bOutdoors » Mon Jun 10, 2019 7:04 pm

It was in the Wall Street Journal last week. The investment manager has risen gates to prevent a run on the fund.
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Re: The collapse of Neil Woodford

Post by Ferdinand2014 » Mon Jun 10, 2019 7:05 pm

He was discussed in the most recent Rick Ferri podcast #10 with Robin Powell and Debbie Fuhr.

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Re: The collapse of Neil Woodford

Post by Dantes » Mon Jun 10, 2019 7:09 pm

I liked
Anyway it’s a truth universally known that a man in possession of a large fortune, a super public profile, and a proven ability to beat the market generally wants to do it bigger and better.

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Re: The collapse of Neil Woodford

Post by retiringwhen » Mon Jun 10, 2019 7:17 pm

Dantes wrote:
Mon Jun 10, 2019 7:09 pm
I liked
Anyway it’s a truth universally known that a man in possession of a large fortune, a super public profile, and a proven ability to beat the market generally wants to do it bigger and better.
The contrast with John Neff could not be greater.

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Re: The collapse of Neil Woodford

Post by nedsaid » Tue Jun 11, 2019 2:36 am

Oh how the mighty has fallen.
A fool and his money are good for business.

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Re: The collapse of Neil Woodford

Post by Valuethinker » Tue Jun 11, 2019 2:55 am

retiringwhen wrote:
Mon Jun 10, 2019 7:17 pm
Dantes wrote:
Mon Jun 10, 2019 7:09 pm
I liked
Anyway it’s a truth universally known that a man in possession of a large fortune, a super public profile, and a proven ability to beat the market generally wants to do it bigger and better.
The contrast with John Neff could not be greater.
Perhaps closer than you think. We live in the age of the retail channel to market - you used to find out about these guys from articles in the WSJ or FT, nowadays the cult of the personality in fund managers is all via the internet - so they have to market themselves, performance alone won't sell the fund - that's partly about the channel to market which is now online via intermediaries like Hargreaves Lansdowne -- that's how you buy funds in the UK (remember Vanguard here did not have a direct retail operation until ?last year? normally you get done over if you buy funds directly from the manager).

Woodford kept a low profile at Invesco-Perpetual for a long time. He was not based in the City of London but 20 km west of London in Henley, a pretty tourist town on the Thames famous for its annual summer festival -- think rural Connecticut. It was quite a trek as there is no direct train for brokers. Latterly companies came to him to present, not he trek into the City. He was not one of the "city guys" beloved of the brokers and the financial press.

It actually caused him financial regulation problems, and they finally had to make his house a registered office of Invesco Perpetual, to allow him to continue to manage his funds (from his garage) ;-).

Other than a penchant for classic sports cars, he was a pretty quiet guy. The cult of personality really only emerged as the fund started to grow into the billions, and when he left Invesco-Perpetual to set up his own shop.

What he was guilty of was of changing his investment style. At I-P he was always "big cap yield" stocks, and had eschewed financials before (and after) the GFC -- so he managed to avoid both the worst of the tech crash in 2000-03, and the GFC in 2008-09. Hence the extraordinary outperformance against index. He's made a lot of money from big pharma, utilities tobacco etc. Call it a Minimum Volatility portfolio, done intuitively.

In his own shop he deviated into unquoted stocks, particularly biotech. Those bets might eventually come good, but they are volatile, and as the money flowed out of his fund due to recent underperformance, illiquidity became a problem.

The fund is now gated (no redemptions). And the short sellers are targeting his big holdings (he's actually been allowed to stop publishing his portfolio).

Peter Lynch's decision to get out at the very top of Magellan's performance (1990) seems more and more inspired. Not to go into competition with Fidelity but just to step out of the game when he was at the top.

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Re: The collapse of Neil Woodford

Post by bad1bill » Tue Jun 11, 2019 6:33 am

Valuethinker, thanks for the concise synopsis.....

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Re: The collapse of Neil Woodford

Post by Valuethinker » Tue Jun 11, 2019 7:19 am

bad1bill wrote:
Tue Jun 11, 2019 6:33 am
Valuethinker, thanks for the concise synopsis.....
You are welcome.

It's possible to be more negative on Neil Woodford.

I think the problem was he grew too big for his own good. Too large inflows. That made it harder for him to invest the money.

In addition his high dividend yield strategy (effectively a minimum volatility strategy, I think) went through one of its bad periods.

Performance dipped, that led to outflows. His holdings were now big enough that the selling lowered the value of what he was selling (the market could see him coming) which in turn worsened performance, and so on.

I don't defend some of his more desperate measures. His Patient Capital Trust (closed ended) was 60% in unquoted cos. 1). I would question his ability and expertise in that for a guy who had made his money in large cap dividend paying stocks* but 2). it did what it said it was on the tin when the fund was raised. It's now at a 30-40% discount to NAV but if one believes in the underlying investments, then fine.

But his main Equity Income fund (open ended) - that also had large, illiquid positions. Eventually a share exchange was worked out with PCT giving the EI fund 9% of PCT in exchange for its illiquid holdings (to keep below a 10% limit on unquoted holdings in the EI fund). There were some other tricks like listing holdings on Guernsey exchange (providing no real liquidity) so he could call them "quoted".

The source of the error was too have too much money and concentrate it on too small market cap bets-- taking too large a percentage of companies. The UK stock market is not that liquid below the top 50 stocks.

He should have closed the funds to new money when it became difficult to make his investments. Capped them in size billions of pounds smaller.

No doubt there will be further revelations of last minute desperation.

I don't think he was intrinsically a guy who believed in a cult of personality - but maybe that constant drum of promotion by intermediaries like Hargreaves-Lansdowne eventually got to his head.

* since he was such a large holder in Glaxo-Smithkline & Astra-Zeneca, down the years, I wonder if he got hints from management about where they were seeking to acquire/ expand, what innovative bioscience was promising, and that shaped his investments into biotech & biopharma.
Last edited by Valuethinker on Tue Jun 11, 2019 7:21 am, edited 1 time in total.

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Re: The collapse of Neil Woodford

Post by nisiprius » Tue Jun 11, 2019 7:41 am

Unfortunately, when stars are shining, the financial press is constantly telling us about them, and they are constantly being put forward as "couldn't be luck, proof of skill, proof that active management works." Then, when they blow up, they drop out of the news and the collective memory, totally. The funds get merged and can no longer be charted on Morningstar or Yahoo! Finance or PortfolioVisualizer.

The successes serve to bolster the active management myth. But the failures never count against it. It's all "you had to be there." Unless you can personally remember how often Bill Miller was in the news and the way everyone talked about him, the collapse of Legg Mason Value Trust means nothing.

Furthermore, people refuse to interpret the collapse as evidence that it was all luck in the first place. It is often interpreted as meaning "yes, they absolutely had it, they had the skill, active management works, but then they mysteriously lost it." Change in style? That seems to happen often in collapses. While Miller's fund was beating the S&P 500, people interpreted his actions in buying more of stocks that were dropping as being the true master strokes of a high-conviction value investor. When it collapsed, the same actions were re-interpreted as "doubling down on his bad bets."

It is reminiscent of the story a friend told me about going to Atlantic City and "winning" at the casino. Honestly, I did not challenge her, but in continuing discussion, it emerged that she had indeed won--on Saturday. Then she had lost, on Sunday. And she lost more on Sunday than she had won on Saturday, but in her mind it didn't count because on Sunday she failed to follow her 'system.' As I say, I wasn't cross-examining her so I don't know why she failed to follow it on Sunday--my guess is that it involved doubling up and had reached the point where it called for a terrifyingly humongous bet, but I don't know.

I am thinking that people are going to insist that Woodford's previous "Saturday" performance was skill, and that the subsequent "Sunday" collapse shouldn't count because he was no longer following his "system."
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Re: The collapse of Neil Woodford

Post by ReformedSpender » Tue Jun 11, 2019 7:50 am

Woodford got careless, investing in several suspect biotech companies



Greed I suppose
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Re: The collapse of Neil Woodford

Post by Toons » Tue Jun 11, 2019 9:09 am

Never heard of him


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Re: The collapse of Neil Woodford

Post by nedsaid » Tue Jun 11, 2019 10:20 am

Valuethinker wrote:
Tue Jun 11, 2019 7:19 am
bad1bill wrote:
Tue Jun 11, 2019 6:33 am
Valuethinker, thanks for the concise synopsis.....
You are welcome.

It's possible to be more negative on Neil Woodford.

I think the problem was he grew too big for his own good. Too large inflows. That made it harder for him to invest the money.

In addition his high dividend yield strategy (effectively a minimum volatility strategy, I think) went through one of its bad periods.

Performance dipped, that led to outflows. His holdings were now big enough that the selling lowered the value of what he was selling (the market could see him coming) which in turn worsened performance, and so on.

I don't defend some of his more desperate measures. His Patient Capital Trust (closed ended) was 60% in unquoted cos. 1). I would question his ability and expertise in that for a guy who had made his money in large cap dividend paying stocks* but 2). it did what it said it was on the tin when the fund was raised. It's now at a 30-40% discount to NAV but if one believes in the underlying investments, then fine.

But his main Equity Income fund (open ended) - that also had large, illiquid positions. Eventually a share exchange was worked out with PCT giving the EI fund 9% of PCT in exchange for its illiquid holdings (to keep below a 10% limit on unquoted holdings in the EI fund). There were some other tricks like listing holdings on Guernsey exchange (providing no real liquidity) so he could call them "quoted".

The source of the error was too have too much money and concentrate it on too small market cap bets-- taking too large a percentage of companies. The UK stock market is not that liquid below the top 50 stocks.

He should have closed the funds to new money when it became difficult to make his investments. Capped them in size billions of pounds smaller.

No doubt there will be further revelations of last minute desperation.

I don't think he was intrinsically a guy who believed in a cult of personality - but maybe that constant drum of promotion by intermediaries like Hargreaves-Lansdowne eventually got to his head.

* since he was such a large holder in Glaxo-Smithkline & Astra-Zeneca, down the years, I wonder if he got hints from management about where they were seeking to acquire/ expand, what innovative bioscience was promising, and that shaped his investments into biotech & biopharma.
Three reactions here. First, the thought flashed across my mind, "So much for the Illiquidity Premium." Larry Swedroe has posted a lot about the Illiquidity Premium and why it works. It sounds like Woodford did too much of a good thing. Second, I think of Warren Buffett's comments about circle of competence. Sounds like he ventured into things that were he was less knowledgeable. Third, this was style drift on steroids.

It sounds like he was off to a great start, not only in attitude but also in performance. But success and fame can get to the best of us, something that I have not experienced myself. It is really easy to be judgemental.
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Re: The collapse of Neil Woodford

Post by nisiprius » Tue Jun 11, 2019 10:33 am

nedsaid wrote:
Tue Jun 11, 2019 10:20 am
...Three reactions here. First, the thought flashed across my mind, "So much for the Illiquidity Premium."
Indeed. There likely is an illiquidity premium, but if so, it exists for a reason. I have a right to say "I don't personally have a taste for that dimension of risk." And while people may get overconfident as a result of a too-steady consistent rise in asset prices, I think a more serious problem is that people get overconfident about liquidity.

That's one of the things that bothers me about the enthusiasm for alternatives in general, and "liquid alts" in particular.

I don't think people sufficiently appreciate the value of the pesky restrictions imposed on mutual funds by the Investment Company Act of 1940.

But that raises another question: could it happen in the US? How different are US and UK mutual fund regulations? In the US, in theory, mutual funds guarantee daily liquidity, and actual settlement within seven days (of course it's usually much faster). And in theory, mutual funds are not allowed to invest more than 15% of their portfolio in illiquid issues. How different are the regulations in the UK, and why did they fail to protect investors in his fund? Yes, there have been problems in the US--it was an illiquidity problem that resulted in the crash of the Third Avenue Focused Credit fund in 2016. I have to say, though, that I never heard of the Third Avenue Focused Credit fund before it collapsed, and don't remember anyone in the forum suggesting it, while apparently the Woodford funds were showing up on "Wealth 50 recommendation lists."

Another big question is: would retail investors, let's say average Bogleheads, have had any inkling that there was anything seriously wrong (other than aggressive or innovative investing?) I personally feel skeptical when I find that a mutual fund is holding assets in e.g. a Cayman Islands subsidiary, even when all the sophisticates tell me that there's nothing at all wrong with that. It seems to me that the only reason for holding assets offshore is that they don't meet regulatory requirements for holding them directly. In this case, "trying to list unquoted shares in the island of Guernsey" sounds... bizarre.
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Re: The collapse of Neil Woodford

Post by nedsaid » Tue Jun 11, 2019 10:53 am

nisiprius wrote:
Tue Jun 11, 2019 10:33 am
nedsaid wrote:
Tue Jun 11, 2019 10:20 am
...Three reactions here. First, the thought flashed across my mind, "So much for the Illiquidity Premium."
Indeed. There likely is an illiquidity premium, but if so, it exists for a reason. I have a right to say "I don't personally have a taste for that dimension of risk." And while people may get overconfident as a result of a too-steady consistent rise in asset prices, I think a more serious problem is that people get overconfident about liquidity.

That's one of the things that bothers me about the enthusiasm for alternatives in general, and "liquid alts" in particular.

I don't think people sufficiently appreciate the value of the pesky restrictions imposed on mutual funds by the Investment Company Act of 1940.

But that raises another question: could it happen in the US? How different are US and UK mutual fund regulations? In the US, in theory, mutual funds guarantee daily liquidity, and actual settlement within seven days (of course it's usually much faster). And in theory, mutual funds are not allowed to invest more than 15% of their portfolio in illiquid issues. How different are the regulations in the UK, and why did they fail to protect investors in his fund? Yes, there have been problems in the US--it was an illiquidity problem that resulted in the crash of the Third Avenue Focused Credit fund in 2016. I have to say, though, that I never heard of the Third Avenue Focused Credit fund before it collapsed, and don't remember anyone in the forum suggesting it, while apparently the Woodford funds were showing up on "Wealth 50 recommendation lists."

Another big question is: would retail investors, let's say average Bogleheads, have had any inkling that there was anything seriously wrong (other than aggressive or innovative investing?) I personally feel skeptical when I find that a mutual fund is holding assets in e.g. a Cayman Islands subsidiary, even when all the sophisticates tell me that there's nothing at all wrong with that. It seems to me that the only reason for holding assets offshore is that they don't meet regulatory requirements for holding them directly. In this case, "trying to list unquoted shares in the island of Guernsey" sounds... bizarre.
For the record, all of my investments are liquid except of course for my home. I do not own any Alternative funds and I do not own any Interval Funds. I have an Advisor that works with 30% of my retirement funds but I make all the decisions and there isn't a lot of turnover. My theory is that boring is good. Watching my portfolio is as exciting as watching paint dry, the grass grow, and tumbleweeds tumbling. This is the way it should be.

Larry Swedroe recommends 4 alt funds, 3 are interval funds with limited liquidity and the fourth is a liquid Alt fund. The recommendations I have seen are 20% of a portfolio, 10% from the equity side and 10% from the fixed income side. So a 60/40 portfolio would then be 50% stocks/30% bonds/20% alts. So the interval funds might be as much as 15% of a portfolio and that is probably okay. Buckingham might have a bit different formula, but what I have mused here is probably pretty close. I think illiquidity is good and could help an individual investor working with an advisory firm, but good things can be overdone. Don't go overboard on illiquidity.

By the way, the interval funds are semi-liquid. Given what they invest in, that is probably a good thing.
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Re: The collapse of Neil Woodford

Post by AlohaJoe » Tue Jun 11, 2019 11:01 am

nisiprius wrote:
Tue Jun 11, 2019 10:33 am
How different are US and UK mutual fund regulations?
A bit of a tangent but I was shocked to learn recently that insider trading was perfectly legal in the UK up until 1993.

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Re: The collapse of Neil Woodford

Post by matjen » Tue Jun 11, 2019 11:02 am

Valuethinker wrote:
Tue Jun 11, 2019 7:19 am
I don't defend some of his more desperate measures. His Patient Capital Trust (closed ended) was 60% in unquoted cos. 1). I would question his ability and expertise in that for a guy who had made his money in large cap dividend paying stocks* but 2). it did what it said it was on the tin when the fund was raised. It's now at a 30-40% discount to NAV but if one believes in the underlying investments, then fine.
Great stuff Valuethinker. The one thing I would add* is that there is a fair amount of "resulting" going on here it seems to me. I don't believe in great man stock picking on a large scale in this day and age, just index or quant buy/hold/rebalance for me. However, if one was a superstar and came out with his own fund to have an ER like this seems actually really fair. Didn't turn out as we now know but I give him credit.

Image

*I really don't know a ton about him at all but came across this ER and thought I would point it out.
Last edited by matjen on Tue Jun 11, 2019 11:07 am, edited 1 time in total.
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Re: The collapse of Neil Woodford

Post by LFS1234 » Tue Jun 11, 2019 11:03 am

AlohaJoe wrote:
Mon Jun 10, 2019 7:01 pm

The short version is: Woodford went from the top of the leaderboard to the bottom. Part of that is because Woodford began dabbling in holding shares of unlisted (e.g illiquid) companies[6]. Now a spiral has begun, the underperformance is causing investors to pull out but the large illiquid holding can't be unloaded except at firesale prices.
This is not an unusual situation. There is nothing inherently wrong with investing in illiquid assets, but doing so can be problematic when this is done by a fund whose investors have the expectation of liquidity on demand.

In the (US) Go-Go era of the late 1960s, some high-flying funds were notorious for investing in illiquid "letter stock" at low prices and immediately marking it up many-fold; and more recently lots of hedge funds have invested in difficult-to-value assets (e.g. extremely expensive NYC condos) which they keep on their books at whatever prices their accountants will allow them to justify. The presence of illiquid assets on a balance sheet should, at the very least, be worth noting. Many suspect that a lot of private equity funds will have trouble "exiting" their investments at anywhere close to the prices they are hoping for.

Nevertheless, the mere presence of an illiquid investment on a fund's books does not imply that it is overvalued. It may also be undervalued. It may take the passage of time to determine which is the case.

David Swensen of the Yale Endowment is known and much-lauded for investing in illiquid assets like timberland. His advantage is that he has only one client, Yale; and that if Yale panics and wants out, there can't be any mis-valuation-related damage caused to co-investors because there are no co-investors.

Venture capital and private equity funds generally invest only in illiquid assets, and typically demand lock-ups of their investors, not allowing any withdrawals for extended periods of time (often up to a decade). When no investor is allowed to depart earlier than any other investor, this avoids conflicts between staying and departing investors.

Warren Buffett's Berkshire Hathaway has lots of illiquid assets; but due to its structure as a publicly-traded corporation, Buffett does not have to liquidate any assets when some of his shareholders want to sell. The departing shareholders merely have to find a willing third party to purchase their shares, which is easy enough on the public markets. Remaining shareholders aren't affected by this.

With mutual funds, there can be a conflict of interest between fundholders who stay and those who depart, so it is important to determine the correct price for every transaction in fund shares so that one group doesn't end up subsidizing the other. With funds investing exclusively in highly liquid stocks, this generally doesn't pose a problem - you just cash out your departing shareholders at day-end market value and cash in any new ones at the same price. Where fund assets are unquoted or highly illiquid, there has to be a way of ascertaining that the remaining shareholders aren't subsidizing the departing ones (and vice versa), and this can require putting a hold on all fund share transactions for a while until a fair price can be determined.

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Re: The collapse of Neil Woodford

Post by AlohaJoe » Tue Jun 11, 2019 11:07 am

matjen wrote:
Tue Jun 11, 2019 11:02 am
However, if one was a superstar and came out with his own fund to have an ER like this seems actually really fair.
There is a wide variety of opinions on what is "fair" for a superstar manager to earn (just witness the billions that hedge fund investors are more than happy to give to hedge fund managers). But Woodford's income from his fund is considered "eye watering" and poor taste in UK investment circles. I don't have any links handy but it is pretty to find articles with tons of quotes from industry insiders talking about the £20 million a year Woodford and his partner have been pulling out from their funds via dividends. There is no doubt a fair amount of schaudenfreude in the UK investment industry from others who wish they could do they same.

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Re: The collapse of Neil Woodford

Post by matjen » Tue Jun 11, 2019 11:16 am

AlohaJoe wrote:
Tue Jun 11, 2019 11:07 am
There is no doubt a fair amount of schaudenfreude in the UK investment industry from others who wish they could do they same.
I bet. Wonder how they felt about Steven Cohen's net worth and the 3% ER and 50% performance fee that he had at SAC Capital? :shock: :shock: :shock:
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Re: The collapse of Neil Woodford

Post by cherijoh » Thu Jun 13, 2019 4:18 am

I heard an interesting story about Woodford on the BBC. They suggested that there were other categories of investments where liquidity currently appeared adequate but which could rapidly dry up in a crisis. The two mentioned were emerging market debt denominated in major currencies (dollars, Euros) and junk bonds. They were particularly leery of ETFs investing in these sectors.

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Re: The collapse of Neil Woodford

Post by nisiprius » Thu Jun 13, 2019 5:19 am

cherijoh wrote:
Thu Jun 13, 2019 4:18 am
I heard an interesting story about Woodford on the BBC. They suggested that there were other categories of investments where liquidity currently appeared adequate but which could rapidly dry up in a crisis. The two mentioned were emerging market debt denominated in major currencies (dollars, Euros) and junk bonds. They were particularly leery of ETFs investing in these sectors.
That seems perfectly reasonable. Both the International Monetary Fund and the Securities & Exchange Commission had had concerns about this for years. Liquidity in corporate bonds had dried up after 2008-2009; the manager of the Vanguard Total Bond Market Index Fund even mentioned that the fund was harder to manage because it was no longer possible to just go out and buy all the issues that were in the index.

The collapse of the Third Avenue Focused Credit Fund in early 2016 showed that these concerns were justified, and in late 2016 it led to the creation of new liquidity rules for US bond funds. I'm not sure how they affect ETFs.

So a relevant question is: how do UK and US mutual fund liquidity rules compare? Is the US more conservative, or could something similar have happened in the US?

A summary of New Liquidity Risk Management Rules mentions:
...all mutual funds, but not money market funds, will be required to have a written liquidity risk management program with several required elements. This program must be run at least on an annual basis and the assessment must use the same factors on a consistent basis. This assessment must show the fund’s strategy and liquidity of portfolio assets in both normal and stressed scenarios, demonstrating that the fund can support a need for mass amounts of liquidity. Funds should also be able to project their cash flows for both the short and the long term, as well as have a defined amount of cash on hand for both scenarios....

...each fund must review its classification of liquidity within its portfolio on at least a monthly basis. There are four categories each investment will fall under – highly liquid, moderately liquid, less liquid and illiquid...

....each fund will determine its own highly liquid investment minimum... A fund may ... breach its own minimum requirement, so long as it reports it to the SEC using the form N-LIQUID...

...the board of directors of the fund are to serve as an oversight committee... the fund must obtain the board’s written approval of its liquidity risk management program before it can be implemented and submitted to the SEC. The fund would also need the board’s approval to make any material changes to the risk management program as well...
So, the question is: is something a lot like this in force in the UK? Was all of it already being done at Woodford's company? Are these just pro forma requirements that are easily "pencil-whipped?"

In short, was this simply a failure by Neil Woodford, or was it also a systemic failure in the UK system for regulating mutual funds?
Annual income twenty pounds, annual expenditure nineteen nineteen and six, result happiness; Annual income twenty pounds, annual expenditure twenty pounds ought and six, result misery.

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