From Boston Review: “…The occasion of my transgression was a
client’s request for an unusual (to my eyes) custom financial structure. “This
trade has been around forever,” the client said about the proposal, a tax
trade. “The government keeps shutting it down and people keep figuring out ways
to make it work again.” And the client thought that it could be made to work
yet again if we—Citigroup—could figure out how to structure the transaction to
fulfill their litany of requirements.
Based on our discussions, I set about working on a
presentation that I christened “Tax Transaction.” This draft was met with
horror by my managing director since, he informed me, “Tax transactions are
illegal.” So the presentation was rechristened “Alternative Financing
Discussion,” the structure was given a purely economic justification, and
taxes, when referenced, were discussed in a deliberately offhand manner
signifying tertiary concern (e.g. “This method of financing is also more tax
efficient than other methods of financing”).
In this alternative financing method, the client would
effectively borrow money at a fixed rate. To justify using a fixed rate we
needed to show it could be cheaper for the client than borrowing at a floating
rate. This justification was part of the economic purpose we had given the
deal. It did not matter that this transaction’s fixed rate was higher than the
fixed rate the company could actually get on the open market (a loss the
company didn’t care about since it would be dwarfed by the expected tax savings
the deal would bring). The only thing that mattered was whether we could
somehow create a scenario where borrowing at floating rates, i.e. rates pegged
to LIBOR that reset every few months, would end up being more expensive than
borrowing at the fixed rate built into our “Alternative Financing Transaction.”
So as I set about figuring out how the bank could structure
the transaction in a way that satisfied both the client’s criteria and our
internal bank policies, I also began making up future LIBORs. I say “making
up,” rather than “forecasting,” because I was not really trying to forecast
anything. Every few days or weeks I’d look at interest rates, figure out what
the fixed rate in the transaction would end up being, and then see if, without
being completely outlandish, I could come up with different combinations of
future LIBORs …..
Wait...wait...there's more at http://www.bostonreview.net/BR37.4/omer_rosen_libor_barclays_citigroup.php
No comments:
Post a Comment