The Institutional Risk Analyst

This week in “The Wrap,” we report in summary fashion about the latest events in Washington and Wall Street this week. The Trump Administration departed from Davos with a variety of “wins,” but there was nothing substantive about housing affordability or really anything else.

And as we predicted several months ago, Fannie Mae and Freddie Mac are at the bottom of the list now instead of the top, reflecting the fact that release from conservatorship has been shelved in favor of the GSEs buying back their own debt. Using the balance sheets of the GSEs to buy MBS basically makes them instruments of public policy, but this does not preclude President Trump from directing an equity offering after the midterm elections.

GS had a remarkable year in 2025, as shown in the table below. It is good to see the firm back on track after the disastrous experiment in retail banking and credit cards.  This is really one of the few pages in the GS public disclosure that has any useful information, which is a major reason that the Fed's Y-9C is must reading for analysts of Goldman Sachs.

President Donald Trump, Bill Pulte and Commerce Secretary Howard Lutnick have apparently met a couple of times in recent weeks to consider policy initiatives for spurring housing. Meanwhile, the GSEs have begun to buy and/or retain mortgage assets in an effort to push down mortgage rates, an effort that is unlikely to have much effect.

But more to the point, the comingled worlds of private equity and credit may be the biggest scandal to hit Wall Street in a century. Most bank loans to PE sponsors "secured" by private company assets are actually non-recourse, so there is no recovery for the bank in the event of default. We think these factors are just some of the reasons that exposures to private equity and credit may be the most risky part of bank loan portfolios.

If SCHW could but find a competent team to manage the bank's assets they could vault to the top of this group in terms of financial and equity market performance. In the meantime, we hope that the folks at the Fed figure out how to publish the Y-9C and related documents for Raymond James.

Only the Fed under Janet Yellen was dumb enough to buy $3 trillion in MBS, costing the taxpayer hundreds of billions in losses without really affecting mortgage rates. A mere $200 billion from Donald Trump is a rounding error, pure populist political pulp -- another progressive political display that will have zero impact on LT interest rates. In fact, the childish suggestions coming from the White House on housing may continue to push LT interest rates up.

LC is clearly succeeding where the larger banks are not in terms of both loan originations and loan sales, which are shown in the chart below. If LC can continue to create assets and also sell loans to investors, that is an indication of a healthy business. But the big question for us is how much of the consumer lending opportunity can LC capture and retain? The table below shows the gross loan yield, net loss rate and net income vs average assets for LC and its bank competi

When the Fed took net loan loss rates for banks down to ~ 50% of par in 2021 vs 95% after 2008, they enabled some very stupid and foolish behavior by investors and lenders. These behaviors are only partly described by the nominal level of interest rates because, of course, we must account for leverage in calculating the full scope of the prospectives losses. Lend More Upon Default (LMUD) has concealed the scope of the disaster and even pushed down reported loan default rates.

Half of COF assets are allocated to consumer loans, with single digits in real estate and C&I exposures. The bank was in the 94th percentile of Peer Group 1 on nonaccrual real estate loans in Q3, the 97th percentile in 90+ day past due C&I loans and the 94th percentile in 90+ day past due for other loans and leases, which includes loans to nonbanks. We expect COF to have high levels of delinquency in its consumer book, but these other credit metrics are a little troubling.

Silver has always been the common man’s metal, but the unique combination of industrial necessity and monetary appeal has helped to resolve its historical "identity crisis," making it both an industrial input and an investment asset. 

Kevin Hassett's comments on Federal Reserve independence may have undercut his chances for the top Fed job. President Donald Trump has observed in recent days that there are “two Kevins,” Hassett and former Fed governor Kevin Warsh, who we personally support.

Of note, JPM's CFO Barnum said in response to a question that “I haven't heard anything to suggest that the private [credit] deals are performing differently from the public deals. It probably is true at the margin that some of the new direct lending initiatives involve underwriting at slightly higher expected losses, and that's significant because, as we've been discussing here, the wholesale charge-off rate has been very, very low for a long time."

“The delinquency rate for commercial mortgages increased in the second quarter of 2025 across most major capital sources,” said Reggie Booker, MBA’s Associate Vice President of Commercial Real Estate Research. “The largest increase was among CMBS loans, driven by rising delinquencies in both multifamily and office properties. Delinquency trends continue to reflect differences in property type, loan structure, geography, and borrower profile.”

The Trump FSOC document reads like a Marvel comic book and is entirely laudatory towards crypto fraud, but uses the same idiotic language as former Treasury Secretary Janet Yellen in describing the grave systemic risks posed by residential mortgage servicers. The report states incredibly: "The continued use of U.S. dollar-denominated stablecoins is expected to support the role of the U.S. dollar in the international financial system..."

The surprise pre-release of Q4 results led to a significant drop in JPMorgan's stock price and took down the entire sector along with it. But is this the only negative surprise likely to come from JPM? We think not. CNBC’s Jim Cramer said on X yesterday that investors should buy JPM on the dip, but we disagree. In fact, the markets seem to know something about JPM. Maybe this explains why Citigroup (C) has outperformed the House of Morgan all year.

PFSI trades on a trailing P/E of 14x vs ~ 8x for RITM. PFSI trades around 1.6x book vs 0.9x for RITM. Case closed? We have long believed that RITM should spin off its manager to create a comp for PFSI and then externally manage the RITM REIT. Like PFSI, in this scenario the new RITM manager would need to retain the Ginnie Mae MSRs.

As we have said consistently, it is better to own the shares of stronger crypto enablers like HOOD and SOFI than the tokens themselves. It is the enablers who profit at the expense of the remaining true greater. We were watching a fascinating conversation with independent technology analyst and advisor Benedict Evans earlier this week and he made the point that serious technologists have largely abandoned crypto as an area of study.

Jim Rickards: False Narratives in Crypto & AI, and the Case for Gold

We have published the latest edition of The IRA Bank Book for Q4 2025. Entitled "Defaults Fall, Market Risk Grows," the report details how indicators of consumer credit risk are falling even as risk to financial markets from institutional and commercial credit, crypto tokens and market exposures grow. Bank income has reached record levels in Q3 2025, but what happens in Q4 2025 and 2026?