Warnings About Financial Institutions and Derivatives

Risks of Financial Institutions
The nature of a financial institution is that there are a lot of ways to go to hell in a bucket. You can push credit too far, do a dumb acquisition, leverage yourself excessively---its not just derivatives [that can bring about your downfall].

Maybe it's unique to us, but we're quite sensitive to financial risks. Financial institutions make us nervous when they're trying to do well.

We're exceptionally goosey of leveraged financial institutions. If they start talking about how good their risk management is, it makes us nervous.

We fret way earlier than other people. We've left a lot of money on the table through early fretting. It's the way we are -- you'll just have to live with it.

Derivatives
The system is almost insanely irresponsible. and what people think are fixes aren't realy fixes. It's so complicated I can't do it justice here - but you can't believe the trillions of dollars involved. You can't believe the complexity. You can't believe how difficult it is to do the accounting. You can't believe how big the incentives are to have wishful thinking about values and wishful thinking about ability to clear.

People don't think about the consequences of the consequences. People start by trying to hedge against interest rate changes, which is very difficult and complicated. Then, the hedges make the [reported profits] lumpy. So they use the new derivatives to smooth this. Well, now you've morphed into lying. This turns into a Mad Hatter's Tea Party. This happens to vast, sophisticated corporations.

Somebody has to step in and say, "We're not going to do it - it's just too hard."

I think a good litmus test of the mental and moral quality at any large institutions [with significant derivative exposure] would be to ask them, "Do you really understand your derivatives book?" Anyone who says yes is either crazy or lying.

It's easy to see [the dangers] when you talk about [what happened with] the energy derivatives - they went kerflooey. When [the companies] reached for the assets that were on their books, the money wasn't there. When it comes to financial assets, we haven't had any such denouement and the accountings hasn't changed so the denouement is ahead of us.

Derivatives are full of clauses that say if one party's credit gets downgraded then it has to put up collateral. It's like margin - you can go broke [just putting up more margin]. In an attempt to protect themselves, they've introduced instability. Nobody seems to recognize what a disaster of a system they've created. It's a demented system. 

In engineering people have a big margin of safety. But in the financial world, people don't give a damn about safety. They let it balloon and balloon and balloon. It's aided by false accounting. I'm more pessimistic about this than Warren is.

Accounting for Derivatives
I hate with a passion GAAP [Generally Accepted Accounting Principles] as applied to derivatives and swaps. JP Morgan sold out to this type of accounting to front-end revenues. I think it's a disgrace.

It's bonkers, and the accountants sold out. Everyone caved, adopted loose [accounting] standards, and created exotic derivatives linked to theoretical models. As a result, all kinds of earnings, blessed by accountants, are not really being earned. When you reach for the money, it melts away. It was never there.

It [accounting for derivatives] is just disgusting. It is a sewer, and if I'm right, there will be hell to pay in due course. All of you will have to prepare to deal with a blowup of derivative books.

Likelihood of a Derivatives Blowup
We tried to sell Gen Re's derivatives operations and couldn't, so we started liquidating it. We had to take big markdowns. I would confidently predict that most of the derivatives books of [this country's] major banks cannot be liquidated for anything like what they're carried on the books at. When the denouement will happen and how severe it will be, I don't know. But I fear the consequences could be fearsome. I think there are major problems, worse than in the energy field, and look at the destruction there.

I'll be amazed if we don't have some kind of significant [derivatives-related] blowup in the next five to ten years.

I think we're he only big corporation in America to be running off its derivative book.

It's a crazy idea for people who are already rich -  like Berkshire - to be in this business. It's a crazy business for big banks to be in.

Yo would be disgusted if you had a fair mind and spent a month really delving into a big derivative operation. You would think it was Lewis Carroll. You would think it was the Mad Hatter's Tea Party. And the false precision of these people is just unbelievable. They make the worst economics professors look like gods. Moreover, there is depravity augmenting the folly. Read the book F.I.A.S.C.O., by law professor and former derivative trader Frank Partnoy, an insider account of the depravity of derivative trading at one of the biggest and best-regarded Wall Street firms. This book will turn your stomach.

Partial Disclosure - The Good

The responsible disclosure process tends to break down in rare occasions where the vendor doesn’t want to fix the issue. When this occurs, the researcher is put into a difficult position whereby full disclosure could put users’ systems at high risk of compromise. The other case where partial disclosure becomes an alternative is when the researcher has discovered a design flaw in a protocol or underlying multiple vendor component. Examples of this case include the DNS flaws published this past summer by Dan Kaminsky and the TCP denial of service condition discovered by Robert E. Lee and Jack Louis that is currently in the disclosure process. When the flaw affects a very large number of vendors and the actual problem is located within the underlying protocols that support the communications of the Internet as a whole, one possible solution is to follow a partial disclosure model where phasing the details to the general public can be used to encourage adoption and creation of patches throughout the enormous target audience.

Partial Disclosure - The Bad

What is driving the fear surrounding partial disclosure is the potential for abuse. When a major flaw is partially disclosed, a number of potential issues may occur. First and foremost, the further along the partial disclosure path we are, the more details will be released to the public, and the higher the probability that someone (either good or bad intentioned) will figure out the exploit and disclose the details. Second, when partially disclosing, the vendor’s hand is being forced into a situation that could speed up fixes, reduce testing, and cause ripple problems elsewhere within the infrastructure. It is difficult enough to dance the fine time line when doing responsible disclosure, but if we are escalated to the point of partial disclosure, additional fuel is added to the fire.

The Ugly

The real ugly part of partial disclosure is when we add to the equation the ability to spread fear, uncertainty, and doubt into the normal user community. It is generally well accepted that FUD can be used to drive additional revenue. If it is possible to increase the perceived magnitude of the “problem” that your product or service solves, it is possible to directly impact the demand for that product or service. That is the major fear imposed by the growing trend of partial disclosure. By releasing just enough information to trigger wide scale speculation into the flaw, it is possible to create buzz and garner media attention resulting in a lot of speculation and very little hard facts around the issue. The potential for abuse by the security industry at large is enormous.

The Fix

Some have suggested a group of security researchers be convened to vet the requirement of partial disclosure and to allow for independent peer review of any security research that requires the partial disclosure process. This suggestion leaves questions regarding who would stand on this group and who would be impartial enough to ensure that the right thing was always done regardless of profit potential. It also leaves open the opportunity for member researchers to utilize the information gathered during the vetting process to position themselves to profit from the data upon release. It might be wiser to rely on a higher level authority or government entity to manage this process and use the services of security researchers as required for subject matter expertise. While a group of this type wouldn’t ensure that all partial disclosure is appropriate, it would hopefully limit the potential for abuse and the ever present chance that people try to profit from the FUD that surrounds the current partial disclosure process.

Sounds like the beginning of a joke, right?  So these two guys walk into a bar…

“The” Bruce Schneier and Marcus Ranum have an article up on TechTarget/Information Security Magazine called, creatively enough, “Bruce Schenier, Marcus Ranum debate risk management“.

Unfortunately, to get to the article, you’ll have to either already be a subscriber to IT Security, a subscriber to TechTarget, or go through the 20 minute process of signing up by giving TechTarget all sorts of “market information” about how you’re really Brandon Walsh, CSO of “The Peach Pit” Industries in Beverly Hills, CA 90210 (phone 714-867-5309).

For those of you who are already a TechTarget person, the link is above.  For those who aren’t, or those who just don’t have the time, I’ll summarize.  The “debate” is kind of awkward because both authors seem come to the same conclusion:

Risk Management, it’s something our profession should do, something humans do naturally, it’s necessary in business, but gosh - we don’t have enough data.

I’m not a cryptographer.  I don’t *nearly* have the insight on privacy and politics that Bruce has.  I’m not deep in IP communications.  I haven’t got a proven track record of innovation in IP Security products like Marcus has.  But here’s the thing, I hope you’ll never hear me pretend that I have the skill set to speak authoritatively on those subjects.  Heck, I wouldn’t claim to be a “risk” expert because I have a some insight into my shortcomings and what is needed to tackle such a complex problem.  But such a tepid article on something that (at least I think) is so important kind of, well, confuses me.

Why is it such a boring article?  I’m not sure.  Maybe because they’re just two guys who would rather debate the merits of specific controls or control activities (after all, their penetration testing debate was a huge success), but there’s no new information in the “debate”.  It’s the same old “insurance companies know risk because they have scads of data and we don’t have that” complaint. You know what?  I’m tired of hearing that line, so let’s talk about it.

HOW DO YOU KNOW WE DON’T HAVE THE AMOUNT OF DATA WE NEED TO DO RISK MANAGEMENT WELL?

Not particularly picking on Marcus, but in the article he uses the common complaint, “We lack the data to do risk management well.”  This mantra is repeated to the point where I’m blase’ about it.  But for some reason, this sentence really jumped out at me this time for two reasons.  It made me ask:

1.)  How do you know we don’t have the proper amount of data?

2.)  Can we even define “well” (i.e. what “good” risk management is) yet?

I really don’t know that the industry, especially concerning IT risk, is mature enough to really conclude that we don’t know (in the case of the former), nor that we can define (latter), conclusively.

PLAYING THE CONTRARIAN

Just because I’m feeling kind of zany this morning, let me suggest something.  Maybe there actually is lots of evidence out there for us to use.  Maybe:

1.)  It’s just that we don’t have particularly good models that provide context.

2.)  When that evidence isn’t an obvious phenomena that lends itself to easy measurement, we throw our hands up in disgust and fall back on “lack of data”, “can’t quantify risk”, “best practices work just fine” or any other number of arguments, no, excuses we use to justify our inability to be precise about the past (more or less the present or future - apologies to Niels Bohr).

IT’S IN THE WAY THAT YOU USE IT

Now I actually am happy to acknowledge that we don’t have enough data to be precise.  You, me, even smart guys like Marcus and Bruce - we’ll never be able to “engineer” risk management.  But you know what?  Neither can Insurance companies.  Sure, there are plenty of places where they have enough data to apply a traditional frequentist approach to risk valuations.   But there are plenty of times Insurers actually insure and they don’t have centuries or decades of data.  There are plenty of times when they rely on the “estimates” of subject matter experts.  There are many times they have enough information to be accurate rather than precise, and that’s good enough for them.

For that matter, it’s worth noting that there are plenty of scientific disciplines that have to deal in imprecise prior information, or evidence that’s fraught with uncertainty (what Ranum calls “squishy”, and what I’ve heard real honest to goodness physicists call “noisy”).  Unfortunately, we’re going to be like them.  Until we can read minds and predict the future, there will always be uncertainty in our measurements and posterior conclusions.  The trick is in how you deal with it and express it.  And while I really don’t know how much time Marcus or Bruce have really spent in the deep end on the subject of risk and its management - I have seen people doing brilliant things around risk (though they just aren’t mainstream).  Whether the tools are Bayesian methods, Monte Carlo engines, reductionist models of complex problems, there are risk analysts trying to deal with the problem.  These analysts are applying scientific method(s) and developing reasonable approaches to a very complex problem.  There are people trying, and our body of knowledge is growing, growing well beyond “gee, I haven’t got an obvious solution so I’ll blame it on lack of data”.  Heck, I’ve seen readers of this blog suggest Douglas Hubbard’s book in other security forums!*

I’VE GOT YOUR DATA RIGHT HERE…

But we don’t have enough data?  I have to ask, how much more do we need?  I mean crikey, JPMC just visited our ISSA chapter claiming, like, a bajillion events an hour.  There’s not one, but several companies out there that will want to tell you about how they have deep “insight” into the attacker community.  The boundaries of IT Risk losses are pretty well established by events that happen to public companies.  We have pretty mature testing/assessment tools and methodologies now that help us test our ability to resist the force an attacker can apply to us.  So what part of the Threat Landscape, Asset (Controls) Landscape, or Loss Magnitude landscape is too incomplete (and what are you doing to find the information you need)?

SO WHY DO WE FAIL?

Which brings me to a final, somewhat depressing conclusion.  Maybe there’s data, and maybe we’re starting to see the means to use it.  But in the end I do have to agree with Marcus that the vast majority of the infosec world *is* doing a really, really bad job with regards to “risk” and “risk management”.  The majority of people I know consider GRC to be a cruel, expensive joke.  Risk Assessment Methodologies tend to be built on the faulty premise that if we create a repeatable process, our measurements and conclusions will magically become accurate and wise.  Risk models tend to be factors loosely measured by ordinal scales and then somehow “multiplied” together to create a relatively meaningless qualitative value.  The State of the Union here is not good.  But after reading such a superficial treatment of an important and complex subject, I am left wondering if Bruce and Marcus were the right people to write about risk management in a mainstream publication.  As Inspector Callahan says, “A man’s got to know his limitations.”

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* Speaking of which, if you want to do one cost effective thing to address your uncertainty - go find Douglas Hubbard’s book. It’s even got a nice recommendation from Peter Tippett.  The book is called “How To Measure Anything” - the title sounds rather hyperbolic, but there are good techniques in it we can use to identify useful information and refine our ability to frame that qualitative information into quantitative values. The key is how Hubbard has you deal with your uncertainty.  For those of you who are more scientific minded and want to dig deep into the subject, I have on good authority that E.T. Jaynes “Probability Theory, The Logic of Science” is a rather under appreciated work.

Around the same time that Professor Luckham and his team was working on CEP applications in network management and security management, I was leading efforts to build network and security management control centers for the United States Air Force.  In the beginning, dating back to 1994, my Internet-related work was for Air Combat Command (ACC), working out of ACC headquarters at Langley Air Force Base.

In 1997, I lead a technical team that developed countermeasures against an actual distributed Internet-based attack on the Langley AFB SMTP email infrastructure.  This attack was documented in a technical paper, E-Mail Bombs and Countermeasures: Cyber Attacks on Availability and Brand Integrity, IEEE Network Magazine, Vol. 12, No. 2, pp. 10-17, March/April 1998.  In addition, this attackand countermeasures I designed was featured in Popular Science Magazine in an 1998 article, War.Com and other news channels.  I also published a number of related papers on this topic.

Our team used a rule-based approach for countermeasures against massive email bombs attacks on the Langley Air Force Base email infrastructure.   We called this rule-based system, BombShelter. and it was written in PERL.  I developed both the original software architecture and the original working prototype for BombShelter (in two days) and then we turned the software over to our team who used the rule-based approach for daily attack countermeasures.

I watched for days, and then weeks, as my team designed rules, and the attackers wrote new attacks that circumvented the rules.  Some folks in the Pentagon used to say that I “lead the effort to fight the first war in cyberspace”.   It might have have been the first cyberwar, I am not sure, but it was certainly the first publicly documented cyberwar.  There is no doubt about this.

Without getting into all the historical footnotes and significance of this cyberwar that was fought with experts and rule-based systems, I would like to jump to an important conclusion.

Rule-based systems are useful, but have limited functionality and scaleability in most complex event processing applications.

Rule-based systems are human resource intensive because rule-based systems cannot learn and adapt on their own, humans learn and then write new rules.  This is how rule-based systems work.

This is the motivation behind why I spend a lot of time to search for new, more efficient and adaptive methods as alternatives to rule-based systems.   After extensive research, I published a series of papers on the future of intrusion detection in the Internet.  Intrusion Detection Systems & Multisensor Data Fusion - Creating Cyberspace Situational Awareness [1], helped lead an evolution in Internet security, particularly in the area of network-based intrusion detection systems (IDS).

In my published research work, motivated by limitations with rule-based approaches, I used the same mature functional model that is used to process missile attacks, control global air traffic, and other complex event processing applications in physical space; but I applied these concepts to cyberspace.

Around the same time, Professor Luckham and others were working on similar problems, all related to real-time detection and response to threats in cyberspace.  They were also funded by the US government.

Sidebar: Stream processing of transaction- based systems (databases), another area of interest, was focused on a totally different problem, which was the low latency processing of straight-thru processing in databased-oriented systems.   These stream processing systems were, and remain however,  rule-based systems.  The problems we were trying to solve in cyberspace, however, cannot be efficiently and pragmatically solved by rule-based systems alone.  Only relatively simple scenarios can be efficiently detected by rule-based stream processing systems.

The vast majority of complex event processing classes of problems require rules plus advanced algorithms that can learn and adapt in real-time.    I know this, not from reading papers or taking university classes on rule-bases systems, but from working on some very challenging operational problems in real-time.    This is why I remain interested in complex event processing and why I continue to elaborate on why rule-based systems have limitations.

“Experienced end users are very intelligent.

These end users know the complex event processing problems they need to solve; and they know the limitations of the current COTS approaches marketed by the CEP community.  Even in Thailand, a country many of you might mistakenly think is not very advanced technologically, there are experts in telecommunications (who run large networks) who are working on very difficult fraud detection applications, and they use neural networks and say the results are very good.   However, there is not one CEP vendor, that I know of, who offers true CEP capability in the form of neural nets.

Almost every major bank, telco, etc. has the same opinion, and the same problem. They need much more capability than streaming joins, selects and rules to solve their complex event processing problems that Dr. Luckham outlined in his book.   The software vendors are attempting to define the CEP market to match their capability; unfortunately, their capabilities do not meet the requirements of the vast majority of end users who have CEP problems to solve.

If the current CEP platforms were truely solving complex event processing problems, annual sales would be orders of magnitudes higher.  Hence, the users have already voted.   The problem is that the CEP community is not listening.”

Not to be overly repetitive,  but the last part of this quote from a year ago is worth highlighting:

“If the current CEP platforms were truely solving complex event processing problems, annual sales would be orders of magnitudes higher.  Hence, the users have already voted.   The problem is that the CEP community is not listening.”

Frankly speaking, nothing in the “CEP world” has changed, technologically speaking, since this September 2007 post was written.  From a sales perspective, we have seen less CEP-related sales in 2008 than in prior years.   If these so called CEP products were actually capability of detecting “real” complex network-centric situations (threats) in real-time, they would be selling faster than a cup of ice water in the blazing hot Sahara desert.

Don’t shoot the messenger.  Build better detection engines!

On the other hand, maybe complex detection is too hard for most of these companies and that is why they focus on routing, mediation and relatively simple rule-based scenarios, versus complex event processing?

Traveling towards VMworld 2008

I, along with thousands of others, wended my way through a vast dimly lit cavern of a place helped along by the strangely surreal sight of ushers in black waving wispy red flags to guide us not to the empty seats in front of us, but to the ones 50 yards on. (Ah Vegas, my feet hurt already.) Perhaps the point was to live in the moment, soak in the pre-rock concert atmosphere complete with a hip and cool soundtrack ripped off from Apple commercials. (Do they all use the same ad firm?) A better way to build the anticipation for, yes, the kickoff keynote session at VMworld 2008. (photo credit: lodev)

To the sounds of Hey Ya (Shake it like a Polaroid picture), we shifted forward in our uncomfortable temporary seating placed, as at all tech conferences, too close for all but the skinny girls. The moment was here – one of those videos started playing on the dozen or so huge monitors floating above the convention crowd. You know this video; you’ve probably seen it before from HP or someone like that. One of those videos with instrumental Coldplay music in the background with time lapse/speeded-up video of people in motion and floating captions dropping into the images that leave you with a slight smile on your face as you “get” the relationship between image and text. (Do they all use the same ad firm?)

And here he is, announced like a Vegas headliner, Paul Maritz, the new CEO of VMware. Hmm. After all that hype, I rather expected someone in a black turtleneck and jeans to come out. Instead here’s this guy with pleat-front pants and an admittedly cool accent (New Zealand?) who looks a little like Al from Home Improvement. Not that there’s anything wrong with that – everyone likes Al.

And then the real fun begins.

• 30 years ago, Paul Maritz started off his business career as a developer
• 10 years ago, VMware was founded by Diane Greene and Mendel Rosenblum (BTW, 10 seconds spent showing a slide with cartoon-ized images of the founders, “thanks for what you did for the company for the past 10 years”. 10 seconds after 10 years…but maybe more would have been hypocritical…)
• a retrospective of centralized vs. decentralized computing initiatives from the 1960’s to today
• of course VMware milestones from 1998 to today
• and then an analyst-ready diagram showing the product roadmap (to be delivered in 2009) with, you guessed it, finally a connection between VMware and cloud computing (remember Maritz’s cloud-computing company was bought by EMC just a couple of years ago and that’s the section he headed up at EMC before being brought into VMware).

Forward Looking

2008 (and probably much of 2009) will be a very busy year for VMware. If you believe the roadmap, VMware seems to be taking on the management of everything – from chargeback and capacity planning to virtual storage and virtual networking (more to come on just what the planned vStorage and vNetwork will deliver) – but all of it VMware-centric. As we said in an earlier post, they’ve moved away from “defending” the hypervisor business proposition to focusing on management services on top of their own hypervisor platform. Revenue pressures must be excruciating – who wants to be a public company these days?

The best part of that new “Virtual Data Center Operating System” diagram/roadmap was the addition (and I mean addition) of something called Cloud vServices. (Did anyone else find it odd that Cloud vServices is kind of on its own in the Infrastructure vServices area? AND, I’ll have to get the other version of the diagram/roadmap I actually saw at the show because that one shows an inexplicable 4^th box in the Application vServices area titled “…”. Really. Maybe to balance out the addition of Cloud vServices?)

What was clear is that the move from VirtualCenter to vCenter –and the new vServices for rolled-up management of virtualization components/capability to span multiple VirtualCenters (or future vCenters) for reporting, monitoring and management at scale – has been in the works for a bit (but in tech time, that could mean 6 months), but the cloud stuff…not so much.

Beyond the very high-level speak appropriate to a keynote (100+ service provider partners for off-premise cloud…suspended VM’s that you don’t have to pay for until you need it), the details are uber-fuzzy. There was a session that Dave went to which was supposed to shed more light, but when questions were asked about how it really works, the answers seemed to be TBD. Does anyone know more? If VMware really has figured out practical cloud computing for enterprises, kudos to them. But I fear they’re like everyone else (except maybe AT&T) and are still working out the details.