When variation margin attacks: Difference between revisions

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Now here is an interesting thing: instead of buying the stocks outright, [[Archegos]] put on its positions using a product called “[[synthetic prime brokerage]]”. Being based on [[Equity derivatives|equity swaps]], [[synthetic prime brokerage]] is caught by [[Regulatory margin|uncleared margin regulations]]. This meant Archegos’ prime brokers were ''obliged'' to pay out realised gains<ref>For [[prime broker]]<nowiki/>s charging “[[dynamic margin]]” this was partly offset by the effect of increased [[initial margin]] required on the inflated value of the position in question; for those charging only a [[static margin]] amount, there was not even that fig-leaf. </ref> or “[[net equity]]” to [[Archegos]], every day, in [[cash]], in the form of “regulatory [[variation margin]]”.  To be sure, prime brokers could impose  thresholds by way of [[initial margin]] — oh, that’s another story altogether — but over those thresholds, variation margin is — at least till the next margin call —the client’s money. It is entitled to withdraw it upon request.  
Now here is an interesting thing: instead of buying the stocks outright, [[Archegos]] put on its positions using a product called “[[synthetic prime brokerage]]”. Being based on [[Equity derivatives|equity swaps]], [[synthetic prime brokerage]] is caught by [[Regulatory margin|uncleared margin regulations]]. This meant Archegos’ prime brokers were ''obliged'' to pay out realised gains<ref>For [[prime broker]]<nowiki/>s charging “[[dynamic margin]]” this was partly offset by the effect of increased [[initial margin]] required on the inflated value of the position in question; for those charging only a [[static margin]] amount, there was not even that fig-leaf. </ref> or “[[net equity]]” to [[Archegos]], every day, in [[cash]], in the form of “regulatory [[variation margin]]”.  To be sure, prime brokers could impose  thresholds by way of [[initial margin]] — oh, that’s another story altogether — but over those thresholds, variation margin is — at least till the next margin call —the client’s money. It is entitled to withdraw it upon request.  


Now this is all completely normal in the world of latter-day [[Derivative|derivatives]]: regulators mandated [[variation margin]] into pretty much every major market on the planet following the [[global financial crisis]] ''in the name of reducing systemic risk'' — but all the same, in the context of [[Archegos]], it made a bad situation worse. It ''forced'' [[swap dealer]]<nowiki/>s to lend to their client against appreciating assets that were increasingly likely to then ''de''preciate again.  
Now this is all completely normal in the world of latter-day [[Derivative|derivatives]]: regulators mandated [[variation margin]] into pretty much every major market on the planet following the [[global financial crisis]] ''in the name of reducing systemic risk'' — but all the same, in the context of [[Archegos]], it made a bad situation worse. It ''forced'' [[swap dealer]]<nowiki/>s to lend to their client against appreciating assets that were increasingly likely to then ''de''preciate again.


Imagine if your bank, by law, had to pay you out the cash value of any increase in your home’s value during the term of your mortgage. Nuts, right?
Imagine if your bank, by law, had to pay you out the cash value of any increase in your home’s value during the term of your mortgage. Nuts, right?
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==== Customers ====
==== Customers ====
Customers, of course, ''do'' have skin in the game: they take all the benefits — less their intermediaries’ fees, commissions and financing costs — and are first<ref>Of course, if the investors should run out of sponges, or their buckets are all full, while there are still some losses left to go round, these get passed to the poor [[Bank|banker]]<nowiki/>s and [[Intermediary|intermediaries]] who may still be owed something. This is why we say investors have a “[[first-loss]]” risk: once they have been wiped from the horizon, any remaining losses go to the investors’ [[Creditor|creditors]], who thus have “[[second-loss]]” risk, whether they like it, or even know it, or not.</ref> to absorb the losses of their investments. They may be [[Professional client|institutional]] ([[pension fund]]<nowiki/>s, [[investment fund]]<nowiki/>s, multinationals) or [[Retail client|retail]] and while the range of investment products they can invest in will depend on their sophistication and financial resources, usually they are not subject to any kind of prudential regulation. Customers can, and do, blow up.  
Customers, of course, ''do'' have skin in the game: they take all the benefits — less their intermediaries’ fees, commissions and financing costs — and are first<ref>Of course, if the investors should run out of sponges, or their buckets are all full, while there are still some losses left to go round, these get passed to the poor [[Bank|banker]]<nowiki/>s and [[Intermediary|intermediaries]] who may still be owed something. This is why we say investors have a “[[first-loss]]” risk: once they have been wiped from the horizon, any remaining losses go to the investors’ [[Creditor|creditors]], who thus have “[[second-loss]]” risk, whether they like it, or even know it, or not.</ref> to absorb the losses of their investments. They may be [[Professional client|institutional]] ([[pension fund]]<nowiki/>s, [[investment fund]]<nowiki/>s, multinationals) or [[Retail client|retail]] and while the range of investment products they can invest in will depend on their sophistication and financial resources, usually they are not subject to any kind of prudential regulation. Customers can, and do, blow up.


Speculative investment vehicles like [[hedge fund]]<nowiki/>s may be highly [[Vega|geared]] and quite ''likely'' to blow up. This is where intermediaries have some [[second-loss]] tail risk: if the customer has blown up, the intermediary loses anything the customer still owes it. Investment funds have ''no'' capital buffer. When they “[[Gap-risk|gap]]” through zero, their counterparties absorb ''all'' remaining market risk, despite wishing to have none of it. [[Broker]]s, banks and and [[dealer]]s ''do'' have a capital buffer, and if their clients’ positions gap through zero, can usually absorb even significant losses.
Speculative investment vehicles like [[hedge fund]]<nowiki/>s may be highly [[Vega|geared]] and quite ''likely'' to blow up. This is where intermediaries have some [[second-loss]] tail risk: if the customer has blown up, the intermediary loses anything the customer still owes it. Investment funds have ''no'' capital buffer. When they “[[Gap-risk|gap]]” through zero, their counterparties absorb ''all'' remaining market risk, despite wishing to have none of it. [[Broker]]s, banks and and [[dealer]]s ''do'' have a capital buffer, and if their clients’ positions gap through zero, can usually absorb even significant losses.
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But the huge preponderance of swap volume is between an [[intermediary]] — a “[[swap dealer]]” — on one side and a [[customer]] — on the other.  
But the huge preponderance of swap volume is between an [[intermediary]] — a “[[swap dealer]]” — on one side and a [[customer]] — on the other.  


So, are [[swap dealer|swap dealers]] “intermediaries” in the traditional sense, having no “skin in the game”? In one sense, no: being a principal to the swap contract, the [[swap dealer|dealer]] takes the other side of the trade to its customer, and is fully exposed to the [[underlier]]’s performance. But in another sense, yes: it ''is'' an intermediary: [[swap dealer]]<nowiki/>s generally [[Delta-hedging|delta-hedge]] their risk. In many cases are prohibited by regulation from taking proprietary positions.<ref>This is the famous “Volcker Rule”.</ref> In the classic case of equity swaps, the dealer executes a physical trade in the cash market, holds or finances that position, and prices its swap at exactly that price. It has no net exposure to the trade at all. Economically, it is no different from a broker lending on margin.
So, are [[swap dealer|swap dealers]] “intermediaries” in the traditional sense, having no “skin in the game”? In one sense, no: being a principal to the swap contract, the [[swap dealer|dealer]] takes the other side of the trade to its customer, and is fully exposed to the [[underlier]]’s performance. But in another sense, yes: it ''is'' an intermediary: [[swap dealer]]<nowiki/>s generally [[Delta-hedging|delta-hedge]] their risk. In many cases are prohibited by regulation from taking proprietary positions.<ref>This is the famous “Volcker Rule”.</ref> In the classic case of [[equity swap]]<nowiki/>s, the [[Swap dealer|dealer]] executes a physical trade in the cash market, holds or finances that position, and prices its swap at exactly that price. It has no net exposure to the trade at all. Economically, it is no different from a broker lending on margin.


==== Deregulation and electronic trading ====
And there’s the thing: if you regard a [[Margin lending|margin loan]] as an intermediary lending a customer a fixed sum to buy an asset, it seems absurd that the banker should in some cases be obliged to pay the borrower more money. It’s like, no, dude, ''you'' borrowed from ''me''. If you want your profit, sell your position, pay me back, and ''then'' you can have your profit. Why should it be different because you traded on a swap?


At about the same time computer-based trading began to revolutionising the financial markets and the madcap spirit of 1980s free-love ''laissez-faire'' delivered their radical deregulation. It is not unreasonable to suppose these conditions contributed to an explosion in the market for OTC swaps during the 1980s.<ref>These three forces combined to create a mammoth. [http://faculty.citadel.edu/silver/IF/MBA_course/Chap9_Swap_Evolution.pdf Citadel] estimates USD interest rate swaps volumes went from from zero in 1981 to over half a billion dollars by 1987. </ref>
The conventional answer is, “because under a [[swap]], I now have [[credit exposure]] to you for that profit and, you know, [[Lehman]].” Yes, it is our old friend the Lehman [[horcrux]]. Let’s come back to that.


== Risk management under the ISDA ==
== Risk management under the ISDA ==
It did not take long for folks to realise that these new [[swap]] things presented a whole new class of risks.<ref name="fwmd"/>


Swaps provide “unfunded” financial exposure to assets: you don’t own the assets, much less pay for them: you don’t have to put any money down up front at all.<ref>Besides any [[initial margin]] your counterparty required: see below.</ref> This is, economically, the same as betting.<ref>It is also the same as buying (or selling) insurance, with one difference: to be insured, you must suffer an insurable loss.</ref> Given the size of individual swap transactions — typically in the millions of dollars — your total notional exposure can quickly blow out of all proportion. The market hit upon two neat tricks to manage these risks: [[netting]] and [[credit support]].
==== Deregulation and electronic trading ====
 
At about the same time computer-based trading was revolutionising the financial markets, the madcap spirit of 1980s free-love ''laissez-faire'' delivered their radical deregulation. It is not unreasonable to suppose these conditions contributed to an explosion in the market for swaps during the 1980s.<ref>These three forces combined to create a mammoth. [http://faculty.citadel.edu/silver/IF/MBA_course/Chap9_Swap_Evolution.pdf Citadel] estimates USD interest rate swaps volumes went from from zero in 1981 to over half a billion dollars by 1987. </ref>


It did not take long for folks to realise that these new [[swap]] things presented a whole new class of risks.<ref name="fwmd"/> Swaps provide “unfunded” financial exposure to assets: you don’t own the assets, much less pay for them: the idea of exchanging notional amounts fell away and, besides initial margin, you didn’t have to put any money down at all. Given the size of individual swap transactions — typically in the millions of dollars — it didn’t take many transactions before total notional exposures were collossal. Practitioners in the market hit upon two neat tricks to manage these risks: [[netting]] and [[credit support]].
==== Netting ====
==== Netting ====
We are not really concerned with netting here — the [[JC]] has plenty to say on that topic [[Close-out netting|elsewhere]] — so let’s quickly deal with it: just as you could offset the [[present value]] of the opposing ''legs'' of each transaction to calculate a positive or negative [[mark-to-market]] value for that swap, so too could you offset positive and negative [[mark-to-market]] values for different swap transactions to arrive at a single net exposure for your whole {{isdama}}. This idea — [[close-out netting]] — was a stroke of genius, and the brave commandos of {{icds}} encoded this “[[single agreement]]” concept into the {{1987ma}} and its successors. Giving effect to netting contracts, and attaining the capital relief they promise is now a multi-million-dollar industry.  
We are not really concerned with netting here — the [[JC]] has plenty to say on that topic [[Close-out netting|elsewhere]] — so let’s quickly deal with it: just as you could offset the [[present value]] of the opposing ''legs'' of each transaction to calculate a positive or negative [[mark-to-market]] value for that swap, so too could you offset positive and negative [[mark-to-market]] values for different swap transactions with the same customer to arrive at a single net exposure for your whole {{isdama}}. This idea — [[close-out netting]] — was a stroke of genius, and the brave commandos of {{icds}} encoded this “[[single agreement]]” concept into the {{1987ma}} and its successors. Giving effect to netting contracts, and attaining the capital relief they promise is now a multi-million-dollar industry of weaponised [[tedium]].  


==== Credit support ====
==== Credit support ====
But even with netting, the [[Leverage|levered]] nature of swap transactions means that your overall net exposure can still swing around wildly.
But even with netting, the [[Leverage|levered]] nature of swap transactions means that overall net exposures can still swing around wildly.


In 1994 ISDA released a “[[credit support annex]]” to the {{isdama}} under which the parties could exchange “credit support” to offset their respective net exposures. This is all rather complicated and fiddly<ref>See our [[CSA Anatomy]], for as much detail as any one person could want.</ref> but the gist of it is that you calculate your net [[exposure]] under an {{Isdama}} on any day and, if it is over an agreed threshold, you can require your counterparty “post” you cash or securities as collateral for that exposure. If the exposure then swings back towards your counterparty tomorrow, it can require you to return equivalent assets . Rinse and repeat.
In 1994 ISDA released a “[[credit support annex]]” to the {{isdama}} under which the parties could exchange “[[credit support]]” to offset their respective net exposures. This is all rather complicated and fiddly<ref>See our [[CSA Anatomy]], for as much detail as any one person could want.</ref> but the gist of it is that you calculate your net [[exposure]] under an {{Isdama}} on any day and, if it is over an agreed [[Threshold - VM CSA Provision|threshold]], you can require your counterparty to “post” you collateral for that exposure. If the exposure then swings back towards your counterparty tomorrow, it can require you to return equivalent assets. Rinse and repeat.


This is rather neat, because it “zeroes out” each party’s [[credit exposure]] to the other each day.
This is rather neat, because it “zeroes out” each party’s [[credit exposure]] to the other each day.


Like the {{Isdama}}, the [[CSA]] is a bilateral document: it assumes the parties are equal, arm’s-length counterparties and that each can post to the other. In the early days, [[Swap dealer|swap dealers]] often adjusted their CSAs so that only the customer posted credit support. This made sense, since end-users of swaps tend not to be prudentially regulated and therefore are not heavily capitalised, whereas intermediaries and swap dealers usually are. What is more, over this period, the [[Basel Accords]] published increasingly stringent and detailed rules<ref>Basel I was 30 pages. Basel II, published June 2006 (whoops!) was 347 pages. Basel III, as of September 2021, is 1626 pages.</ref> about how much capital banks should hold against their trading exposures to their customers.  
Like the {{Isdama}}, the [[CSA]] is a bilateral document: it assumes the parties are equal, arm’s-length counterparties and that each can post to the other. In the early days, [[Swap dealer|swap dealers]] often adjusted their CSAs so that only the customer posted credit support. This made sense, since swap customers tend not to be prudentially regulated or heavily capitalised, whereas intermediaries and swap dealers usually are.
 
The solvency risk of banks and intermediaries was managed by prudential regulation, risk weighting and capital ratios. Over this period, the [[Basel Accords|Basel Committee]] published increasingly stringent and detailed rules<ref>Basel I was 30 pages. Basel II, published June 2006 (whoops!) was 347 pages. Basel III, as of September 2021, is 1626 pages.</ref> about how much capital banks should hold against their trading exposures to their customers.  


If at first customers were less bothered about the creditworthiness of their swap dealers,<ref>To be sure, sophisticated investment managers were already requiring their dealers post [[variation margin]] by the the start of the new millennium.</ref> this all changed, fast, during the 2008 financial crisis in which every major dealer had at least a near-death experience, and a number — [[Lehman]], Merrill Lynch, Bear Stearns, and literally dozens of others<ref>This is a [https://en.wikipedia.org/wiki/List_of_banks_acquired_or_bankrupted_during_the_Great_Recession fun list].</ref> had actual ones.
If at first customers were less bothered about the creditworthiness of their swap dealers,<ref>To be sure, sophisticated investment managers were already requiring their dealers post [[variation margin]] by the the start of the new millennium.</ref> this all changed, fast, during the 2008 financial crisis in which every major dealer had at least a near-death experience, and a number — [[Lehman]], Merrill Lynch, Bear Stearns, and literally dozens of others<ref>This is a [https://en.wikipedia.org/wiki/List_of_banks_acquired_or_bankrupted_during_the_Great_Recession fun list].</ref> had actual ones.
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===== Remember the good old days =====
===== Remember the good old days =====
Now remember that old distinction between “intermediary” and “customer”. Intermediaries are meant to be well-capitalised; they don’t have a dog in the fight: their interest is just in collecting their commission. Their customers take the market risks.
Now remember that old distinction between “intermediary” and “customer”. Intermediaries are meant to be well-capitalised; they don’t have a dog in the fight: their interest is just in collecting [[commission]]. Their customers take the market risks.


Swap dealers ''look'' like they are taking market risks, but they are not. Post Volcker, they are not ''allowed'' to. Swap dealers are passing on the return of their hedging activity to their customers, and collecting commissions and interest on financing.<ref>We have in mind [[Synthetic equity swap|synthetic equity derivatives]] here. This may be less clearly the case in other asset classes, but it is still (post Volcker) broadly true for all of them.</ref> They are somewhat at the mercy of their customers: having put positions on, their legal rights to terminate them again tend to be legally and [[Commercial imperative|commercially]] circumscribed. Customers can terminate at any time — it’s their investment — and for any reason, including vague nervousness about the solvency of their dealer.
Swap dealers ''look'' like they are taking market risks, but generally they are not. Post Volcker, in most cases they are not ''allowed'' to. [[Swap dealer]]<nowiki/>s pass on their returns of their trading activity to their customers, in return for [[Commission|commissions]] and [[interest]] on financing.<ref>We have in mind [[Synthetic equity swap|synthetic equity derivatives]] here. This may be less clearly the case in other asset classes, but it is still (post Volcker) broadly true for all of them.</ref> Furthermore, [[dealer]]<nowiki/>s are somewhat at the mercy of their customers: having put positions on, their rights to terminate are legally and [[Commercial imperative|commercially]] circumscribed. By contrast, customers can terminate at any time — it’s their investment — and for any reason, including vague nervousness about their dealer’s solvency.


===== Physical prime brokerage =====
===== Physical prime brokerage =====
You can, and physical [[prime brokerage]] customers do, achieve exactly the same effect with a [[Margin lending|margin loan]]: the customer buys shares on margin; the [[prime broker]] holds the shares as collateral for the loan. If the shares decline in value, the broker may call for more margin. If the shares rise in value, the customer generates increased equity with the broker, but is not automatically entitled to the cash value of that equity. There is no variation margin, as such.
You can, and physical [[prime brokerage]] customers do, achieve exactly the same effect with a [[Margin lending|margin loan]]: the customer buys shares on margin; the [[prime broker]] holds the shares as collateral for the loan. If the shares decline in value, the broker may call for more margin. If the shares rise in value, the customer generates increased equity with the broker, but is not automatically entitled to the cash value of that equity. There is no [[variation margin]], as such.


But here is the difference: the [[prime broker]] may ''agree'' to lend more against that equity — that is the business it is in, after all — but it is not ''obliged'' to.  The customer cannot force the broker to lend against the equity. As long as it leaves enough equity in the account the customer may withdraw excess equity, but only by taking the shares it owns. Withdrawing ''shares'' from a prime brokerage account doesn’t fundamentally change ones debtor/creditor relationship. Withdrawing cash ''against'' shares assuredly does.
But here is the difference: the [[prime broker]] may ''agree'' to lend more against that equity — that is the business it is in, after all — but it is not ''obliged'' to.  The customer cannot force the broker to lend against the equity. As long as it leaves enough equity in the account the customer may withdraw excess equity, but only by taking the shares it owns. Withdrawing ''shares'' from a prime brokerage account doesn’t fundamentally change ones debtor/creditor relationship. Withdrawing cash ''against'' shares assuredly does.
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Swap trading involves [[market risk]] and [[credit risk]].  
Swap trading involves [[market risk]] and [[credit risk]].  


[[Market risk|''Market'' risk]] is the risk that an asset goes ''up'' when you want it to go ''down'', or ''down'' when you want it to go ''up''. [[Credit risk|''Credit'' risk]] is the risk that the person whom you want to pay you that return cannot, because that she is ''broke''.
[[Market risk|''Market'' risk]] is the risk that an asset goes ''up'' when you want it to go ''down'', or ''down'' when you want it to go ''up''.


[[Variation margin]] is meant to neutralise both: if the day’s loser squares up the value of her loss each day in collateral to the winner, the parties reduce their respective credit exposure to nil: if neither party owes anything on the trade, there is no credit risk.
[[Credit risk|''Credit'' risk]] is the risk that the person whom you want to pay you that return cannot, because that she is ''broke''.
 
[[Variation margin]] is meant to neutralise both: if the day’s loser squares up her loss each day and posts it as collateral to the winner, the parties reduce their respective credit exposure to nil: if neither party owes anything on the trade, there is no credit risk.


[[File:Archegos Positions.png|thumb|The purple, blue, light blue and red lines are the key parts of Archegos’ portfolio between March 2020 and August 2021. The big drop is 21 March 2021.]]
[[File:Archegos Positions.png|thumb|The purple, blue, light blue and red lines are the key parts of Archegos’ portfolio between March 2020 and August 2021. The big drop is 21 March 2021.]]
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Let’s have another look at that lovely [[Archegos]] chart: over 6 months from September these stocks rallied on average 54%. Then, in just four days, these stocks fell fully half that value.
Let’s have another look at that lovely [[Archegos]] chart: over 6 months from September these stocks rallied on average 54%. Then, in just four days, these stocks fell fully half that value.


And here we see the buried credit risk of variation margin. As those positions appreciated, the brokers were obliged to pay their cash value, in VM, to Archegos. Archegos used some of this rising equity to buy more shares in the same stocks, further pushing up their price, obliging the brokers to pay more VM.  
And here we see the buried credit risk of [[variation margin]]. As its swap positions appreciated, the brokers were obliged to pay their cash value to Archegos. Archegos used some of this cash to buy ''further'' positions in the same stocks, further pushing up their price, obliging the brokers to pay it even more variation margin. And the higher the stocks went, the thinner their liquidity, the greater their implied volatility, and the more certain that when they did come down, they were going to come down ''fast''.  


Archegos put ''all'' its cash into more positions. As the stock rose, its absolute position in the shares grew too.  
Archegos put ''all'' its cash into more positions. As the stock rose, its absolute position in the shares grew too.  


Say it held 100 shares at 40, fully margined. Should they appreciate to 60, it's net equity increases 2,000. Broker credits it with the cash and it buys a further 25 shares at 60, pushing the price to 80. This results in a net equity increase of 4000, to 10000, so the broker pays out 4000 more, Which it used to buy a further 40 shares. Note it's holding is 165 shares and the price surges to 100. Broker dutifully credits a further 6500 in VM, which the customer withdraws and uses to buy another 55 shares, taking is total holding to 220.
Say it held 100 shares at $40, fully margined at 25%: a total value of $4,000 of which the dealer has lent $3,000. Should the shares appreciate to $60, its net equity increases by $2,000. The Swap dealer credits it with the cash and it buys (on margin) a further 25 shares at $60, pushing the price to $80. This results in a net equity increase of $4,000, to $10,000, so the broker pays out $4,000 more in variation margin, which the client uses to buy a further 40 shares. Now its holding is 165 shares and the price surges to $100. Broker dutifully credits a further $6,500 variation margin, which the customer uses to buy another 55 shares, taking is total notional exposure to 220 shares.
 
Take (er) stock: the stock has rallied 120%. The broker has paid out 12500 is variation margin, to well over 300% of the original investment value. The customer has no cash.
 
Now the stock retreats to 80. The broker calls for margin, but the customer has no cash. Three customer tries to sell positions but suddenly the ask 50. Even if the customer sold its whole holding at this price — fat chance in a thin falling market, the broker would lose 1500 of its cash.  


So, to take (er) stock: the positions have rallied 120%. The dealer has paid out $12,500 in variation margin, to well over 300% of the original investment value. The customer has no cash left should the shares fall in value.


Once those
Now they do just that: the stock retreats to $80. The swap dealer calls for $4,400 in variation margin, but the customer has no cash. The customer tries to sell its positions but no-one is buying, and the arrival of a large portion of shares sends the bid lower. Suddenly the bid for these shares is back where they started, at $40. Even if the customer sold its whole holding at this price — fat chance in a thin falling market, it would yield only $8,800 and the broker would lose $3,700 — 23% more  than its original loan. 


You generally have one risk or the other at any time: it is not much good having made a killing on the roulette table if the casino is bankrupt, because it cannot give you any money for your chips. If, on the other hand, you have already lost everything at the card table, it does not matter much if the casino is broke, because it didn’t owe you anything anyway.
You generally have one risk or the other at any time: it is not much good having made a killing on the roulette table if the casino is bankrupt, because it cannot give you any money for your chips. If, on the other hand, you have already lost everything at the card table, it does not matter much if the casino is broke, because it didn’t owe you anything anyway.