Goldman Sachs’ Lloyd Blankfein has also a big question to answer us Venezuelans.

Sir, Brooke Masters writes that when “Sued by the US Securities and Exchange Commission over allegations it had misled clients about mortgage-backed securities… Lloyd Blankfein… launched a top-to-bottom cultural review and spent 18 months visiting clients to reassure them that Goldman had got the message on ethics.” “Goldman Sachs has big questions to answer” November 7.

So Masters rightly asks so what happened as “Last week, the US Department of Justice revealed that two former senior Goldman bankers had been criminally charged with helping to loot 1MDB, a Malaysian state investment fund that authorities allege was victim of one of the biggest frauds of all time.”

Sir, I have my own question. After Mr Blankfein’s much-touted ethics revamp in 2011, what on earth was he doing lending, in May 2017, to a notoriously human rights violating odious regime, namely Venezuela’s Maduro’s?

In fact, as I see it, corrupting not some government official but the regime itself, by offering fresh money in return for the possibility of huge returns, sounds to me as something quite punishable by US’s Foreign Corrupt Practices Act (FCPA).

We are now in November 2018, and Mr Blankfein has not found it within himself to yet utter the smallest “Venezuelans, I am so sorry”

Sir, what kind of elite do we have when a Lloyd Blankfein still gets invited to all kind of academic and social engagements?

@PerKurowski

Bank systems’ “Fifth Risk”: When shit really hits the fan, banks will be holding especially little capital.

Sir, Brooke Masters reviews Michael Lewis’ “The Fifth Risk”, a book that got its titled when John MacWilliams, a former Goldman Sachs investment banker told the author about the “fifth risk”, referring to ‘project management’, the risk society runs when it falls into the habit of responding to long-term risks with short-term solutions.” “Why boring government matters”, November 3.

Well-intentioned bank regulators, wanting to make our bank system safer, and came up with risk weighted capital requirements based on the perceived credit risks. If the perceived credit risks (those that bankers saw and used to adjust to with size of exposure and risk premiums) do not represent the most immediate short-term outlook on risk for banks what does? 

The real long-term risk is obviously that something that was ex ante perceived as safe, and with which banks could therefore build up large exposures, suddenly, ex post turned out very risky. The regulators with their short-term solutions only guaranteed that when shit really hit the fan, banks would stand naked with especially little capital.

Brooke Masters quotes Ronald Reagan with “the nine most terrifying words in the English language are ‘I’m from the government, and I’m here to help’ ”.

Indeed! Just like when regulators told us “we credit rating agencies know all about risks so, with our regulations, we will make your bank systems safer”. As a result they gave us the 2008 crisis, way too much credit for house purchases, and mountains of 0% risk weighted sovereign debt around the world. If only they had stayed home.

Sir, “good boring government” is indeed needed, but beware, few things as dangerous as bored bureaucrats… they’re truly frightening.

@PerKurowski

Do we not need a Martin Act to crack down on regulators who dare regulate banks without having a clear idea about what they are doing?

Sir, Brooke Masters writes “global banks and other big financial services groups have lived in fear of an old New York state anti-fraud law. The Martin Act has been used to crack down on biased Wall Street research, insurance bid-rigging and “dark pools” said to mislead traders, among many things” “Loosening the law that haunts bankers puts us at risk” June 20.

Great! But why is there not anything similar when for instance European regulators and central bankers assign a 0% risk weight to Greece. Of course they must have known Greece was not worth it, no sovereign is, and yet they went ahead. And the final consequence of that have been horrible sufferings resulting from excessive public debt, but without the slightest indication of holding those responsible for it accountable.

Yes “The US system relies on fears of prosecution and giant fines to help keep banks and insurers honest”, but what do we have to keep technocrats from regulating when they obviously have no idea about what they are doing… like for instance when they think that what is ex ante perceived as risky poses ex post more dangers to our bank system than what is ex ante perceived as risky.

@PerKurowski

What if we in writing had to authorize phone companies to listen to our calls, in order to have access to phones?

Brooke Masters writes: “when I link our Amazon Echo speaker to my son’s Spotify account, I have no idea whether I am violating one of the thousands of terms and conditions he agreed to with his account. Furthermore, does that act give Amazon the right to send him advertisements based on the songs we play?” “Take ownership of the sharing economy” December 29.

She is absolutely right. The rights we seem to have to give up in order to gain access to social media and alike, though defined in small letters in thousands of unreadable pages, is one of the most undefined issues of our time.

Some questions:

Should the marginal cost for social media owners to access, and waste, so much of our limited attention span, be zero?

Should we be able to copyright our own preferences so that we at least can have something to negotiate with?

How much can we allow being distracted during working hours before our employer has the right to deduct our salaries paid?

How will such working hours distractions be accounted for in employment statistics?

How is all this free or very cheap consumption paid by used attention spans be accounted for, for instance in GNP figures?

Should social media owners be allowed to impose their own rules or should that not be subject to some kind of a special arbitration panel?

How our global differences be managed? Does a government that interferes with its citizens’ rights of access to social media have access to other web sites of other nations?

@PerKurowski

How long will regulators believe that unrated entrepreneurs pose more danger to banks than investment graded companies?

Sir, Brooke Masters writes that “a group of banks collectively lent €1.6bn to a South African billionaire. At the time, these “margin loans” looked like really safe bets because the lending was secured by 628m Steinhoff shares worth €3.2bn and the company had an investment-grade rating” and now they “were sitting on paper losses of €1.2bn” “Beware of top execs who depend on share-backed loans”, December 16.

Sir, this just another evidence of that what is really dangerous for banks is not what is perceived risky but what could erroneously be perceived as safe. And therefore that the current risk weighted capital requirements for banks makes absolutely no sense?

Sir, why is it so hard for you to ask regulators: “Is it not when banks perceive something as safe that we would like for these to hold the most capital?”

Are you afraid they will give you a convincing answer and leave you standing there as a fool? Don’t you think that if they had had an answer they would have shut me up decades ago?

Simon Kuper in today’s FT writes about how America an Britain have fallen into the hands of incompetent amateurish well-off baby boomer politicians, born between 1946 and 1964, “Brexit, Trump and a generation of incompetents”.

Sir why could that not also be applicable to baby boomer regulators, like for instance Mario Draghi, Stefan Ingves or Mark Carney?

PS. We should note though that it was a pre-baby-boomer generation’s Paul Volcker and Robin Leigh-Pemberton who were responsible for the origins of this monumental regulatory faux pas.

@PerKurowski

Are those who impose regulations that create generous incentives for these to be gamed entirely without blame?

Sir, Brooke Master while discussing regulations for carmakers and banks refers to “mis-sold mortgage-backed securities and payment protection insurance” “The diesel scandal echoes bankers’ woes” July 27.

The regulators, with Basel II of 2004, allowed banks to leverage 62.5 times if a AAA to AA rating was present… while for instance only 12.5 times if there was no credit rating. That temptation set up the banks to, sooner or later fall into a trap. Are these regulators innocent?

In the same vein carbon emission controllers set up procedures that evidently could easily be cheated on. Are these controllers also entirely innocent?

I ask these questions because from what we have seen neither regulators nor controllers have been demoted, on the contrary, at least with respect to banks many, like Mario Draghi and Stefan Ingves, have been promoted.

Had the credit-rated-risk-weighted capital requirements for banks that distort the allocation of credit to the real economy not been introduced, the 2007/08 crisis and the ensuing slow growth would not have happened.

If a country decides to impose a 1.000% tax on liquor, does it not have any responsibility in that its citizens (including its legislators and tax collectors) start smuggling liquor?

@PerKurowski

Risk weights of 20% for AAA rated and 150% for the below BB-, evidences the Basel Committee’s intellectual failure

Sir, Brooke Masters makes a lot of good points in her “Loss of a safety-first regulatory regime is no reason to party” February 4. Unfortunately, again, as is usual for almost all commenting on bank regulations, these are solely from the perspective of the safety of banks; so rarely from the perspective of the borrowers, most specially the “risky” borrowers, like the SMEs and entrepreneurs, and whose borrowings are taxed with the highest capital requirements for the banks.

When Masters’ writes that relative to some large institutions “Some smaller banks are struggling with high compliance requirements”, it is so in much because the natural borrowing clientele of smaller local banks belong to the “risky” group.

Masters ends by recommending: “just trim back the Dodd-Frank rules and stay in the Basel process but temper its safety drive… even try leaving the fiduciary rule in place”

I do not agree. The Basel Committee has produced regulations that make no sense to the real economy and, if you really want banks to have a chance to be sustainably safe, you must make sure the allocation of credit to the real economy is efficient and adequate. The Basel Committee with its risk weighted capital requirements dangerously distorts that allocation. And all based on the completely erroneous theory that what is ex ante perceived as risky is riskier ex post to the banks than what is perceived as safe.

That the AAA rated, so dangerous in that a perceived safety can easily cause very high exposures, have a risk weight of 20%, while the really so innocuous below BB-rated are assigned a risk weight of 150%, is about the best example of how confused current bank regulators are. To rebuild those regulations using the same builders and who are not even recognizing the mistakes cannot lead to anything good. Face it, banking after around 600 years of functioning, was in 1988, with Basel I, dramatically changed for the worse. 

The Dodd-Frank Act? What can I say: to me it is a monument to legislative surrealism. For instance in its 848 pages it does not even mention the Basel Committee for Banking Supervision.

Fiduciary role? Since no one can really guarantee that any fiduciary responsibility is complied with, it is better not to imply such thing with regulations. The best approach is just explaining to investors what its acceptance or not by the advisors, is “supposed” to mean. 

PS. It would be great if Brooke Masters used her influence to get some answers from any bank regulators to these questions.

PS. The sad truth is that our banks are in the hands of Chauncey Gardiner type regulators.

@PerKurowski

That banks have strengthened is pure wishful thinking, as most of it is the result of weakening the real economy.

Sir, Brooke Masters’ writes: “Eight years after the financial crisis, we were all getting bored with bank stress tests. Most of the institutions are so much stronger and better capitalised than they were” “UK’s tough stance on banks contrasts with global mood” December 3

That’s not really so. Most of the strengthening is the result of banks shedding “risky” assets in favor of safe, so the other side to that coins is having in the medium and long term run made the real economy weaker.

As I have complained about for years, current stress tests only look at what is on the balance sheets of banks, ignoring completely the aspect of what should have been there.

With respect to “imposing “output floors” on the models. These would effectively raise capital requirements for some banks by pushing up the value of their risk-weighted assets”, the real question is, how could regulators be so naïve so as to think those risk models were not going to be tweaked? Lower risk determination, means lower capital requirements, means higher leverages, means higher expected risk adjusted returns on equity.

With respect to “floors unfairly penalise banks with unusually safe assets, such as those who keep a lot of low-risk mortgages on their books”, the question is when will banks keep on favoring the “safer” construction of basements were the jobless young can live with their parents over the “riskier” lending that could allow the young to find the jobs they need in order to become responsible parents too?

Sir, you want strong banks? Keep them on a tight capital leash without distorting what they do? You want weak banks? Make them operate only in what is safe and help them with their returns on equity by being very accommodative allowing high leverages.

@PerKurowski

With respect to the Big Four, it is all déjà vu

Sir, I refer to Brooke Master’s “A clubby oligopoly that is overdue for reform” of August 20 and to your editorial “Accountancy’s Big Four need more competition” August 25.

“The Big Four accounting firms became big by marketing the value of their size. Now they want to have their cake and eat it too, asking to be sheltered from ruinous lawsuits. If accountability is to mean anything in accounting, we cannot afford to turn the concept of professional responsibility into a risk model of affordability.

Individual professionals and small firms lay their names on the line, day after day. If the Big Four cannot handle it, they had better let go. Then we might all be better off. At least the systemic risks will be smaller.”

Sir and that is a letter I wrote and that you published in May 2004, 12 years ago, before I became a pariah to FT.

And years earlier, in 1997, in an Op-Ed in Venezuela I had analyzed much of that issue though from a slightly more local angle. It is amazing to see how serious problems are identified, and then nothing is done to solve these, and they come back to haunt us over and over again.

PS. Brooke Master writes in her piece that a disgruntled PwC trainee described PwC as a “meat grinder” and moaned about how boring the job” Does that not sound like accounting could become ready for the use of robots?

@PerKurowski ©

Regulators tell banks “Occupy what’s safe”; and so expel widows, orphans and pension funds, to handle what’s risky

Sir, Brooke Masters reports on how the Security Exchange Commission is making sure that private equity industry duly manages conflicts of interest and treats its clients fairly. “SEC enforcers must keep bearing down on private equity” August 27.

But Masters also writes: “Historically, PE clients have been highly sophisticated. So they are either well placed to decipher complex investment contracts or rich enough not to quibble about extra fees. But that is changing. Public pension funds are shifting more and more of their money into private equity as they chase higher yields. Pension fund managers are far less experienced with the sector.”

Why did this happen? When regulators, with their risk weighted capital requirements told banks they could leverage more, and therefore obtain higher risk-adjusted returns on equity with assets perceived as safe than with assets perceived as risky, they made banks occupy that area in which, without leverage, widows, orphans and pension funds used to dwell.

So see what they done. By trying to make banks safer they clearly made life for widows, orphans and pension funds much riskier. That is what happens when regulators regulate with no concern about the impact their regulations will have.

And the saddest part of it all is that it is all for nothing. Major bank crisis are never the result of excessive exposures to what is perceived as risky, but always the result of unexpected events or excessive leveraged exposures to what was ex ante perceived as safe, but that ex post turned out not to be.

PS. For the sake of our children and future pensioners, I pray we can reverse this, and that there are still some bankers out there who know how to be bankers, and not only how to be equity minimizers. 

@PerKurowski ©

Are the systemic risks, derived from many or all cars being on autopilot, ignored by regulators? Like in banking?

Sir, Brooke Masters, with respect to the recent Tesla accident that caused a death, writes: “the more a car’s autopilot does, the less experience drivers will have — and the less watchful they will become. It is madness to expect them to seize the wheel and work a miracle in a moment of crisis” “Tesla tragedy raises safety issues that can’t be ignored”, July 2.

That sounds a lot like banking now becoming more and more automatically responsive to regulations, which could be faulty, and less and less reponsive to bankers’ diverse senses.

And Masters holds that “US regulators, who are in the midst of writing new guidelines for autonomous vehicles, need to take this into account before they give blanket approval to partially self-driving cars”. 

That sounds a lot like when our bank regulators are concerned with the risk of individual bank and not with the risks for the whole banking system. If those regulators are just evaluating how autonomous vehicles respond to traffic where humans drive all other vehicles, they will not cover the real systemic dangers. 

Masters informs: “Tesla noted that this was the first death to occur in 130m miles of driving on its autopilot system, versus an average of one death per 60m miles of ordinary driving.”

And to me that is a quite useless and dangerous information considering the possibilities of the mega chain reaction pile up car crash that could result when all or most cars are on autopilot, responding or trusting in similar ways… like when the very small capital requirement against what was AAA rated caused the mega bank crisis.

I can hear many arguing that if all cars are controlled then no accidents could occur. Yes that might be so but for it to occur, as a minimum minimorum, we would need to control all hackers to absolute perfection.

The real beasts in banking are the regulators who believe they can manage bank risks from their desks in Basel

Sir, Brooke Masters reviews Tony Norfield’s “The City: London and Global Power of Finance” “Banking as seen from the belly of the beast”.

Masters writes that Norfield “seeks to document just how the UK and the US extract their pound of flesh from the rest of the world by dominating the financial flows that make international trade possible”.

And again I must ask: Who dominates more the financial flows in the world, the banks or those regulators who tell banks to lend to the infallible sovereign, the AAArisktocracy and housing but not to the risky SMEs and entrepreneurs. Because that is what bank regulators do with their credit-risk-weighted-portfolio-invariant capital requirements for banks.

Masters writes that Norfield “Mostly reserves his scorn for politicians who seek to distinguish between worthy industrial capitalists and bad bankers.”

I have not read the book yet, so I am not absolutely sure of its meaning, but one thing I am sure off: I reserve my deepest scorn to those regulators who, with such hubris, feel themselves capable of discerning and managing the bank credit risks for the world.

They are so incredibly dumb. Imagine, in order to make the banking system safer, with Basel II they placed a risk weight of only 20% on AAA rated assets and one of 150% for below BB- rated assets. As if below BB- rated assets could generate such excessive exposures so as to be a threat to any banking system.

They are so incredibly dumb they do not even define the purpose of the banks before regulating these.

And the incredibly dumb list goes on and on and on

PS. I once heard a very important regulator, with respect to some bankers objecting part of the regulations with scorn express: “If they do not want to be bankers, let them be shoe shiners instead”

@PerKurowski ©

Rules that make all banks behave the same can pose greater systemic risks than all SIFIs put together.

Sir, I refer to Brooke Masters article on “systemically important financial institution whose failure could destabilise the economy” “MetLife’s court win means US regulators should redraft rules” Saturday 2.

Before regulating or redrafting anything, regulators should at least come to understand that their own rules might be the source of the most dangerous systemic risks.

In 2001, in an OpEd I wrote the following onbank regulations:

“The regulatory risk: Before there were many countries and many ways of how to regulate banks. Today, with Basel proudly issuing rules that should apply worldwide, the effects of any mistake could be truly explosive. 

Excessive similarity: Encouraging banks to adopt common rules and standards, is to ignore the differences between economies, so some countries end up with inadequate banking systems not tailored to their needs. Certainly, regulations whose main objective appears to be only to preserve bank capital, conflict directly with other banking functions, such as promoting economic growth, and democratize access to capital. 

Low diversity of criteria: A smaller number of participants, less diversity of opinion and, with it, increased risk of misconceptions prevailing. Whoever doubts that, should read the dimensional analysis that ratings agencies publish. 

Backlash: The development of decision-making processes has benefits but also risks. Thus we see that the speed of information itself, which promotes quick and immediate response, can exacerbate problems. Before, those who took the problem home to study it, and those who simply found out late, provided the market a damper, which often might have saved it from hurried and ill-conceived reactions.”

And already in 1999 in another OpEd I had written: “The possible Big Bang that scares me the most is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause its collapse”

And then Basel II’s 20 percent risk weight for AAA rated securities, caused the financial crisis 2007-08; while Basel I’s zero riskweight assigned to sovereigns, doomed sovereigns like Greece.

Of course there is a need to think about the systemic risk of SIFIs, but even more important, is looking to minimize the systemic risks of bank regulations… or at least to recognize their existence.

A million of individual small banks can easily be turned into a very dangerous Systemic Overall Important Banking System, by just some rules drafted by some members of that mutual admiration club known as the Basel Committee for Banking Supervision.

@PerKurowski ©

When paid by Volkswagen, the fines should go to patent free research of better diesel engines… and emission controls

Sir, Brooke Masters write “Drivers who bought VW’s “clean diesel” engines are now faced with technical fixes that could well reduce both fuel efficiency and power. Their communities have much dirtier than anticipated air” “Lawsuit on behalf of 1m $1 investors is something to fear. Somebody ought to sue” October 3.

Indeed but when suing make sure that if you win it can make a difference, not just make up for something secondary.

Many Volkswagen’s diesel engine buyers, who said they bought it out of environmental concern, many of them just green show-offs, now have a legitimate grievance being left out hanging like fools. But, if they are going to sue, they should at least request that, if successful, all fines paid by VW should go to finance the development of patent free better diesel motors.

Brooke Master’s also writes: “There are many frivolous [and not non frivolous] law suites were the attorneys on both sides walked away with millions of dollars in fees”. And with that she reminds me of that, at least in the case of banks being sued, all lawyers should be paid their fees in bank shares… I mean so that we do not hurt the lending capacity of banks and with that of ten thousands of innocent bystanders borrowers… the sort of civilian casualties.

Perhaps if we start looking into the issue of where compensation payments and fees go to, and how it is paid, then perhaps we will start looking at tort reform from a much more productive angle.

@PerKurowski

Sir FT, who is more likely to engage in predatory bank regulations, men or women?

Sir, I have some questions to you in reference to Brooke Masters’ “Women regulate banks run by men” in Your FT Special Report on Women in Business of September 15.

An audit report from the office of inspector general of the FDIC broadly defines predatory lending as "imposing unfair and abusive loan terms on borrowers”. Since current risk-weighted capital requirements for banks cause additional discrimination against borrowers deemed as risky, this could also be deemed as predatory regulations.

So Sir, who do you believe is more likely to engage in such regulatory deviances, men or women?

Who is more likely to understand that those financial excesses that can endanger banks is not built with what is perceived as risky but what is erroneously perceived as safe, men or women?

Who is more likely to understand that the cost of introducing such risk-adverse regulations that cuts off bank credit to SMEs and entrepreneurs will be paid by future generations, men or women?

Who is more likely to understand that this sort of discrimination can only increase whatever inequalities exist, men or women?

And when finally understanding how stupid these current Basel Committee regulations are, who is most likely to say “sorry”, and then rectify, men or women?

Sir, just to make it clear, I do not hold any clear opinions in this matter… I am just asking about yours... do you dare giving it? 

@PerKurowski

Bank regulators have not even begun to learn from their mistakes

Sir, I refer to Brooke Master’s “Banks are still struggling to learn from their mistakes” March 14.

Master writes: “bankers say that the real problem with the US stress tests is that they are too complicated, opaque and difficult to predict. Regulators counter that financial meltdowns can come from unexpected sources and banks need to be ready”.

But I would ask the regulators: “If you think that financial meltdowns can come from unexpected sources, and banks need to be ready… then please explain the rationale behind the current risk weighted equity requirements for banks.”

Sir, bank regulators have not even begun to learn from their mistakes… just look at Basel III digging our banks and our economies even deeper into the hole they made.

Just look at how central banks are launching QEs, without even noticing how blocked the channels of bank finance are.

@PerKurowski

Any recklessness of bankers is by far surpassed by that of their current regulators.

Sir, Brooke Masters writes: “Reckless bankers caused the financial crisis by running their businesses without a care for the long term consequences”, “Bankers will fail to win back trust with tragedy analogies” December 13.

That is reckless reporting.

Regulators, by allowing banks to leverage 50 times and more their equity with assets perceived as “absolutely safe”, while at the same time ordering a much lower leverage for assets perceived as “risky”, caused the crisis and, by not acknowledging their mistake, and thereby hindering bank credit from flowing to where it can be most productive, keeps us submerged into it.

That was indeed reckless behavior, and bank regulators did it by not caring one iota about any long-term consequences… as can easily be evidenced by the fact that they have not even defined what the purpose of our banking system is.

“I can’t breathe!” If with respect to finance somebody has the right to utter that, that is the real economy… for which risk-taking is oxygen.

Sir, I protest FT for also failing to indict bank regulators, for causing our economies to stall and fall. (Is it that you automatically must side with the police?)

The Financial Stability Board, one of the Great Distorters, goes at it again

Sir Brooke Master and Tracy Alloway write about how the Financial Stability Board is focusing on securities lending, like the “repo” market. “Shadow banks face fresh limits to trading” August 30.

The FSB wants to impose: “a minimum .05 percent haircut for corporate debt securities with maturity of less than a year – so a $100 security could be used to raise $99.50. Equities and securitizations made up of debt with durations of five years and longer would be hit by a 4 percent haircut” allowing consequentially these latter only to be able to raise $96 for each $100,

Here one of the great distorters goes at it again. Do they not understand that by differentiating between short and long term they are distorting how the markets will allocate financial resources.

Come on FSB, in general terms of stability, what is wrong with long term debt? In terms of needed liquidity... does not long term debt need that perhaps even more than short term debt?

And I sure hope that Mark Carney, the Bank of England governor, and the FSB chairman, was joking when he called the proposal “an essential first step towards… transforming shadow banking into market-based financing” If not… “Houston we’ve got a problem”

Bank regulators insisting on playing risk managers for the world, evidences hubris and lunacy is still going strong.

Sir, it is indeed scary reading Brooke Masters reporting on a “Call to harmonise bank risk models”, August 6.

The average risk weight for sovereign corporate and institutional debt that European Banking Authority found in 35 big banks is quoted as being 35 percent with a standard deviation of 12 percent. This indicates how frightening badly capitalized most European big banks are.

In Basel II terms a 35 percent risk weight, applied to a generously defined 8 percent basic capital requirement, could indicate the average banks to be assets to equity leveraged about 35 to 1, and some even 55 to 1 and more.

But even scarier, is reading what EBA suggests. Bank regulators should not be risk-managers for the world and have no business concerning themselves with whether the models banks use to analyze their risk work or not. Their responsibility is to think exclusively in terms of what to do when risk-weights and risk-models do not function adequately. And, in this respect, the last thing regulators should do is precisely what the European Banking Authority calls for, which is “further moves towards harmonized rules for risk models”. That only guarantees to increase the systemic risk of many risk models being wrong at the same time. It is as if regulators have learnt nothing at all from this crisis.

All in all what the article indicates, is the need for a more simple leverage ratio type of capital requirement, which, since applied equally to all assets, makes it therefore more independent of risk models. That would of course also help to reduce the extreme distortions in the allocation of bank credit to the real economy introduced by capital requirements based on perceived risks.

Much more important than guaranteeing sufficient capital, is that bank capital requirements do not distort.

Sir, I am amazed. Brooke Masters, Financial Time’s chief regulation correspondent seems to be surprised with what she writes in “The leverage story that banks want to keep under wraps”, April 9.

Sincerely I had assumed, years after the outburst of the crisis, and after so many explicatory letters I have written to her and other at FT, she would have at least known that the risk-weighting of assets dramatically hides the true extent of bank leverage.

And she writes: “Bankers argue that leverage ratio is a crude tool that penalizes basic low-risk products”, which refers of course to those low-risk products which already benefit from lower rates and ample access to finance. Sincerely I hope Masters will now at least understand sufficiently that the current risk-weighted ratios, penalizes what is perceived as “high-risk”, that which is already penalized with higher interest rates and lower access to bank credit.

Sir, much more important than making sure banks have sufficient capital, is to make sure that their capital requirements do not cause distortions in the real economy, and which dooms it to disasters in which not even perhaps a 99 percent capitalized bank could meet its obligations