Could the Basel Committee learn enough from puzzles and poker so as to correct their misinformation?

Sir, I refer to Tim Harford’s “What puzzles and poker can teach us about misinformation” FT Weekend December 5.

When deciding on what’s more dangerous to banks the regulators in the Basel Committee, with “expert intuition” and great emotion shouted out the “below BB-” and, for their risk weighted bank capital requirements, assigned these a 150% risk weight, and a very smallish 20% to what’s rated AAA.

But, with what type of assets can those excessive exposures that could really be dangerous to our bank systems built-up, with assets rated below BB- or with assets rated AAA?

Never ever with assets perceived as risky, always with assets perceived as safe.

Sadly, the regulators had missed their lectures on conditional probabilities.

And their “expert intuitions” are so strong that they were not able to understand the clear message sent by the 2008 AAA rated MBS. 

What does Tim Harford think regulators could learn from puzzles and poker to correct their misinformation?

PS. Trying to understand the how come of the so loony bank regulations, by reading Daniel Kahneman’s “Thinking, Fast and Slow” 2011.

@PerKurowski

The risk weighted bank capital requirements, is just a lean and mean “regression to the mean” machine.

Sir, Tim Harford when discussing luck and reversal of fortunes, holds that genius followed by mediocrity [is] likely a “regression to the mean”, or in simple terms, a return to business as usual. “It can be hard to discern luck from judgment” May 25.

Indeed, but sometimes that reversal to the mean, has nothing to do with such mystical issues as luck, but is a direct consequence of a distortion. 

As I have often written to FT about, allowing banks regulatory privileges when financing what’s perceived as safe, like sovereigns or houses, will result in too much financing of the safe, which will cause “the safe”, sooner or later to revert to become very risky.

In the same vein, those who without correcting for a crisis are now considered triumphant, like ECB’s Mario Draghi, only because they’ve managed to kick a crisis-can forward, will one day be held much accountable, when that crisis can rolls back on some, as it sure must.

@PerKurowski

Loss aversion has bank regulators looking too much at the cost of the crisis, while ignoring the benefits of the whole boom-bust cycle.

Sir, Tim Harford writes: The concept of “loss aversion” developed by Daniel Kahneman and Amos Tversky…showed that we tend to find a modest loss roughly twice as painful as an equivalent gain… Those who were forced to evaluate and decide at a slow pace were… not intimidated by short-term fluctuations… less likely to witness losses.”, “The languid pleasures of slow investing” February 10.

That is precisely what happens when bank regulators go into action during a crisis; they just look at the losses, and completely ignore what good might have been achieved during the whole boom-bust credit cycle.

And that is why our regulators in the Basel Committee, panicking, imposed risk weighted capital requirements for banks, which pushes debt that relies more on existing servicing capacity, like financing “safe” houses, than debt that hopes to generate new revenue streams, like loans to “risky” entrepreneurs.

And we all know there’s little future in that!

Harford ends with: writes: “Perhaps we slow investors should adopt a mascot. I suggest the sloth” Indeed, and let us send a stuffed one to Basel.

An aide-mémoire on the major mistakes with the risk based capital requirements

@PerKurowski

“Regression to the mean” is one of the reasons the current risk weighted capital requirements for banks are loony.

Sir, Tim Harford writes: “for statistical reasons, outstanding performances tend to be followed by something less impressive. This is because most performances involve some randomness. On any given day, the worst observed outcomes will be incompetents having an unlucky day and the best observed outcomes will be stars having a lucky day. Observe the same group on another day and, because luck rarely lasts, the former outliers will not be quite as bad, or as good, as at first they seemed. This phenomenon is called “regression to the mean”. “Reversals of fortune have random roots” April 22.

And yet Sir, our dear undercover economist finds it so hard to understand how loony current risk weighted capital requirements for banks really are.

Perhaps he might be interested in what I reflected on when reading Daniel Kahneman’s “Thinking, fast and slow”

http://subprimeregulations.blogspot.com/2013/12/understanding-how-come-of-so-loony-bank.html

@PerKurowski

Gillian Tett also suffers from "biases in our brains that undermine our capacity to make rational decisions”

Sir, Gillian Tett writes on the issue of “how bad humans are at assessing risk”, and refers to that “academics Daniel Kahneman and Amos Tversky have highlighted all manner of biases in our brains that undermine our capacity to make rational decisions.” “Fear of cultural ‘pollutants’ can be allayed with acceptance”, February 11.

As an example, Tett mentions that in the US “the data suggest that the chance of dying in a terrorist attack by a refugee, of any religion, was just one in 3.64bn in any given year. That is far lower than the risk of being struck by lightning”. Yet Tett writes, there is “irrational” fear of immigrants.

Ms. Tett, should perhaps do well showing more humility because, like all of us, she is just as bound to be afflicted by exactly the same human weakness. 

There is no data that would indicate that any major bank crisis was caused by excessive bank exposures to something perceived as risky when placed on balance sheets; and all data points that the real dangers lies with what is perceived as very safe, yet Ms Tett, her colleagues, and most of the bank regulation community see nothing strange with risk weights of 20% for what is AA to AA rated and 150% for the below BB-.

Ms Tett writes “There is little point in countering people’s “irrational” fear of immigrants by throwing statistics about or dismissing Trump’s supporters as “racist”.

Sir, I am of course not talking about racism, but should I not insist, as I do, day after day, with thousands of letters, in trying to illuminate those that who by favoring the dangerous safe, actually discriminate against the access to bank credit of the innocuous risky?

Over the last decade, around the world, millions of SMEs and entrepreneurs have seen their begging for an opportunity denied by sheer financial regulatory bigotry. And Sir, you are well aware that FT shamefully keeps mum on it.

@PerKurowski

The “peak end” rule factor is very dangerous. It fools us into interpreting ex post resulting risks, as real ex ante risks.

Sir, Tim Harford writes about “How the sense of an ending shapes memory” May 28

In it Harford refers to the “peak-end rule” that arose from a 1993 study titled "When More Pain Is Preferred to Less: Adding a Better End" by Daniel Kahneman, Barbara Fredrickson, Charles Schreiber, and Donald Redelmeier. 

That rule also points like at us remembering more the status found at the end, the ex post, than the one existing at the beginning, the ex ante.

At the end of a bank crisis, many bank borrowers might appear with a Below BB- rating. And therefore this “peak-end” rule might explain, why regulators awarded the below BB- rated a 150 percent risk weight. 

That is ​so tragically dumb, since the banks would never ever have created, ex ante, the dangerous excessive bank exposures to below BB-rated.

Those were more likely to have happened, and are much more likely to happen, with the AAA to AA rated; those awarded a meager 20 percent risk weight.

@PerKurowski ©

What behavioral theory explains how hard it can be for even those who know it to understand?

Sir, Tim Harford discusses “base rate” and admonishes us:“It is easy to leap to conclusions about probability, but we should all form the habit of taking a step back instead. We should try to find out the base rate, or at least to guess what it might be. Without it, we’re building our analysis on empty foundations” “How to make good guesses” February 26.

So Mr. Harford: Clearly an asset that is evaluated as risky is normally expected to cause larger losses to a bank than an asset that is perceived as safe. But, what is the base rate for that a bank would create excessive exposures to what is ex ante perceived as risky? Is really what’s risky more dangerous to the bank system than what is perceived or has been deemed as safe? 

What sort of behaviorial explanation would Daniel Kahneman, Amos Tversky, Maya Bar-Hillel, Richard Nisbett, Eugene Borgida, Philip Tetlock and other experts give to the fact that a person like the Undercover Economist, even when in possession of the required knowledge, just cannot accept the fact that the pillar of our current bank regulations, the credit risk weighted capital requirements, is built upon a completely wrong foundation? 

@PerKurowski ©

‪#Oxfordlitfest‪ ‬An opportunity to see if Martin Wolf has overcome his intuitions with respect to bank regulations

"More-perceived-risk-more-bank-equity and less-risk-less-equity", sounds so utterly logical, that perhaps intuition kills understanding… or, in Daniel Kahneman’s terms, that System 1, the fast intuitive and emotional one, is so convinced it has done its part, so as not to allow System 2, the slower more deliberative and more logical thinking process, to kick in.

For instance Martin Wolf, in July 2012 wrote: “Per Kurowski, a former executive director of the World Bank, reminds me regularly, crises occur when what was thought to be low risk turns out to be very high risk.” 

Yet Wolf has not been able to take it from there and deduct that, if so, and as all empirical evidence supports, then those bank equity requirements should perhaps be 180 degrees the opposite.

Sir, what on earth has a regulator to do with the perceived risks of bank assets, when what he should be exclusively concerned with, is with how bankers perceive those risks and manage these?

Our banks currently are like in a car with two steering wheels; the first one controlled by bankers, and the second by regulators who are responding, simultaneously, to basically the same risks the banker sees. And so of course we must crash either because banks embrace excessively what seems safe, or because of an excessive aversion to what seems risky.

Perhaps ‪Oxfordlitfest‪ would provide an opportunity to see if Martin Wolf has finally managed to engage System 2, by asking him: 

Mr. Wolf: If bank crises usually result from excessive exposures to something which ex ante has seemed safe but that ex post turned out to be risky: Why are equity requirements for banks lower for what is perceived as risky than for what is perceived as safe?

Mr. Wolf: Give us one single bank crisis resulting from an excessive exposure to something that was perceived as risky, when banks put that asset on their balance sheet.

Few things hamper growth as much as sissy bank regulations.

Sir, Gillian Tett writes that according to BoE’s Andy Haldane, there has been “a shift in cultural attitudes towards the future” with “our hyper-connected technology [perhaps] inadvertently shortening our time horizons [making us] less ‘patient’ less able to plan and invest long term” “How impatience hampers long-tem growth”, February 20.

And Ms. Tett, as an anthropologist who knows “cultural attitudes toward time vary”, finds this interesting. And indeed it is!

But, why on earth is Ms. Tett, the anthropologist, not interested in the willingness of societies to take the risks, that which gives future a chance?

At this moment, the most significant danger to growth is the risk-aversion imposed on banks, by means of equity requirements based on perceived credit risks; those that allow banks to earn higher risk adjusted returns on equity when lending to the safe than when lending to the risky. That goes back a very short time, to the early 90’s Basel I, and then much increased in 2004, with Basel II.

Ms. Tett also refers to Daniel Kahneman’s fast and slow modes of thought. And so let me explain in those terms:

The at-first-sight “System 1: Fast, automatic, frequent, emotional, stereotypic, subconscious” standard basic intuition of risky-is-risky and safe-is-safe, has proved too strong so as to permit opening a more reflective “System 2: Slow, effortful, infrequent, logical, calculating, conscious” analysis… which would lead to risky-is-safe and safe-is risky and most specially if that means questioning some of the other members of a mutual admiration mutual important network club.

Look for instance at Martin Wolf. In July 2012 he wrote: “As Per Kurowski, a former executive director of the World Bank, reminds me regularly, crises occur when what was thought to be low risk turns out to be very high risk." And yet Wolf is incapable to take it from there, so as to accept that perhaps current bank regulations, with respect to perceived credit risk, are 180 degrees off target.

Regulators wrongly believe that to increase the stability of banks, they must stimulate risk-aversion.

Sir, I refer to Martin Wolf’s “Make policy for real, not ideal, humans” December 17.

In it and with references to the World Bank’s latest World Development Report (WDR2015); and Daniel Kahneman’s “Thinking fast and slow” he writes, “most of our thinking is not deliberative but automatic; it is socially conditioned; and it is shaped by inaccurate mental models”.

Clearly, the socially conditioning of believing experts to be unable to totally get things wrong, have stopped most, Martin Wolf included, from accepting the fact that current bank regulators decided automatically with no deliberation and based on inaccurate mental models. Let me for the umpteenth time repeat the evidence:

Automatic thinking would be: Risky is risky, safe is safe, and therefore banks should be required to hold more capital against risky assets based on perceived risks.

Deliberative thinking would be: What is risky might not be risky if it is perceived as risky, while what is perceived as safe might be really dangerous if it turns out to be risky, and therefore perhaps banks should be required to hold more capital against what is perceived as safe, than against what is perceived as risky.

And an inaccurate mental model is one that is based on that the only purpose of banking is to serve as a safe mattress where to stash away our savings, while ignoring its fundamental social purpose of allocating bank credit as efficiently as possible. And because of that bank regulators did not care on iota about how with their credit risk weighted capital requirements for banks, they have caused huge distortions by allowing “safe” assets to produce much higher risk-adjusted returns on equity than “risky” assets.

WDR2015 mentions “the tendency of poor women to believe that the right treatment for diarrhea is to cut fluid intake, to stop their child ‘leaking’”.

Frankly, those in the Basel Committee, and in the Financial Stability Board, and most “experts” on regulations are just as wrong. They believe that the right thing to do for the stability of our banks (and our economies) is to stop the leakages… by increasing the risk-aversion.

Unfortunately, the power of “automatic” thinking is enormous. In July 2012 Martin Wolf wrote that I regularly reminded him of that “crises occur when what was thought to be low risk turns out to be very high risk” but, as we could see in his latest book “The Shifts and the Shocks”, he has yet not been able to internalize the meaning of it.

On bank regulations why can’t we get to the heart of its problems? Why can’t we keep political agendas out of it?

Sir, I refer to Edward Luce’s “Too big to resist: Wall Street’s come back” December 14.

Anyone who with an open mind reads Daniel Kahneman’s “Thinking, Fast and Slow” 2011, or this years “World Development Report 2015: Mind, Society, and Behavior” issued by the World Bank, should be able to understand the following with respect to current bank regulations:

Regulators (and ours) automatic decision-making makes us believe that safe is safe and risky is risky; while a more deliberative decision-making would have made us understand that in reality very safe could be very risky, and very risky very safe.

And so when so many now scream bloody murder about the influence of big banks in the US congress, because these managed to convince legislators to allow “banks to resume derivative-trading from their taxpayer insured arm”, they posses very little real evidence of what that really means… except, automatically, for the fact that it all sounds so dangerously sophisticated.

No, if there is something we citizens must ask our congressmen to resist, that is the besserwisser bank regulators who, with such incredible hubris, thought themselves capable of being risk-managers for the world, and decided to impose portfolio invariant credit risk weighted capital requirements for banks.

These regulations distorted all common sense out of credit allocation, and cause the banks to expose themselves dangerously much to what is perceived as “absolutely safe”, while exposing themselves dangerously little for the needs of our economy to what is supposedly “risky”, like lending to small businesses and entrepreneurs.

If we, based on what caused the current crisis should prohibit banks to do, it would have very little to do with derivatives, and all to do with investing in AAA rated securities, lending to real estate sector (like in Spain) or lending to “infallible sovereigns” like Greece.

Does this mean for instance that I do not agree with FDIC’s Thomas Hoenig’s objection to US Congress suspending Section 716 of Dodd-Frank? Of course not! But, before starting to scratch the regulatory surface, something which could create false illusions of safety, or even make it all much riskier… we need to get to the heart of what is truly wrong with the current regulations… Sir, enough of distractions!

And also enough of so many trying to make a political agenda and election issue out of bank regulations… as usual it would be our poor and unemployed or under employed youth who most would pay for that.