Do we know of a display of hubris greater than “risk weighted bank capital requirements”?

Sir, Gillian Tett in “Economists can’t predict the future — policy should reflect that” July 1 wrote: “Robert Rubin, Peter Orszag and Joseph Stiglitz called on economists to embrace ‘copious amounts of humility’ when projecting the future.”

One of the magnificent displays of hubris, the antonym of humility, came into being when bank regulators imposed, risk weighted bank capital requirements, as if they, from their desks, have any real bankable notion, of what the future really entails.

And on that, this trio, as the rest of the Academia, as Gillian Tett, as FT too, have all kept total silence.

Any populism your populist can do mine can do better; mine can do populism much better than yours.

Sir, Gillian Tett, when discussing populism and populists writes, “Nor is it obvious that Mr Trump will lose in 2020. If you look at recent opinion polls, these offer as much reason for alarm as for cheer.” “Is the populist wave in the west here to stay?” September 14.

Clearly populism is in the eye of the beholder. For instance, if Hugo Chavez had hosted “The Populist Apprentice” he might very well have told President Donald Trump. “You’re fired!” 

As for me Sir, you know very well I opine that one of the worst and most destructive populism ever, was when the expert bank regulators in the Basel Committee told us that with their risk weighted bank capital requirements, our banks would be safer… not caring one iota about how that would distort the allocation of credit to the real economy and, to top it up, base these on that loony idea that what's perceived as risky is more dangerous to our bank system than what's perceived as safe 

@PerKurowski

Ms. Gillian Tett, what is that we really have, capitalism or statism?

Sir, Gillian Tett lectures us interestingly with “If you want to understand what is at stake in this debate, it pays to consider the original meaning of the word ‘company’”... “a society, friendship, intimacy; body of soldiers”, “one who eats bread with you” “in other words initially synonymous with social ties”. “Capitalism — a new dawn?” September 7.

Yet, over the years I cannot rememer Ms. Tett saying a word about that our banks are regulated exclusively so as to be safe mattresses in which to put away our savings, without one single consideration given to their vital social purpose of allocating bank credit efficiently to the real economy. “A ship in harbor is safe, but that is not what ships are for”, John A Shedd.

And Ms. Tett also writes “the 2008 financial crisis had undermined faith in unfettered free markets.” What? Like those “unfettered free markets” with Basel II regulations that when in order to borrow from banks, borrowers would have to remunerate an amount of bank capital of 0% if sovereigns, 1.6% if AAA rated, 2.8% if residential mortgages and 8% if unrated entrepreneurs?

http://subprimeregulations.blogspot.com/2019/07/risk-weights-are-to-access-to-credit.html

@PerKurowski

In USA, for the patterns of default, differences between states as to “deficiency judgments”, should matter.

Wikipedia: “A deficiency judgment is an unsecured money judgment against a borrower whose mortgage foreclosure sale did not produce sufficient funds to pay the underlying promissory note, or loan, in full.”

Sir, the default patterns Gillian Tett refers to in “Driven to default”, March 14 will, in the USA, of course much depend of in what state the defaults occur, given the great differences in allowing or not “Deficiency Judgments”

Has there been any research on this issue? Not that I know off. But that is not surprising given how the fundamental mistake with current risk weighted capital requirements has also been widely ignored.

@PerKurowski

President Trump seems to be on route to become one of the greatest “paga-peos” (scapegoats) in history.

Sir, Gillian Tett writes that for her “money, there is another, darker, way to interpret this week’s [extreme volatility in US equity markets]. Two years into Mr Trump’s presidency, global investors are questioning the administration’s financial credibility…Steel yourself to cope with further turbulence triggered by Mr Trump”,“Expect more turbulence from Trump’s Fed fight”, December 28.

Indeed, president Trump is to be blamed for some of it, but the truth is that had the markets been more normal, not so much bubbled-up, he would only cause some ripples never Tsunamis.

That Trump has given indications to fire Jay Powell, the Fed chair, is bad in as far as it interferes with the necessary independence and credibility of a central bank. But, that said, let me also hold that, if a central banker or a regulator believes that what bankers perceive as risky is more dangerous to bank systems than what they perceive safe, and therefore use credit distorting risk weighted bank capital requirements, as they’ve done for a long time, that is a clear justified cause for their removal.

Venezuelan historians sometimes recount that in old days the refined ladies of the society always used to keep a young slave close by. Whenever they let out noisy and smelly gases, they would hit the slave hard and loudly on his head spelling out “Boy/Girl!” whichever applied. These useful blame-takers, scapegoats, were known as “paga-peos”, literally “fart-payers”.

Sir, President Trump clearly produces some gases himself, but he could also go down in history as one of the greatest paga-peos ever.

When booming equity markets, house prices and unsustainable debt levels everywhere, built up with easy bank credit, huge liquidity injections and ultra-low interest rates come crashing down, as they must, sooner or later, those who are much more to blame for it, could all jointly point at President Trump and shout “He did it!” and Ms. Tett might smilingly nod in agreement.

PS. Though in Spanish here you will find more interesting details about the “paga-peos” tradition and about how it can be used with even worse intentions.

@PerKurowski

Hercules Poirot, as a bank regulator, would be much more watchful of the “safe” than of the obvious risky.

Sir, Gillian Tett reminds us that “Any fan of Agatha Christie mystery books knows that distraction is a powerful plot device: if there was a commotion in the kitchen, detective Hercule Poirot would look for a body in the library, or other clues being hidden in plain sight, amid the noise.” “Federal Reserve attack is just a distraction”, November 30.

Indeed, but she could rest assure that Poirot, if cast as a bank regulator, would laugh at his current colleagues who show so much concern with what seems obviously risky, like when they in Basel II assign a risk weight of 150% to what’s rated below BB-, and so little about what seems very safe, like giving only a 20% risk weight to what’s rated AAA and is, therefore, if wrong, truly dangerous for the bank system.

Ms. Tett argues here that President Donald Trump “uses weapons of distraction more effectively than almost any leader before him”

She could be right but also, when GDP and inflation data are fraught with may uncertainties or outright errors, to hear the Fed discussing the “neutral rate”, could also be an intent to distract from the fact that they find themselves in that “dark room” deputy Fed chair Rich Clarida is quoted to have mentioned, and so that they therefore have not the faintest idea about what’s going on, and much less about what to do. 

Sir, when not knowing the answer to a question, proceeding to with a firm voice give an answer nobody is guaranteed to fully understand, also qualifies as a high quality distraction.

PS. That 20% risk weight of the AAA to AA rated, translated to a capital requirement of only 1.6% (8%*20%) which meant the banks were allowed to leverage mindblowing 62.5 times with such assets (100/1.6) which translated in to the cause numero uno for the 2008 crisis. 

@PerKurowski

Why should Donald Trump or Gillian Tett worry about US’s public debt when the experts, the bank regulators, assign it a 0% risk?

Sir, Gillian Tett, making it a Democrat vs. Republican issue, expresses anxiety about the US debt and suggests “a new version of the bilateral Simpson-Bowles Commission” “Investors start to fret about ballooning US public debt” November 9.

Sir, you know the regulators, for the purpose of bank capital requirements, assigned a risk weight of 0% to the sovereign debt of the USA and one of 100% to unrated American citizens (except when buying houses). That translates into that the interest rate politicians see is a subsidized interest rate, not its real cost. That dooms the US public debt to become, sooner or later, unsustainable… and especially so if markets begin to feel the US is losing its absolute military supremacy.

The bilateral Simpson-Bowles Commissionin 2010 presented many important recommendations that should be pursued, but it did not even mention the need to eliminate the regulatory subsidy to public debt.

Sir, unfortunately, getting rid of that distortion is no easy task, as regulators have really painted themselves into a corner. Can you imagine if regulators where to announce that the risk weight of US debt has been increased from 0% to 0.01%?

PS. In 1988, when with Basel I, statist regulators assigned that 0% risk weight the US debt was $2.6 trillion, now it is more than $22 trillion... but what has that to do with anything?

 

@PerKurowski

Paul Volcker warns public administration training is no longer on universities’ radar. Neither seems conditional probabilities and Bayes’ rule to be

Sir, interviewed by Gillian Tett, Paul Volcker’s tells her, “I would like my legacy to be some attention to public service. When I grew up good government was a good slogan. But now the phrase ‘good government’ is a mockery [and] universities have effectively abandoned practical public administration training, focusing instead on ‘policy’",“Volcker sets a challenge for the next generation” October 26. 

And Ms. Tett laments, “Few students want to make the type of financial sacrifices that Mr Volcker did for many decades, in the name of public service”

That concern has great merits, especially because the alternative would be to see our public service posts filled with experts in negotiating what crony statism could have to offer.

The Paul Volcker as Fed chair in the 1970s crushing inflation was a hero of mine. Unfortunately I woke up to the fact he helped doom to failure our banking system.

Getting the clue from Charles Goodhart’s “The Basel Committee on Banking Supervision: A History of the Early Years 1974-1997”, in Steven Solomon's “The Confidence Game: How Unelected Central Bankers Are Governing the Changed Global Economy” of 1995 I read:

“On September 2, 1986, the fine cutlery was laid once again at the Bank of England governor’s official residence at New Change… The occasion was an impromptu visit from Paul Volcker… When the Fed chairman sat down with Governor Robin Leigh-Pemberton and three senior BoE officials, the topic he raised was bank capital…

Adequate capital – the bank’s buffer against bankrupting loss- was the keystone of a central banker’s mission to uphold financial system safety and soundness.

They literally wiped the blackboard clean, then explored designing a new risk-weighted capital adequacy for both countries… 

It included… a five-category framework of risk-weighted assets… It required banks to hold the full capital standard against the highest-risk loans, half the standard for the second riskiest category, a quarter for the middle category, and so on to zero capital for assets, such as government securities, without meaningful risk of credit default.”

That led to the Basel Accord, Basel I in 1988. And of course, setting the capital requirements for the banks based on the risks that bankers cleared the most for, credit risk, had to dangerously distort the allocation of bank credit to the real economy. As I say over and over again, any risk, even if perfectly perceived, will cause the wrong actions if excessively considered.

Suffices to say that 100% of the assets that caused the especially large 2007-08 crisis were assets that, because they were perceived as especially safe, generated especially low capital requirements for the banks.

When I consider the total silence by universities on the consequences for the stability of our banking system and for the dynamism of our economies produced by the risk weighted capital requirements for banks, I am also saddened.

Universities, like Harvard Business School, do have “Conditional Probabilities and Bayes’ rule” on the curriculum. Could it be that professors are kept too busy preparing these courses so to have time to look out at what’s happening in the world? Or could it be their students, like Paul Volcker, never understood them.

Sir, wake up! When hubris filled besserwisser regulators tell you: “We will make your bank system safer with our risk-weighted capital requirements”, as if they were great clairvoyants, and you believe them, you have fallen for some pure, unabridged and very dangerous populism. 

The risk weighted capital requirements for banks guarantee especially large exposures, to what’s perceived as especially safe, against especially little capital, which dooms bank systems to especially severe crises.

PS. If regulators want to use risk weighted bank capital requirements, these should be based not on the credit risk of assets per se, but on the risk for the bank system the assets pose, conditioned on how risks are perceived and acted on by bankers. Who has the power to tell them so?

@PerKurowski

The risk premiums for a suspect of human rights violating nation will increase, which, sadly, will also attract investors

Sir, Gillian Tett, with respect to how business should or could behave in cases of human rights violations, like that of Khashoggi, if confirmed, writes: “since western businesses are scrambling to maintain their investments there at a time of rising Sino-American tensions. “What will we do the next time that the Chinese toss dissidents in jail or clamp down on local journalists?” asks one chief executive. The answer is not clear.” “The Khashoggi case puts US businesses in a moral bind”, October 19.

How much has the risk premiums required by anyone wanting to invest in Saudi Arabia gone up after the Khashoggi incident, and after how Saudi Arabia reacted against Canada when its Foreign Affairs Minister Chrystia Freeland tweeted concerns about the news that several social activists had been arrested in Saudi Arabia? These must have increased a lot, and an initial public offering of the Saudi oil giant Aramco is rumored cancelled.

That costs of course the human rights violating nation a lot… but those higher risk premiums also attract… as we can notice when a Goldman Sachs finances a notorious human rights violating regime like Venezuela’s Maduro’s.

The answer to the chief executive’s what to do question, should have to include “what our shareholders have mandated us”. Unfortunately too many shareholders also turn a blind eye to ugly realities, when for instance a Goldman Sachs announces record returns on equity.

What do we lack? Perhaps the will of a responsible elite that is willing to shame those who behave in a disgraceful manner, in a completely apolitical way. We need a society whose members would not invite Goldman Sachs’ Lloyd Blankfein to have tea at their homes. 

Sir, I have not been able to find the reference to it on the web but, some years ago, in Swedish television, I remember having heard something about a Swedish king who said he feared more the opinions of Stockholm’s high societies ladies than Russia. 

@PerKurowski

The priority of those who committed the mistakes that caused the financial crisis has been the cover up, not the corrections

Sir, Gillian Tett, similarly to like Martin Wolf wrote a couple of days ago, expresses surprise and concerns for the fact that so many things that were supposed to be corrected or at least bettered after the financial crisis seem worse today. She lists the level of debt and leverage, the market share of TBTF banks, the size of the shadow banks, and that no few bankers directly related to the crisis have been jailed. “Surprising outcomes of the financial crash”, September 7.

But how can one be surprised by so few corrections and betterments when those supposed to correct and better it remain being those who committed the mistakes, and have not been held accountable one iota for their mistakes? 

But how can one be surprised by so few corrections and betterments when in the aftermath of the crisis so many truths were classified as those that shall not be named, and consequently arduously silenced, like for instance:

Lack of regulations: Wrong! Total missregulation. Regulators for their risk weighted capital requirements for banks used the perceived risk of banks assets, those that bankers were already clearing for, and not the risk that bankers would perceive and manage the risks wrongly. They seemingly never heard of conditional probabilities.

Excessive risk taking: Wrong! It was the regulators excessive risk aversion that gave banks incentive to build up excessive exposure to what was perceived safe. Like allowing banks to leverage assets a mind-blowing 62.5 times only because some human fallible credit rating agencies had assigned it an AAA to AA rating.

Greece did it: Wrong! EU authorities did Greece in, when assigning a 0% risk weight to its debt. Is the statism implied in assigning a 0% risk weigh to the sovereign and one of 100% to the citizens discussed? No! There are too many interested in benefitting from crony statism for that.

Sir, Ms. Tett ends with “predictions are best presented with a dash of humility — and the knowledge that what does not happen can sometimes be even more significant than what actually does.”

Indeed but since “that what does not happen” could be much a result from a lack of questioning, to understand it could also require loads of humility from journalists. Capisce FT? 

@PerKurowski

When will someone invited dare to pose the question that shall not be made at a Davos or Jackson Hole gathering?

Sir, Gillian Tett writes: “The International Monetary Fund calculates that between 1970 and 2011, the world has suffered 147 banking crises... But whatever their statistical size, the pre-crisis period is marked by hubris, greed, opacity — and a tunnel vision among financiers that makes it impossible for them to assess risks.”, “When the world held its breath” September 1.

Sir, and why should regulators, who impose risk weighted capital requirements for banks, and stress test these be less affected by that “tunnel vision”? 

If regulators knew about conditional probabilities, if they absolutely wanted and dared to distort the allocation of bank credit, they would have set their risk weights based, not on the perceived risks of assets, but on how bankers’ perceive and manage risks.

Tett quotes Alan Greenspan with “I originally assumed that people would act in a wholly rational way, that turned out to be wrong.” Shame on him, had he just done his homework, he would have known that what was perceived as risky never ever causes financial crises, that is always the role of what was thought as very safe.

Tett also quotes Paul Tucker, the former deputy governor of the Bank of England with, “There is a dynamic which pushes banking and the penumbra of banking to excess, over and over again”. That “dynamic” force was the regulators pushing bankers into excesses, for instance by allowing them to leverage 62.5 times if only an AAA to AA rating issued by human fallible credit rating agencies was present.

Tett recounts: “One day in the early summer of 2007, I received an email out of the blue from an erudite Japanese central banker called Hiroshi Nakaso”, who warned her “that a financial crisis was about to explode because of problems in the American mortgage and credit market.” 

Tett was astonished, though she did, by then, not disagree with the analysis. May 19th 2007 I wrote the following letter to FT, which was not published.

“Sir, after reading Gillian Tett’s “A headache is in store when the credit party fizzles out” May 19, it is clear we should all go down on our knees and pray for that she is right, in that it is only a headache that is in store for us. 

As for myself I have serious doubts that the consequence of this blissful-ignorance-bubble resulting from our hide-and-not-seek the risks with derivatives, is unfortunately going to be much more painful than that. When that day comes though, before putting the sole blame on the poor bankers earning their luxurious daily keep; I suggest we look much closer at the responsibility of our financial regulators.”

Sir, sadly, that suggestion has been way too much ignored until now. 

“Why do you require banks to hold more capital against what by being perceived as risky is made less dangerous to our bank systems, than against what by being perceived as safe, poses so many more dangers?” That is the questions that seemingly shall not be asked by anyone who markets his name in the debate and does not want to risk being left out from Davos or Jackson Hole gatherings.

PS. Here is somewhat more extensive aide memoire on the mistakes in the risk weighted capital requirements for banks.

@PerKurowski

Special tax breaks for investment in O-zone is another source of distortion… and of gaming.

Sir, Gillian Tett writes that Steven Mnuchin the US Treasury secretary [told] luminaries such as Lloyd Blankfein, John Paulson, Howard Marks and Bill Ackman [to] put money into “development” projects in exchange for massive tax breaks.” “Populism is the true legacy of the crisis” August 31.

For a starter, given the presence of Goldman Sachs “luminaire” Lloyd Blankfein there I wish Mnuchin had also mentioned imposing special confiscatory taxes on any profits derived from financing regimes that notoriously violate human rights... namely giving odious credits.

As to tax breaks for investment in special opportunity zones O-zone, my objection would be the same like what I have against the risk weighted capital requirements for banks. It distorts the allocation of credit/investment to the real economy and it can be gamed.

@PerKurowski

Are bankers stopping their regulators from boarding a ‘listening bus’, scared these might wake up and then wake them up?

Sir, Gillian Tett asks: “can lofty chief executives ever find a way to get out of the C-suite and view life from a completely different perspective?” “Jamie Dimon’s ‘listening’ bus? Get on board”

Sir, of course it is good that Jamie Dimon, or anyone else for that matter, tries to listen to different opinions, though a bus is not really needed for that. 

But much more important than Jamie Dimon doing so it would be for the lofty besserwisser bank regulators to walk down Main street in order to learn more about banking, and life.

Then they might begin to understand that it is not what bankers perceive as risky which is dangerous to the bank system, it is what they perceive as safe.

But, being able to hold assets perceived as safe against so little of bank equity, meaning obtaining the highest returns on equity with what’s “safe” and not having therefore to venture into riskier terrains, sounds like a banker’s wet dream come true. Therefore perhaps it is bankers, like Dimon, whom all block regulators from leaving their desks, except for some controlled visits to Davos and Jackson Hole.

PS. As the less equity that needs to be compensated the more room there is for big banker bonuses, I am really not referring to an insignificant wet dream

@PerKurowski

Populism is not the exclusive domain of politicians and autocrats. Even technocrats practice it and experts fall for it

Sir, Ray Dalio, Bridgewater’s founder, told Gillian Tett “that the proportion of the western world voting for populist candidates had risen to 35 per cent. The figure, from a report by his firm, was starkly higher than at the start of the decade, when it was 7 per cent.” She finds that “unnerving on several levels” “Economics alone does not explain the surge of populism” August 4.

It is now ten years since a crisis caused exclusively by assets that because these had been perceived, decreed or concocted as safe banks could hold against very little capital turned out to be risky. And still so few question the wisdom of basing regulations on the belief that what is perceived as risky is more dangerous to our bank system than what is perceived as safe.

So Sir, I find it even more unnerving that seemingly 99.9% of regulatory experts, economists and financial journalists do still seem to believe, and ever refuse to question, those populist regulators who tell us they know all about bank risks, so as to make our banks safer with their risk weighted capital requirements.

Yes, many voters might fall for nice sounding populist promises, but others too, perhaps even you Sir, can sometimes not be able to resist these. Imagine, safe banks at no cost, does that not just sound too sweet not to believe?

@PerKurowski

Should central bankers answer my questions, or are they better off ignoring these?

Gillian Tett writes: “A century ago…central bankers barely talked to the public. Montagu Norman, the Bank of England governor from 1920 to 1944, is thought to have said: “Never explain. Never excuse.” That was partly because bank chiefs did not expect ordinary mortals to understand finance. But they also believed aloof detachment increased their authority.” “Should central bankers engage with the public?” July 28.

Sir, consider that I have with all means, even begging journalists to ask the questions, not been able to get an answer on something that should be very much within the general area of interest and responsibilities of a central banker, namely bank regulations.

My questions are simple and straightforward.

Why do you think that the regulators think that what is perceived as risky is more dangerous to our bank systems than what is perceived as safe? Could it be because regulators look at the risk of the assets of a bank, like bankers do, and do not look at the risk those assets could pose to the bank system, as regulators should do?

Why do you think that allowing banks to leverage differently their capital (equity) with assets based on different capital requirements, could not very dangerously distort the allocation of bank credit to the economy?

When are those European central bankers/regulators who assigned a 0% risk weight to Greece, going to be named and shamed, for dooming that nation to the so tragic consequences of excessive public debt?

Sir, “If Montagu Norman saw [my questions] what would he make of it all?”

Perhaps: “Never explain. Never excuse”, most especially when you have no explanation and you have no excuse?

@PerKurowski

Don’t help bank regulators get away from being held accountable for their mistakes by politicizing the issue.

Sir, Gillian Tett commenting on Ben Bernanke, Henry Paulson and Timothy Geithner comments on the 10-year anniversary of the Lehman Brothers collapse writes:“Critics on the right complain that markets have been hopelessly distorted by government meddling” “European banks still have post-crisis repairs to do” July 20.

Frankly, you do not have to be from “the right” to “complain that markets have been hopelessly distorted by government meddling”

In 1988 bank regulators, based the risk weighted capital requirements for banks they were introducing on the nonsense that what was perceived as risky was more dangerous to our bank system than what was perceived as safe. With that they dangerously distorted the allocation of credit to the economy… and caused the crisis.

Would the Lehman Brothers have suffered the same collapse had not the SEC authorized it in 2004 to follow Basel II rules, and it could therefore (just like the European banks) leverage 62.5 times with securities backed with subprime mortgages, if these counted with an AAA to AA rating issued by human fallible credit rating agencies. Of course no!

But here we are a decade later and this major flaw of current bank regulations is not even discussed. What especially excessive exposures to something perceived decreed or concocted as safe are banks in Europe, America and elsewhere building up only because of especially low capital requirements, and which will guarantee, sooner or later, especially large crises? That should be the concern.

But, come to think of it, it could be that Ben Bernanke, Henry Paulson, Timothy Geithner and Gillian Tett, still believe in the story the Basel Committee told them, perhaps because they want so much to believe that a fairy could make banks safe and still be able to serve the economy. 

@PerKurowski

When it comes to recklessness, the whizz-kids are small fry when compared to current bank regulators

Sir, Gillian Tett, referring to “the 2008 financial crisis writes: “Regulators were largely toothless because the whizz kids were creating financial instruments that straddled national borders, regulatory silos and outdated laws” “Cambridge Analytica scandal echoes the financial crisis” July 13.

Hold it there! If the regulators were “toothless”, what on earth were they doing regulating in the first place?

And, really, how much damage could reckless whizz kids have caused, if regulators had not, for instance allowed banks to leverage their capital with securities backed with mortgages to the subprime sector, 62.5 times, only because a human fallible credit rating agency had assigned that instrument an AAA to AA rating?

And what whizz kids have ever been involved with something as reckless as when regulators assigned a risk weight of 0% to sovereigns like Greece?

If we take this all to the issue of misuse of data, what are we to say about regulators who seem to keep a low profile on the fact that whatever data Cambridge Analytica laid there hands on, that was nothing when compared to the so much more extensive data social media, like Facebook, already possess. Could these regulators, in a Basel Committee for Data Supervision, really be crafting adequate policy responses that will not have serious “unexpected” consequences?

What if that data had now to be shared with governments, would that not make any autocrats’ “Big-Brother is Watching You” wet dreams come true?

@PerKurowski

Regulators gave banks great incentives to smoke around drum barrels marked “empty”, and to stay away from drums marked “full”.

Gillian Tett writes “before 2008 the big banks spent a great deal of time fretting about issues that seemed obviously risky — hedge funds or highly leveraged companies — but tended to ignore anything that seemed safe or boring, such as AAArated mortgage-backed securities” “What the Hopi culture teaches us about risk” June 23.

Sir, if you go to my TeaWithFT blog and click on Gillian Tett, you will find that over the years I must have written her at least 100 letters explaining that what is perceived as risky, drums marked “full”, is never as dangerous than what’s perceived as safe, drums named “empty”. 

But, if a 70 year old paper by US fire-safety inspector Benjamin Lee Whorf, based a lot on Hopi Native American culture, is more convincing to Ms. Tett than my arguments, so be it.

My real complaint though is that Ms. Tett only refers to what bankers did, and does not mention the fact that bank regulators, on top of it all, with their risk weighted capital requirements, allowed banks to smoke (leverage) much more around drums named “empty”, than around drums named “full”. 

So when Ms. Tett writes: “In theory, this danger has now receded: banks have been trained to take a more holistic view of risk and to question whether even AAA ratings are always safe”, let us not forget that with Basel II, regulators allowed bank to leverage a mindboggling 62.5 times if only an AAA to AA rating was present. Since that besserwisser regulatory mentality still prevails, and risk weighting derived incentives still exists, unfortunately I do not share the hope that dangers have receded. New dangerous “absolutely safe” always lurk around the corners.

And Sir, come on, we have European central bankers who told banks “You can smoke as much as you like around that 0% risk weighted drum named Greece”; and they have still not been made accountable for that… and, between you and I, you FT is not entirely without blame for that.

PS. The sad complement to this analysis is that what regulators decreed as drums marked “full”, and made banks stay away from, includes entrepreneurs and SMEs, something which must erode the dynamism of the economy. 

@PerKurowski

How can banks price risks correctly when regulators interfere and alter the payouts?

Sir, Gillian Tett writes: “If you peer into the weeds of global finance, you will see peculiarities sprouting all over the place… there is [a] pessimistic explanation: years of ultra-loose monetary policy have made investors so complacent that they are mis-pricing risk.” “Markets appear calm but are behaving abnormally” June 22.

Years of ultra-loose monetary policy, QEs or asset purchase program have indeed distorted the markets so there has to be much mis-pricing going on. But that’s not all.

The expected winnings (the dividends or payouts times the odds of winning) is exactly the same for all possible bets in a game of roulette. This is why roulette functions as a game. The credit markets with all the signals read and emitted, by all its many participants, givers and takers, continuously work towards equal payouts. And achieving these is what an efficient credit allocation is all about. 

But what if someone altered the payouts in roulette, like the regulators, with their risk-weighted capital requirements for banks did in the market of bank credit, how long would roulette survive as game?

Sir, just remember the 0% risk weight assigned by European central bankers to Greece. Those allowed banks immense leveraging and see such ROE payout possibilities that it went overboard lending to Greece; just in the same way Greece went overboard borrowing too much. 

And what about mispricing the risk of securities with a 20% risk weight in Basel II, which allowed banks to leverage 62.5 times only because some human fallible rating agencies had assigned these an AAA to AA rating? Frankly, is not the current bunch of bank regulators the mother of all mispricers ever?

So, to blame the investors, markets, banks for mispricing risks while blithely ignoring the regulatory (and other) distortions that exists is irresponsible; and could only be understood in terms of wanting to favour bank regulators… something which you hold in your motto you do not. 

Sir, let’s get rid of as many distortions as possible, so as to let investors, markets, and our banks stand a decent chance to do a good job allocating credit. The future of our grandchildren depends on it.

For a starter, and though the road there is full of difficulties, we must get back to one single capital requirement (8-15%) for banks, so that these can leverage the same against absolutely all assets.

@PerKurowski

The regulatory subsidy of house financing has caused much of the financialization of property markets.

Sir, Gillian Tett writes that since some investors are treating housing more like a tradeable asset, chasing yields around the world… [the] housing market is more “financialised”, [and so] a decade of ultra-loose monetary policy in the west has lifted so many geographically dispersed real estate boats” “New York property jitters herald declines elsewhere” May 25.

Since decades regulators allow banks to leverage much more their equity when financing the purchase of a house than for instance financing an entrepreneur. That means that compared to when banks held the same capital against all assets, which it did during most of its history, they now earn higher expected risk adjusted returns on equity when financing the purchase of a house, than for instance financing an entrepreneur.

Anyone who does not think this directly influences house prices should not be writing about finance.

What could the price of houses be in the absence of this regulatory subsidy? It’s hard to say. A static analysis would clearly yield the answer of much lower (30%?), but a dynamical one could perhaps yield higher prices, as a result of so many more affording houses because of more jobs created by entrepreneurs.

How do we get rid of the distortion? The sad fact is that for the redistribution profiteers it is much more interesting to offer affordable houses than to have more people affording their houses, which of course c'est pas la même chose. 

PS. One question I often ask myself is: nowadays when we finance someone’s purchase of a house how much of its price do we need to finance just because of the subsidized financing?