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

Are our productivity, real salary, unemployment, and GDP figures up to date?

John Authers writes, “If ever there was a good place to take a deep breath and gain context on our unnecessarily complex world, it would be Jackson Hole, Wyoming” “Powell avoids foreign complications in the winds of Wyoming” August 25.

In a recent post in Bank of England’s blog “bankunderground” I read: “With the rise of smartphones in particular, the amount of stimuli competing for our attention throughout the day has exploded... we are more distracted than ever as a result of the battle for our attention. One study, for example, finds that we are distracted nearly 50% of the time.”

So, one interesting way for central bankers to get an understanding of our ever more complex world would be to ask them: If you deliver the same at work as a decade ago, but now you spend 50% of your working hours consuming distractions, on your cell or similar, how much has your productivity, your real salary, your voluntary unemployment increased? And what about GDP?

PS. Sir, as you well know, before initiating the Jackson Hole proceedings, I would love for all central bankers there to assist a seminar on the meaning “conditional probabilities.” Had they known about it before imposing their risk weighted capital requirements for banks it would have saved the world from a lot of problems.

@PerKurowski

During this year’s central bankers’ Jackson Hole meetings, will there finally be a seminar on conditional probabilities?

Sir, you write “The global economy and financial markets remain relatively benign, but the political environment in which central banks once operated has changed, perhaps for ever” “The tricky politics of being a central banker” August 24.

Indeed, but all is not that tricky for central bankers and their financial sector regulation colleagues. Just think of how they have all been able to progress, for soon thirty years, Basel I 1988, without any knowledge about conditional probabilities. 

Imagine, even after a 2007-08 crisis, caused 100% by assets that had extremely low capital requirements, only because these assets were perceived as extremely safe, and they have not yet been called out on that.

If I were to be invited, I would again ask them: Why do you believe that what’s perceived risky is more dangerous to our bank system than what’s perceived safe, have you never heard of conditional probabilities? But of course I am not invited.

Sir, again I will invest some hope that a “Without fear and without favor” FT journalist dares to asks that question. I must confess though that investment will be quite small, as I want to avoid having to be so disillusioned again.

PS. Conditional probabilities and risks for the bank system

@PerKurowski

Crony capitalism, which is really crony statism, includes many crony relations with central banks and bank regulators

Sir, Mohamed El-Erian writes about Jackson Hole meetings 2017: “The symposium left open questions for markets that, given very profitable adaptive expectations, are conditioned to rely on central banks to boost asset prices, repress financial volatility and influence asset class correlations in a way that rewards investors and traders more.” “Yellen and Draghi had good reason for Jackson Hole reticence” August 29.

So instead of relying on the real economy, Mohamed El-Erian, and I presume all his colleagues operating in the financial markets, rely more on what central banks do.

That is so sad, especially since the risk weighted capital requirements for banks, hinders all central bank stimuli to flow where it should. We now have buyback of shares, dividends financed with low interest rate loans, house prices going up, but SMEs and entrepreneurs not getting their credit needs satisfied because the regulators feel these are "Oh so risky!"

El-Erian reports: “Janet Yellen, chair of the US Federal Reserve, and Mario Draghi, president of the European Central Bank — [told] politicians about the importance of financial regulation”

That only happens because politicians have not dared to ask regulators questions like:

Who authorized you to distort the allocation of bank credit in favor of those perceived, decreed and concocted, as “safe”, like sovereigns and AAArisktocracy, and away from the “risky”, like SMEs and entrepreneurs?

Where did you find evidence that those perceived as risky ever caused major bank crisis? As history tells us, these were always, no exceptions, caused by unexpected events, like those ex ante perceived as very safe turning up, ex post, as very risky. 

PS. Do bankers love these crony relations? You bet! Being able to earn the highest expected risk adjusted returns on equity on what is perceived as very safe, must be a wet dream come true for most of them. And besides, by requiring so little capital, and therefore having to serve much less any shareholders’ aspirations, there is much more room for their outlandish bonuses

@PerKurowski

Free our economies from risk weighted bank capital requirements; foremost from the 0% risk-weighting of sovereigns

Sir, you write about the “US Federal Reserve and the European Central Bank, facing the relatively pleasant task of withdrawing stimulus after years of good economic growth.” “The Fed ponders the fractious politics of debt” August 25.

Sir, may I ask you, do you really think the economic growth we have seen could be qualified as good considering the immense stimulus given through QEs and low interests? If the growth had really been consistent with the amount of stimulus given we wouldn’t have these qualms about reducing central banks’ “swollen balance sheets”, would we?

And then you favour Janet Yellen and Mario Draghi with, “ECB and the Fed are fortunate in being headed by two competent policymakers”. I do not agree with your assessment. Both of them, when it comes to regulating banks, which is something they do, are simply clueless.

First: Basel II, for the purpose of capital requirements for banks, assigned a risk weight of 20% to what is rated AAA and one of 150% to what is rated below BB-. That clearly assumes that the ex ante perceptions about risks are not cleared for in any way, and that these would therefore be indicative of the ex post risks. That is plain stupid and those unable to understand that are not qualified to regulate our banks.

Second: Sovereign debts have been zero risk weighted while unrated citizens have been assigned a risk weight of 100%. That is unauthorized regulatory back door statism that subsidizes governments’ access to credit, and which is paid for by taxing, for instance SMEs and entrepreneurs, with in relative terms much less and much more expensive access to bank credit.

Third: Those who cannot understand that the risk-weighted capital requirements hinders the efficient allocation of credit to the real economy; and therefore its distortions wastes much if not all of any stimulus, should not have anything to do with QEs.

Fourth: Those who to the “swollen balance sheet built up by quantitative easing”, refuse to add the sovereign debt and the reserves held in central banks that are a direct function of preferential risk weighting, do not understand the magnitude of the difficulties we are facing.

Sir, day by day our banks, thanks to regulators, are dangerously overpopulating more and more whatever perceived, decreed or concocted safe havens there are. Equally dangerous for our real economies, they keep on underexploring the risky bays that could contain the real factors that could help us to a better future, or at least not a much worse one.

Sir, your steadfast silence on these regulatory failures seems to evidence complicity.

@PerKurowski

Will Jackson Hole Conference 2017 also ignore the distortions produced by the risk-weighted bank capital requirements?

Sir, Michael O’Sullivan, when speculating on Paul Volcker’s presence during this year’s Jackson Hole conference, writes that: “he might well look askance at the actions of contemporary central bankers. Volcker was an inflation crusher, a rate-riser (to 20 per cent) and, we can suspect, someone who believed that investors and economies had to bear the consequences of their choices”, “Jackson Hole offers central banks a chance to hand over baton” August 22.

Indeed but we should not forget that the Fed’s Paul Volcker, teaming up with the Bank of England, was the one who promoted the risk weighted capital requirements for banks… those who have, and still are, horrendously distorting the allocation of bank credit to the real economy.

Basel I, with its 0% risk weight, allowed banks looking to maximize returns on equity, to leverage infinitely the net risk adjusted margins, when paid by a friendly sovereign.

Basel II, for whenever an AAA to AA rating was present in the private sector, authorized a mindboggling 62.5 times leverage.

Basel I and II assigned a risk weight of 100% to risky SMEs and entrepreneurs’ allowing these borrowers’ net risk adjusted margins to be leveraged just 12.5 times.

So banks are going overboard lending and investing in what is perceived, decreed or concocted as safe, the present; while abandoning financing “the risky”, the future.

And all this because silly risk adverse regulators just can’t get their hands on the difference between ex ante and ex post risks. When you argue with them that what is perceived as very risky becomes by that fact alone safe, and that what is perceived as safe becomes risky, their eyes go blank… and they ignore you.

Bankers who are having their wet dreams of earning the highest ROEs on what is “safe”, with so little shareholder capital that it leaves much over for their bonuses, also keep an interested mum on this.

Sir, the immense stimulus offered by central banks has been wasted because the can was kicked down the wrong roads of increasing asset prices and government debts, and not down the road of those who can best help us to a better future.

Risk taking is the oxygen of development. God make us daring!

In the name of my constituency, my grandchildren, I can only say, “Damn those bank regulators”

@PerKurowski

ECB’s Mario Draghi’s star quality would evaporate had he to publicly answer some hard questions on bank regulations

Roger Blitz writes: “Mario Draghi, president of the European Central Bank, will be the star at the annual Jackson Hole symposium in Wyoming this year.” “Weak dollar remains centre stage” August 5.

Sir, if Mario Draghi, a former chair of the Financial Stability Board, and the current chair of the Group of Governors and Heads of Supervision (GHOS) of the Basel Committee, and therefore one of the most responsible for current bank regulations is the star of anything, that is only because he has never been made to fully answer some questions about current bank regulations in public, by his peers or by for instance FT’s journalist.

There are many many questions I could think of, but let me just indicate two:

First: Mr. Draghi. Do you not think that allowing banks to leverage more their equity with the net margins offered by those perceived safe than with those same margins when offered by those perceived risky; which means it is easier for banks to obtain higher returns on equity with “the safe” than with “the risky” does not distort the allocation of credit to the real economy?

If Draghi answers no, then there is nothing to do, as he would be evidencing he is clueless about finance on Main Street. If he answers yes then follow up with: Don’t you think this could be dangerous for the real economy and who authorized you and your colleagues to do so?

Second: Mr. Draghi, obviously current risk weighted capital requirements for banks, more perceived risk more capital, less risk less capital, indicates you the regulators believe that what is perceived as risky, is what is risky for the bank system. So, will you please tell us when there has ever been a bank crisis that has resulted from excessive exposures to what was perceived as risky when placed on the balance sheets of banks? As far as I gather from history all bank crisis, no exceptions, have been caused by unexpected events, criminal behavior or excessive exposures to what was perceived as safe when incorporated on banks’ balance sheet but that later, ex post, turned out to be very risky.

If Draghi answers yes, then he is deaf and has not heard the question. If he answers no, then ask him to explain why Basel II assigned a standard risk weight of 20% to what was AAA to AA rated and a 150% to what was rated below BB- and would therefore not be touched by bankers even with a ten feet pole.

Sir, Mario Draghi at ECB and others at the Fed with QEs and low interest rates, have just been kicking the 2008 crisis can down the road. The risk weighted capital requirements have caused that can to roll on the wrong roads. That is an act of terrorism against our economies.

@PerKurowski

If they do not belong to her The Group, the tribe, Gillian Tett does not seem to read what her readers write to her.

Sir, Gillian Tett writes “Echoes of 2008 as danger signs are ignored ” and mentions the “Jackson Hole tribe barely mentioned these at all”. “We had all better hope that by the summer of 2017 a debate about finance gets a proper billing at Jackson Hole” September 2.

I invite you here to read the probably more than hundred letters I have sent Ms Tett over the years, but that she has decided to ignore, probably because I do not belong to her The Group.

Who am I? Just a former Executive Director of the World Bank who, in October 2004, in a formal statement delivered at the Board wrote:

“Phrases such as ‘absolute risk-free arbitrage income opportunities’ should be banned in our Knowledge Bank. We believe that much of the world’s financial markets are currently being dangerously overstretched through an exaggerated reliance on intrinsically weak financial models that are based on very short series of statistical evidence and very doubtful volatility assumptions.”

In January 2003, in FT, I warned “that, sooner or later, the ratings issued by the credit agencies are just a new breed of systemic errors, about to be propagated at modern speeds”

Here are more of my documented early opinions (1997-2004) on bank regulations

So what would I like Ms Tett to do? To be more than a groupie and do her job asking those she might meet in Jackson Hole, Davos and similar The Group meetings, some of the too many questions that have gone unasked by journalists over the last soon 30 years, like:

How have you defined the purpose of banks before regulating these?

“A ship in harbor is safe, but that is not what ships are for.” John A Shedd, 1850-1926

Why do you base your capital requirements on the ex ante perceived risks?

“May God defend me from my friends. I can defend myself from my enemies” Voltaire.

Had Tett, or any other important financial journalist, like Martin Wolf, asked some of these questions much earlier, we might not have the need to even reference 2008.

The Basel Accord, Basel I, 1988, set the risk weight of the Sovereign at 0% and that of We the People at 100%... which de facto means that regulators believe government bureaucrats give better use to bank credit than the private sector… something that most of us on Main Street and who are not runaway statists, would find sort of questionable.

@PerKurowski ©

More than low-growth, central bankers fear having to explain risk-weighted capital requirements for banks

Sir, Sam Fleming, reporting on the meetings at Jackson Hole writes: “Eight years after the crash, major economies including the US are stuck with sub-target inflation, ultra-low rates, and economic growth that remains pedestrian…[central banks] could be trapped in a low growth rut that leaves them hugely vulnerable when the next downturn comes.” “Central bankers fear threat of low-growth rut”

And again the distortion in the allocation of bank credit to the real economy that the credit risk weighted capital requirements for banks causes, was not even discussed.

But of course, who would want to discuss the following?

Sir, you risk weigh an AAA to AA rated asset with 20% and a below BB-rated asset with 150%. Do you mean that assets that are perceived as very risky are more dangerous to the banking system than assets perceived as very safe?

Sir, explain how on earth you have gotten away with risk-weighing the Federal Government at 0% while risk weighing “We the People” at100%?

Sir, if a bank can leverage one asset more than another, would it then not expect to earn a higher risk adjusted return on equity with that asset, and would it then not invest more than normally in that asset?

@PerKurowski ©

What does stealing a show among adoring fan means? Draghi should dare to address a room full of unemployed young Europeans

Sir, Mario Draghi, as the former chairman of the Financial Stability Board, is one of the responsible for the risk-weighted capital requirements for banks, which, because regulators think that is too risky for the banks, stop banks in their tracks from lending to medium and small businesses, entrepreneurs and start-ups.

And so now, when Gavyn Davies reports that “Mario Draghi steals the show at Jackson Hole” August 27, I have to wonder how Draghi would be received by a crowd of well informed young unemployed Europeans? I really doubt he would there be able to steal a show, most likely he would have to retire running.

Don´t prime pumps, when unclogging the tubes is needed

Sir, John Plender, referring to the annual gathering of central bankers at Jackson Hole, writes “Policy makers agonize over how best to prime the pump”, August 29, 2012. How sad they will waste their time agonizing over the wrong problem. When the tubes are clogged, you need to unclog these before priming the pump. 

Current bank regulations, specifically the capital requirements for banks based on perceived risk, are hindering the flow of credit from reaching those we most need for it to reach, namely the job creating small businesses and entrepreneurs. 

Frankly... what are the thickheaded bank regulators smoking?