Martin Wolf insists on turning a blind eye to the Financial Instability AAA-Bomb armed by the Basel Committee

Sir, Martin Wolf writes: “it has to be possible for the financial system to cope with changes in asset prices without blowing up the world economy… An essential part of achieving this is deleveraging and in other ways strengthening intermediaries, notably banks.” “Central banks alone cannot stabilise finance” October 25.

What did the Basel Committee for Banking Supervision do, for instance with Basel II?

They assigned risk weights of 0% for AAA rated sovereigns, 20% for AAA rated private sector, 35% for residential mortgages and 100% for the unrated private sector.

That, with a basic capital requirement of 8%, translated into banks being able to leverage their capital (equity): limitless with AAA rated sovereigns, 62.5 times with AAA rated private sector, 35.7 times with residential mortgages and 12.5 times with the unrated private sector.

Major bank crisis never ever result from excessive lending to what is perceived as risky. These, with the exception for when some major unforeseen events occur, always result from excessive exposures (credit bubbles) to what is ex ante perceived as safe, but that ex post turns out to be very risky, often precisely because too much credit has been given to it.

So considering that this regulation implies telling banks to go to where for the system it is the most dangerous, while holding the least capital, it must truly be classified as a bomb against financial stability. In 2009, in sad jest, I set up a blog titled The AAA-Bomb.

And oh if the only thing that bomb produced was financial instability. But no, it also produces economic weakness, by negating the “risky” the access to credit they need in order to keep the economy going forward. We finance much more the building of safe basements in which our jobless children can live, than those “risky” who could have a better chance to provide them with the jobs they need to move to their own upstairs.

And don’t tell us that if a bank can leverage much more with the “safe”, and thereby obtain much higher expected returns on equity with the “safe” than with the “risky”, it will keep on bothering with lending to SMEs or entrepreneurs. Of course it won’t. The risk weighted capital requirements for banks have turned our savvy know-your-client loan officers into dumb equity minimizers.

With respect to “deleveraging and in other ways strengthening intermediaries, notably banks” Wolf now opines “That has indeed happened, but not, in my view, nearly enough.”

Well of course not! How could that be, when even Martin Wolf himself has played a great role in silencing the existence of that bomb… that about which I have written to him more than 400 letters and to FT in general more than 2.500.

Finally Martin Wolf writes about “the failure of governments to address the many frailties that still lead to financial excess. The central banks did their job. Unfortunately, almost nobody else has done theirs”

What? Look at the major role central bankers like Paul Volcker, Mario Draghi, Jaime Caruana, Mark Carney, Stefan Ingves and many other have had or have in the area of banking regulations. They, by ignoring the distortions in the allocation of bank credit to the real economy these regulations caused, have wasted most of the stimulus they have been injecting with their quantitative easing and low interest rates.

Sir, since getting rid of the risk weighted capital requirements for banks is not even mentioned here by Wolf, and you yourself can be considered a partner in the silencing of me, I guess this letter will also be added to the silenced ones… but of which I of course keep a record… here on the web.

PS. Come to think of it, should not central bankers even recuse themselves when it comes to bank regulations?

PS. Truly, FT's lack of curiosity amazes me

PS. Sir, click if you want an aide mémoire on the mistakes

@PerKurowski

Can journalists wash their hands about the (dis)empowering of citizens and of keeping failed elite in power?

Sir, Gillian Tett referring to “how the global elite converged on Davos this week” writes: “The most interesting issue revolves around something the WEF calls the “(dis)empowered citizen”. This arises because the internet makes voters feel more powerful than ever… The bitter irony is that although the internet gives people the impression they have a voice, in most countries power remains firmly with the elite.”, “The big illusion of empowerment for the masses”, January 22.

Tett holds “This creates disappointment and frustration: ordinary people have the illusion they are vocal. But although they use their mobile phones to exercise power over some issues, they cannot easily use them to change important issues such as politics.”

But, do journalists have no role to play in that? Are they not suppose to in many ways represent ordinary people in front of the elites?

For instance I do not call the Financial Times on the mobile phone (except perhaps when I will travel and suspend my subscription for a week or so) but I have sent thousand of letters to FT, including to Ms. Tett on issues like the following:

Four very important central bankers in Europe; ECB’s Mario Draghi and BoE’s Mark Carney, former and current chairs of the Financial Stability Board; BIS’ Jaime Caruana and Sveriges Riksbank Stefan Ingves, former and current chair of the Basel Committee for Banking Supervision, with their approval of risk-weighted capital requirements for banks, believe that ‘highly speculative’ below BB- rated assets are far more dangerous to the bank system than ‘prime’ AAA rated assets.

Since ex ante perceived ‘highly speculative’ below BB- rated assets have never ever set of a major bank crisis, as these have always resulted from excessive exposure to something ex ante deemed as safe but that ex post turned out very risky; that should raise some very serious questions about the risk management capabilities of those four highly empowered technocrats.

But, would Ms. Gillian Tett raise such question when meeting them? I don’t think so but, if she has, and has not reported back on the answers, to me or to you Sir, then she is just much more complicit in the cover up of the elite’s blunders than I thought possible.

@PerKurowski ©

Europe’ banks are in hand of regulators and central bankers who prefer dreaming about the safer past than a riskier future.

Sir Mark Mazower writes: “I was going to write — “critics and supporters of the European dream”. But there is no dream any longer and that is in some ways the biggest problem of all.” “Fresh ideas and lessons from the past are key to Europe’s survival” January 22.

A dream could be about a better future or about conserving a better past. Europe’s bank regulators, with their credit risk weighted capital requirements, which allow banks to earn much higher risk adjusted returns on equity when refinancing the safer past, than when financing the riskier future, clearly evidence what they dream about… poor Europe’s youth.

Let me refer to four extremely important European central bankers: ECB’s Mario Draghi and BoE’s Mark Carney, former and current chairs of the Financial Stability Board; BIS’ Jaime Caruana and Sveriges Riksbank Stefan Ingves, former and current chairs of the Basel Committee for Banking Supervision

All these gentlemen fully support credit risk weighted capital requirements for banks, which de facto means they believe that ex ante perceived ‘highly speculative’ below BB- rated assets, are far more dangerous to the bank system than ‘prime’ AAA rated assets. Europe, if that’s not scary, what is?

@PerKurowski ©

Yes! Central banks must be made accountable

Sir, Alex J Pollock, of American Enterprise Institute in Washington, asks that “Central banks must be made accountable”, November 13.

Absolutely! I totally agree: “there is zero evidence that these central bankers have superior knowledge, obvious that they have no superior insight into the future, and dubious that they command superior virtue.”

Anyone thinking that by distorting the allocation of bank credit in favor of those perceived as ex ante as safe, and which discriminates against the fair access to bank credit of those perceived as risky, will make the bank system safer, has not the slightest idea about what he is doing.

Not only are bank crises always the result of excessive exposures to what is perceived as safe but turn out to be risky; but also the strength of the real economy is a direct function of banks lending intelligently to those perceived as risky, like to its SMEs and entrepreneurs.

Let me just name some of these failed regulators that should be held accountable: Jaime Caruana, Mario Draghi, Stefan Ingves, Alan Greenspan, Ben Bernanke and Mark Carney.

@PerKurowski ©

Utterly failed but yet promoted bank regulators, evidence the mother of all lack of accountabilities.

Sir, Robert Jenkins holds that “For the good of his own reputation as well as that of his institutions and British banking, Mr Flint should go”, “How the HSBC chairman can restore accountability at his bank” March 11.

Agree, but so should also all regulators who had anything to do with those failed and outright stupid regulations which caused the current crisis, and which keep on dangerously distorting the allocation of bank credit to the real economy.

These regulators were so dumb that, instead of looking at whether bankers were perceiving credit risks correctly or not, and at how they were managing those perceived risks, they decided to look at the same risk bankers were perceiving in order to set their equity requirements for banks. And, obviously, clearing for the same perceptions a second time, distorted all common sense out of the allocation of bank credit… and caused banks to create excessive and dangerous exposures to the AAArisktocracy.

The Jaime Caruana, Mario Draghi and Mark Carneys of the bank regulatory world, instead of being sent home in shame after the Basel II flop, were promoted and some of them even instructed to proceed with elaborating Basel III.

As a result they still do not even acknowledge their mistake

Talk about lack of accountability!

@PerKurowski

A “lack of accountability” worthy of the Guinness Book of Records

Sir, Louis Brennan refers to Peter Doyle's letter highlighting the “unprecedented scale” of the IMF’s forecasting error in relation to its 2010 programme for Greece, in order to argue for “reform of institutions such as the IMF and the ECBm so that an ethos of transparency and accountability obtains in their operations and decision-making.”

Though forecasting errors are usually seen in the rear window, and though IMF sits in the uncomfortable position of at times influencing so much so as to make their forecasts come true, damn if you’re right, damn if you’re wrong, no one can deny Brennan has a valid point.

But, in terms of lack of accountability, that is really peccata minuta when compared to that of the Basel Committee’s. Let me just describe it this way. Neither Hollywood nor Bollywood would ever dream of placing the responsibility for the production of a Basel III, in the same hands of those who produced that incredible box-office flop that was Basel II.

But there they are, with some of their players, like Mario Draghi and Jaime Caruana, having even promoted. It should apply to the Guinness book of records.

PS. In the case of IMF, and as it there had a much more active role, I regard Argentina as a much worse mistake than Greece

FT, for the time being, forget the unaccountable bankers… we’ve got a much bigger problem at hands.

Sir I refer to your “Hold Britain’s banks to higher standards: New rules on personal accountability are tough but necessary” October 9.

In it you write: “The regime also brings in a new criminal offence of reckless misconduct that causes a financial institution to fail. This would carry a sentence of seven years’ imprisonment and an unlimited fine”,

And then you state: “Those grumbling about perverse regulation should acquire some perspective. Blowing up the nation’s physical infrastructure would carry the severest penalties. Recklessly damaging its financial plumbing can be just as damaging, but has been punishable at most by social opprobrium and a moderation of compensation from previously outlandish highs. No top banker has been punished for the enormous losses that caused the crisis.”

But, as you very well know, I hold bank regulators as the prime responsible for the crisis, having approved incredibly distorting credit-risk weighted capital (equity) requirements which they did not and have yet not been able to understand. And so, if I am right, is not the regulators lack of accountability so much worse? If I am right, and a banker responsible for a failed bank should get seven years... how many years in prison do these failed regulators deserve?

And FT, dare look at it… don’t turn away cowardly. The unrepentant chairman of the Basel Committee when Basel II was approved, is now the General Manager of the International Bank of Settlement; the unrepentant former chairman of the Financial Stability Board, is now the President of the European Central Bank; the current unrepentant chairman of the Financial Stability Board is also Governor of the Bank of England; and the clearly unrepentant current chairman of the Basel Committee is also the Governor of the Swedish Riksbank.

And FT don’t tell me you are unaware that there is a 100 percent correlation between what got banks in trouble and what these regulators allowed the banks to hold against extremely little equity… only because they perceived these assets, ex ante, as “absolutely safe”, and because of their hubris they never doubted their perceptions.

And FT, don’t tell me you are unaware of that secular stagnation, deflation, mediocre economy and all similar creatures, are direct descendants of that silly risk aversion displayed by our unaccountable to anyone failed bank regulators.

So FT, forget the bankers… if only for the time being... we got a much bigger and serious problem at hands.

Do I feel these bank regulators should be jailed? Of course not! I just feel they should go home, in shame, put on their dunce cap, and then beg the forgiveness of all those young who because of them will now become part of a lost generation.

PS. And, by the way, when journalists and columnists of an important paper withhold important arguments only because they do not like the messenger, or the messenger does not stroke their ego sufficiently, does that have no implications when it comes to personal accountability?

Luke Johnson. Who would be your favorite contender for the title of the mother of all start-up slayers?

Sir I would not argue one iota with Luke Johnson’s “Contenders for patron saint of start-ups” July 30.

That said it would be interesting to see who he opines is the number one contender for start-ups' slayer?

Clearly it has to be one prominent bank regulators, like Mario Draghi, Stefan Ingves, Mark Carney, Jaime Caruana or any other of those who concocted the venom against star-ups we know as the risk weighted capital requirements for banks.

Because of that the start-ups, usually perceived as “risky”, relatively to those perceived as “safe”, now have to pay even higher interest rates, get even smaller bank loans and have to accept even harsher terms than they used to.

And sadly the only result of that mumbo-jumbo regulation is that now our banks run the risks of too much exposure to what seems absolutely safe, while renouncing to the benefits of diversifying when lending to those who seems risky.

There is Sir, as you surely must understand, no future in such silly risk-aversion!

Why does Martin Wolf keep mum about the horrendous mistakes with risk-weighted capital requirements for banks?

Sir, until about two years ago I had written way over a hundred letters to Martin Wolf where I explained the profound mistakes of the risk-weighted capital requirements for banks present in Basel II. At that point he told me, in no uncertain terms, not to explain it to him anymore since he already understood it. And since that time, as you know, I have not copied Wolf with the letters I have been sending to you commenting on his articles.

But still, week after week, like in his “Bad advice from Basel’s Jeremiah” July 2, Wolf steadfastly refuses to discuss the possibility, I would say the certainty, that these capital requirements seriously distorts all monetary and fiscal policies enacted to ease the consequences of the financial crisis, rendering these useless.

And so Sir, I have to either conclude that Martin Wolf has not understood one iota of what I explained to him, something which might be entirely my fault, or he has some other reasons for keeping mum about it.

PS. Again I will not copy Martin Wolf with this letter. You decide Sir what to do.

Sometimes it is very hard to collect the money you win betting on where your mouth is

Sir, I refer to Tim Harford’s “Money where your mouth is” June 21. Suppose I had place money where my mouth was with the following:

“We have bank regulations that though requiring banks to hold 8 percent in capital when lending to businesses without credit ratings, allow banks to hold only 1.6 percent capital when lending to someone who has ex ante an AAA rating. And so I bet $1.000 on that, within the next decade, banks will lend much too much to some borrower ex ante rated as absolutely safe, but who ex post turns out to be very risky… and that this, aggravated by the fact that for that against that exposure banks had to hold little capital, will result in a major bank crisis.”

What would you had said about a bank regulator betting against me? And, if he had done so, would the current crisis not mean that I had won the bet, long before the decade ran out? But tell me…how would I collect my winnings?

I say this because banks regulators actually bet the whole banking system against my theoretical proposition, and I have not seen anyone paying up! On the contrary they have mostly been promoted. Like Mario Draghi, the former Chair of the Financial Stability Board, promoted to President of the European Central Bank. Like Jaime Caruana, the former chairman of the Basel Committee on Banking Supervision, promoted to General Manager of Bank for International Settlements.

Yes Tim Harford, “a world full of confident forecasts that nobody [including FT] never bothers to verify… is intolerable”. And so I would agree that “the world needs more wagers between pundits” but, before we start the betting, let us be sure there is a decent clearing house where these debts could be settled.

Mr Caruana and his fellow regulators deserve months of humbling community service and being banned for life from any regulatory activity.

Sir when a previous member of the Basel Committee like Mr. Jaime Caruana says “Basel II is evolving” and was not a contributory factor to the crisis, and that “You don’t see a correlation with the adoption of Basel II and the difficulties” as is reported by Patrick Jenkins in FT on September 21, this is indeed an insult to our intelligence and to humanity.

Mr. Caruana is well aware that when the Basel Committee demanded from the banks a capital requirement of only 1.6 percent, which is equivalent to authorizing a leverage of 62.5 to 1, when the banks were involved with a client or a security rated AAA by the credit rating agencies, they set off a world-wide race in search of the AAAs; and which, over just a couple of years, led trillions of dollars over the precipice of the subprime mortgages in the US, and created misery for hundreds of millions of people all over the world.

The least Mr Caruana and his fellow regulators deserve, is six months of a very humbling community service and, of course, being banned for life from any regulatory activity.