Europe, if you spoil your kids too much they will not grow strong. That goes for banks too.

Sir, Patrick Jenkins analyzes several concerns expressed about European banks when policymakers gathered to mark the retirement of Danièle Nouy from ECB’s Single Supervisory Mechanism (SSM); who is to be succeeded by Andrea Enria as the Eurozone’s chief banking regulator. “As European banks regulator retires, six big challenges remain” December 11.

The former Grand-Chair of the Federal Reserve, Paul Volcker, in his recent book “Keeping at it”, co-written with Christine Harper, recounts the following when, in 1986, the G10 central banking group tried to establish an international consensus on bank regulations and capital requirements:

“The US practice had been to asses capital adequacy by using a simple “leverage ratio”-in other words, the bank’s total assets based compared with the margin of capital available to absorb any losses on those assets. (Historically, before, the 1931 banking collapse, a ten percent ratio was considered normal)

The Europeans, as a group, firmly insisted upon a “risk-based” approach, seemingly more sophisticated because it calculated assets based on how risky they seemed to be. They felt it was common sense that certain kind of assets –certainly including domestic government bonds but also home mortgages and other sovereign debt- shouldn’t require much if any capital. Commercial loans, by contrast, would have strict and high capital requirements, whatever the credit rating might be.”

Sir, even though the Basel Accord was signed in 1988 and further developed in 2004 with Basel II, and with which the European risk weighting was adopted, I am sure we can trace the differences between US and Europe banks to these original differences on capital requirements. The US has been much more strict on capital than Europe. In fact the problems with American banks during the 2008 crisis were mostly restricted to those investment banks, which supervised by the SEC, had been allowed in 2004 to adopt Basel II criteria.

In Europe meanwhile banks could do with much less capital, which meant that much more was left over for bankers’ bonuses. In essence, Europe’s banks were dangerously spoiled. The challenge these now faces is having to substitute their equity minimizing financial engineers with good old time loan officers; and convince the capital markets of that. Good luck!

@PerKurowski

Are identified non-performing loans truly riskier to bank systems than those many still out there waiting to be identified as such?

Sir, Arthur Beesley reports that “ECB’s Single Supervisory Mechanism, a watchdog created in 2014 to oversee eurozone banks, is pressing Irish lenders to achieve a 5 per cent NPL ratio in line with European norms”,“Irish banks step up efforts to shed bad debts” August 22.

Of course it is in general terms good when banks clean up their balance sheets but, I must ask: Why should identified non-performing loans be more risky to a country’s financial stability than those loans that could be about to be identified as such?

“A 5 per cent NPL ratio in line with European norms” That sounds precisely like what deskbound regulators might invent in order to show everyone they’re working hard. How much better would it not be for all if these regulators took some time off in order to take a course on the meaning of conditional probabilities; I mean so that could move away from that simpleton idea of risk weighting the capital requirement for banks based on the risks that are perceived.

“There’s a very healthy demand for loan assets on Irish property,” said Owen Callan, equity analyst at Investec in Dublin…[so] it’s not a bad opportunity to get rid of some of these loans in what is a very strong market.”

Great! But if that was not the case, should Irish banks anyhow have to obey regulators sitting in Fankfurt am Main inventing general rules that should apply to all European banks, independent of their particular realities… like they did when they assigned a 0% risk weight to Greece?

Sir, I would never have voted for Brexit but, each day that goes by and I see how EU authorities do not confront the real EU challenges; like how to handle the absence of a foreign exchange adjustment mechanism lost with the Euro; and instead promote themselves with all type of small issues that are better handled by local authorities, I get the feeling it might have not been such a crazy vote.

@PerKurowski

For transparency, all candidates to chair ECB’s Single Supervisory Mechanism, should publicly answer one question.

Sir, I refer to Claire Jones and Rachel Sanderson reporting on the selection by the European Central Bank, of the person to substitute for Danièle Nouy as the chair of the Single Supervisory Mechanism. “ECB banking watchdog seeks new chief” July 17.

A major turning point for our Western world liberal order, in truth for our whole civilization, was when regulators, surprisingly, 1988, with no one questioning them, decided that what is perceived as risky is more dangerous to our bank system than what is perceived as safe, and proceeded to apply such nonsense with their risk weighted capital requirements for banks.

We have already paid dearly for their stupidity, which excessively boosted bank exposures to AAA rated securities, house mortgages and sovereigns (like Greece), and has made it harder for SMEs and entrepreneurs to access bank credit.

Therefore, in the name of that transparency we all deserve, which of course includes all at the Financial Times, all candidates to chair ECB’s Single Supervisory Mechanism should give their public and reasoned answer to the following question: 

What is more dangerous to our bank system, that which is perceived as risky, or that which is perceived as safe?

Will those involved in the selection process, and who might clearly have a vested interest in it remaining a question that shall not be asked, dare to ask it?

Here an aide memoire on the major mistakes of the RWCR

@PerKurowski

How can you not doubt bank regulators who believe that what’s perceived as safe is safe to the banking system?

Or the title could alternatively be: “How can you not doubt bank regulators who believe that what’s perceived as risky is what is really risky to the banking system?

Sir, Claire Jones and Jim Brunsden report that “doubt still surrounds whether the new Frankfurt-based body, the Single Supervisory Mechanism, has done enough to tackle persistent failings in parts of the region’s banking sector” “Doubts grow over Eurozone banking supervisor’s performance” March 23.

I ask how can a “Single Supervisory Mechanism” be expected to perform its duties when they have to face the reality of banks being ruled by absolutely in-operant regulations, which they presumably cannot or dare not criticize openly?

http://subprimeregulations.blogspot.com/2016/12/must-one-go-on-hunger-strike-to-have.html

Per Kurowski

Daniėle Nouy, new chair of Single Supervisory Mechanism, should hear out those like me who detest current bank regulations.

Sir, I refer to Sam Fleming´s, Alice Ross’s and Claire Jones’s “ECB Super>regulator prepares to be unpopular” February 10.

Of course, as you know from my more than a thousand letters, I much welcome that Daniėle Nouy “As one of the regulators who presided over the setting up of the Basel II accord on bank capital, which stressed risk-weighted assets as the best measure of a lender’s health… now admits her thinking on how banks are assessed has evolved… and now [at least] believes the leverage ratio¸ which compares a bank’s capital with its entire assets, is also a crucial measure.”

And of course, having held that bank regulators should be faster on the trigger, so that adequate pruning was done, I also fully agree with her opinion of “Let weak banks fail”, as reported on the front page by the same reporters.

But, when Ms Nouy there holds that “One of the biggest lessons of the current crisis is that there is no risk-free assets so sovereign assets are not risk free”, I just can’t refrain from asking, why on earth did it take the current crisis to find out that, when history is so full of examples? Sincerely it is hard to believe that regulators were so naïve to believe that… so one has at least the right to suspect some other motivation.

And also, when Ms Nouy speaks about the “health check” of banks “which will include an asset quality review and stress test”, I get the feeling she has not fully realized the Basel Mistake, in the sense of the worst not being what is on the banks’ books, but what is NOT there, like all the loans to the “risky” medium and small businesses, entrepreneurs and start-ups, which were never made, only because of discriminating risk-weighted capital requirements.

I would dare Ms Nouy to sit down one hour with me to give her a piece of my mind on what wrongs the Basel Committee has made, primarily letting expected losses stand in for unexpected losses, and then on what I believe should be done. And she should not be nervous about that, since I absolutely share all her concerns about “it’s not the best moment in the middle of the crisis to change the rules”… though surely transitioning has to be initiated… without making it worse.