Indeed, reforming the credit rating market is an urgent necessity. Indeed, shame on the regulators

Sir, Arturo Cifuentes concludes, “Reforming the credit rating market is an urgent necessity. Shame on the regulators” “Few lessons have been heeded 10 years after Lehman collapse” August 23.

Yes shame on the regulators! But also for some other reasons than those Cifuentes mentions.

Just for a starter, the credit rating agencies would never ever have caused so much damage had their opinions not been leveraged immensely by the risk weighted capital requirements for banks. Imagine, Basel II, 2004, allowed banks to leverage 62.5 times if only a human fallible credit rating agency assigned an asset an AAA rating. 

It should have been crystal clear that with that the regulators were introducing a huge systemic risk in the banking sector. That I mentioned for instance in a letter published by FT in January 2003; and I loudly explained and protested it while an Executive Director in the World Bank during those Basel II preparation days.

In Europe, the EU authorities even overrode the credit rating agencies opinions and assigned Greece a 0% risk weight, which of course doomed it to its current tragic condition. 

Then, let us mention the mother of all regulatory mistakes; for their risk weighted bank capital requirements, initiated in 1988 with Basel I, the regulators used the perceived risk of assets instead of the risks of those assets conditioned on how their risks are perceived? How loony, how sad, what a distortion, what a recipe for disaster was not that? And still, 30 years later, they do not even acknowledge their mistake.

By the way, when Cifuentes denounces that Solvency II, with its myopic risk view, will discourage insurance companies, the natural holders of illiquid assets, to hold these investments, and it will therefore increase the systemic risk by making their portfolios less diversified, I could not agree more.

Sir, you know that for over more than a decade I have written to Financial Times 2.787 letters objecting to the “subprime banking regulations”, this one not included. Galileo could indeed be accused for being obsessed with his theories, but, could those doing their utmost to silence his objections, the inquisitors, not be accused of the same?

PS. Cifuentes mentions “Olivier Blanchard’s 2016 admission that incorporating the financial sector in macro models would be a good idea”, I might have had something to do with that.

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

@PerKurowski

Why do regulators insist in realizing bankers and insurers wet dreams? It costs the real economy too much!

Solvency II does to the insurance industry what Basel regulations did to banks. It introduces what is known as the “risk-based approach” to capital and regulation.

In essence it means more ex ante perceived risk more capital, less ex ante perceived risk less capital.

That translate into the lesser the ex ante risk is perceived, the more you will be able to leverage your capital.

And the more you are allowed to leverage capital, the higher are the expected risk adjusted returns on equity.

And so, just like it realized the banker's wet dreams (more elegant "nocturnal emissions") Solvency II should now realize those of the insurers… namely that of being allowed to earn the highest risk adjusted returns on equity on what is perceived as the safest.

Evidence of the existing enthusiasm we find when Oliver Ralph quotes Omar Ripon, partner at accountants Moore Stephens with “Risk-based capital is a great thing. The best firms are looking at using it to improve their returns. If you only look at it from the compliance angle, you won’t get the benefits.” “Insurance divides over shared rules” March 14.

Unfortunately allowing bankers and insurers to realize their wet dreams has a very high cost for all the rest of us.

First it obviously distort a lot in the financial markets in terms of how credit, investments and capital is allocated.

When the European Commission explains why Solvency II is needed they hold that Solvency I “does not entail an optimal allocation of capital, i.e. an allocation which is efficient in terms of risk and return for shareholders”

But that is certainly what the risk based capital approach cannot do.

That is because all risks that are considered by the capital requirements are risks that have already been perceived and cleared for in other ways, by means of risk premiums, amounts of exposure and other.

And any risk, even if perfectly perceived, if it is excessively considered, causes the wrong action.

And then of course “hiding risks” or production of Potemkin ratings, which allows for higher leverages, becomes a competitive tool.

“Any risk you hide I can hide better, I can hide better the risks than you can… No, you can't - Yes, I can - No, you can't Yes, I can! Yes, I can!”

And if the distortions in capital allocation to banks and insurance are bad, the distortion it produces among those who access bank credit or insurance investment funds from the insurance companies is much worse. It will mean the “safe” will get too much, much more than what they already get (making them risky) and that the “risky” will get too little, much less than what they already get… and as a consequence our real economy will suffer a lot.

I know too little of the insura © nce industry to estimate their capital requirements but, in the case of banks, these should be required to hold 10 percent in capital against all assets to cover for the unexpected, which, even though it can be expected, includes such events as regulators having no idea of what they are doing.

PS. I challenge you to read the European Commission’s explanations of Solvency II and count the self confessed distortions it will produce.

@PerKurowski

Insurance sector: Again loony regulators are trying to cover for unexpected losses by analyzing the expected ones.

Sir, I refer to Alistair Gray’s report on “the capital [insurance companies] must hold against unexpected losses” “Insurers face tough new safety rules” October 5.

In it Gray writes: “A paper to be published quantifies the higher capital requirements for the designated insurers. The size of the hit will depend on each company’s mix of business and how systemically important regulators deem them to be. So-called non-traditional and non-insurance (NTNI) activities carry the largest surcharges, of between 12 per cent and 25 per cent.”

So again we have regulators, like those of banks, who set capital requirements for unexpected losses based on the expected risks they perceive. Loony! Do regulators really think they can perceive risks better than the insurance companies? Is there not a huge risk that both the insurance companies and the regulators will perceive the same risks, and so that there therefore will be an overreaction to these risks, which obviously means a sub-consideration of other risks? And boy, are these regulations just screaming to be gamed?

Also, at a moment that so many want infrastructure projects to be started as a way of reactivating the economy, who of the regulators is thinking about the fact that many of the risky long term projects, often financed by insurance companies… could perhaps not happen only because of wrong and distorting capital requirements.

Where have all humble regulators that know of the importance of not interfering gone? When will they ever learn, when will they ever learn?

Why do they in order to cover for unexpected losses not just set for instance a 10% capital requirement on all assets? Are they scared they would then look like less sophisticated regulators to the general public? If so, God save us from regulators suffering an inferiority complex.

@PerKurowski ©

Insurance: Is anyone looking at how Solvency II might affect investments in the real economy and the premiums to pay?

Sir, Alistair Gray writes about how investors in the insurance industry are struggling to assess the impact as European regulators finalize details of Solvency II regime, “Insurers face crunch over new capital rules” September 1.

Is anyone looking at how Solvency II might affect the investments of the insurance companies in the real economy?

Is anyone looking at how Solvency II might affect premiums for covering different risks?

The answer to both those question is most probably a “NO!” That because regulators molded in credit-risk weighting traditions, clearly do not care one iota about such minutia.

So what could the consequences of Solvency II then be for other than the investors?

First, it will certainly create incentives for insurance companies to hold more of safe “infallible assets”, and so there will be additional demand for sovereign debt and less demand for riskier assets… like long term investments in infrastructure projects. And so the safe havens will be further dangerously overpopulated and the riskier but perhaps worthier bays even more underexplored.

As for the insurance clients let me speculate over what it could imply in terms similar to those applied by the Basel Committee to banks. For instance when selling health insurance to smokers and non-smokers.

Traditionally insurers looked at actuarial risks of smokers and non-smokers in order to decide on the premiums to charge and the exposures to accept, and that was it. But, now, it could be that since regulators believe the smokers are “riskier” than the non-smokers, Solvency II could have in mind using the same actuarial studies in order to set higher capital requirements for insuring smokers than insuring non-smokers. That would of course mean that the spread in premiums paid by these two groups would increase… and drive up any inequalities.

@PerKurowski

God help our grandchildren if our insurance sector, like our banks also fall into the hands of a Sissy Brigade.

Sir, You hold that “Global insurers should be supervised at scale”, May 4. One reason for why you think that should be, is “the pivotal role of American International Group in the 2008 financial crisis. AIG… was belatedly found to have an insolvent derivatives trading unit, heavily intertwined with large banks and investment banks.”

That’s correct, but the real cause for that excessive intertwinement was that since AIG was AAA rated, if it assumed the risk of a bank asset, then according to Basel II, banks could leverage their equity with that exposure more than 60 to 1. What a temptation! So in fact it was the regulators’ own dumb risk-aversion that caused AIGs problems.

I find it amazing that the world has allowed itself to fall into hands of a shortsighted bank regulator who thinks that banks can remain safe by avoiding to take the risks needed to adequately take care of the real economies’ financing needs.

With its credit-risk weighted equity requirements, those which allow banks to earn higher risk adjusted returns on equity when financing what is perceived as safe, than when financing what is perceived as risky, the Basel Committee (and the Financial Stability Board) has completely distorted the allocation of bank credit to the real economy.

And now another risk-aversion centered Sissy Brigade, the EU with its Solvency II, is also in pursuit of the insurance sector, which will make sure its investments will be completely distorted too. And FT, tough not explicitly in this editorial, even seems to be egging them on. God help us. God especially help our children and our grandchildren, those most in need of banks taking risks, with reasoned audacity.

@PerKurowski

Senator Richard Shelby. Ask Fed and FDIC, why Alabama’s borrowers are denied a fair access to bank credit.

Sir, I refer to Barney Jopson and Caroline Brinham’s “Republican resist global insurance role”, April 29.

Richard Shelby, chairman of the Senate banking committee is quoted with: “An international regulatory regime should not dictate how US regulators supervise American or US based companies”.

It is a quite relevant opinion, but Senator Shelby should start by asking the Fed and the FDIC the following:

Why on earth are Alabama’s state-chartered banks allowed to lend to well-rated corporations elsewhere, or to sovereign governments, holding less equity than when lending to their own local SMEs and entrepreneurs?

Does that not enable sovereign governments and members of the AAArisktocracy to generate higher risk adjusted returns on bank equity than what Alabama’s borrowers can do?

Does that not mean that Alabama’s borrowers are refused fair access to the credits of their Alabama banks?

Senator Richard Shelby faces a hugely important challenge. But he should know that challenge extends way beyond the insurance sector and the Financial Stability Board. He should start with banking, and with the Basel Committee, that committee that so much influences US bank regulations, but that is not even mentioned once in the over 800 pages of the Dodd-Frank Act.

@PerKurowski

Any regulator that would call what is currently happening an unexpected consequence is clearly not fit to regulate.

Sir, I refer to Stephen Foley’s “BlackRock chief warns ripple effect of strong dollar threatens US growth” April 7.

It states that Larry Fink, CEO of BlackRock “highlights the risk that monetary easing has inflated asset bubbles as investors such as pension funds searching for yield in a low interest environment are pushed into riskier classes”. And it quotes Mr Fink with: “This mix of growing assets and shrinking yields is creating a dangerous imbalance”. I am left wondering whether Mr. Fink really knows what is going on.

Does he know that one reason for why pension funds “are pushed into riskier classes”, is that they are pushed out from the perceived safe havens by bankers pushed into safer classes by their regulators with their silly and dangerous credit risk weighted equity requirements for banks? And that is just going to get worse the tighter bank equity gets to be, and when insurance companies also regulated with Solvency II in a similar way?

Indeed, “monetary policy seem insufficiently attuned to the conundrums their actions are creating for investors” But regulators are equally attuned to the conundrums their actions are creating for the fair access to bank credit of “the risky”, like for all the SMEs and entrepreneurs we need to get going when the going is tough.

And regulators please do not call all this an unexpected consequence. If you do it just evidences even more that you are definitely not fit to regulate.

@PerKurowski

Our economies are drowning for lack of oxygen in overpopulated safe havens.

Sir, I refer to John Dizard’s “Central banks enlist ageing populations in the competitive devaluation game”, March 28.

Dizard discusses Bank of Japan’s paper “Demographic Changes and Macroeconomic Performance — Japanese Experiences”; IMF’s “Is Japan’s Population Aging Deflationary?” and a paper by BIS titled “Can Demography Affect Inflation and Monetary Policy?”

One aspect not discussed in connection to this demographic change, is that since increased risk-aversion goes with the investment objectives of an aging population, the demand for safe havens relative to risky bays should be increasing.

Add to that the sad fact that bank regulators decided, on their own, that it was more important for our banks to avoid risks instead of to allocate bank credit to efficiently to the real needs of the economy, that of course also adds immensely to the demand for safe havens.

And it is only getting worse. Now by means of added Basel III liquidity requirements for banks, and Solvency II regulations for the insurance sector, which all-predicates risk-aversion, the demand for what’s “safe” must grow even more.

And, since any safe haven can become extremely dangerous if overly populated, it should be clear that an amazing scarcity of financial safety is lurching around the corner. Poor widows and orphans financially they will be more widowed and orphaned than ever.

But also poor the coming young generations, those who will be denied that societal risk-taking that could help them to have a good future with plenty of jobs.

@PerKurowski

The most urgent financial sector reform in Europe is getting rid of its dangerous credit-risk-adverse bank regulations

Sir, Wolfgang Münchau describes the immense problems low interest rates cause the pension fund industry, and we can only hope that is no news to those supporting low interest rates “Real danger lies in Mitteleuropa’s financial sector” March 9.

But then Münchau states: “Low interest rates are, of course, not the cause of this slow moving wreck. The cause is, of course, the train” and goes on to proclaim: “If there is anything in Europe that requires urgent reform, it is not the Greek product market, but the German and Austrian financial sector… if Germany continues with its policy of forcing a deflationary adjustment in the eurozone and running large saving surpluses with an unreformed financial sector at home, we should prepare for the next big financial crisis”.

I am curious, what financial sector reform does Münchau refer to? Is he not aligned with Basel III?

Sir, for more than a decade I have known for sure that what no economy can afford, in order to remain sturdy, is someone giving its banks special incentives to lend to those perceived as safe and to stay away from those perceived as risky; something which the Basel Committee has foolishly done by means of credit-risk weighted equity requirements.

For reasons that escape me, Münchau and most other at FT have decided to ignore that argument.

So if there is one urgent financial sector reform pending in Europe (and other places) that is getting rid of current bank regulators and their senseless aversion of credit risk.

But sadly it just looks only to get worse as its insurance sector is now also being threatened with similar mistaken regulations, Solvency II.

And why did FT mostly ignore also this for about a decade?

Sir, what Mr. Robin Monro-Davies tells you in his letter “Making Basel III look like a doodle” September 8, is what I have been telling you for about a decade and which you basically, for reasons I cannot understand, decided to ignore. 

I greeted regulators during a workshop at the World Bank on Basel II in May 2003 with a “I congratulate you, we can already begin to see how Basel II is forcing bank regulators to make a real professional quantum leap. As I see it, you will have a lot of homework in the next years, brushing up on your calculus—almost a career change.” 

And I have also often warned about “Solvency II” taking the “Basel II” route.

Are we to allow Solvency II do to our insurance companies what Basel II did to our banks?

Sir, Paul J Davies in “Capital rules raise fears over insurers’ risk appetite” April 20, though correct in so many aspects sadly makes precisely the same mistake that the Basel Committee did when they established their capital requirements for banks based on officially perceived risk. He says “The higher returns on risky assets ought to be diluted by a higher capital charge in perfect proportion. That ignores that the “higher return on risky assets” he sees is the result of the market already having looked at the same risk information available and adjusted their risk-premiums and interest rates correspondingly.

Is it not bad enough that Basel II drove our banks excessively into what was officially perceived as not risky assets, carrying no capital at all, to now have Solvency II doing the same of our insurance companies?

If Solvency II would be something like Basel II

Sir, in “EU reform plan alarms insurers” April 5, representatives of insurance companies express some reservations about the regulatory package known as Solvency II coming in force at the start of 2013... and I wonder whether some of the insured would have reasons to be concerned too.

I mean if Solvency II for the insurance companies follows the principles of the Basel II applied to banks, then the capital requirements for insurance companies for insuring those perceived as less healthy will be higher than those required when insuring those perceived as much healthier, independently from the fact that insurance companies already charge higher premiums to the first group.

Has anyone heard about some health rating agencies positioning themselves for business?

From Basel II into Solvency II… has the European Parliament lost it?

As reported by Nikki Tait and Paul J Davies, April 23, not only do the higher risks have to pay higher insurance rates because the market so demands it, but now they have to be additionally penalized in order to compensate for the higher capital requirements for higher risks that will be imposed on the European insurers by the European Parliament; as a result of something called “Solvency II” and which sounds and reads frightfully similar to Basel II.

Do they never learn? Now again, what will result from all this is increasing the incentives for disguising as being of lower-risks and for having the regulators go to sleep in the belief that all has been taken care of. Who is going to measure the risks? The insurance risk rating agencies? Start praying!