Regulators, please do no harm, you’ve done enough!

Sir Viral Acharya in “Why bankers must bear the risk of ‘too safe to fail´ assets” March 18, points out that “though AAA –rated tranches and repo financing are relatively safe, their entire risk is systemic in nature” and therefore [bank] regulations “should be more concerned about seemingly fail-safe assets… rather than worrying much about riskier assets”.

As you must have been able to gather from my many (unpublished) letters making the same argument I believe he is absolutely correct. My deepest concern though is how we all landed in the hands of bank regulators so naive as to believe that in a world of intrinsically coward capitals disaster looms where risk is perceived as high and not where the risks are perceived as low and therefore create conditions for stampedes towards safety and that could dangerously overcrowd even the ex-ante safest haven.

Again, for the umpteenth time, we need for our regulators to be fully aware that their regulations could be the source of the worst kind of systemic risk and, if they’re not, then we are much better off without any sort of regulation.

When selecting the regulators we must reduce the risk of a systemic fault or similarity in their thinking process. Now we have only single-minded gnome clones.

Without understanding the regulatory arbitrage one cannot get the real measure of the banks

Sir John Gapper in “Volcker has the measure of the banks”, January 28, quotes Viral Acharya, a professor at New York University’s Stern School, saying that “the crisis was caused by a ‘general underpricing of risk’ that led many banks into taking on more trading and investment risk to boost their returns”.

“Underpricing of risk”... by the banks? No! Who really underpriced risk were the regulators when they allowed the banks to hold less capital when “holding triple-A mortgage-related derivatives”, and which thereby artificially increased the returns of these assets. In other words the banks were receiving what they perceived as good returns only because of regulatory arbitrage.

I am truly amazed how, now soon two years into the crisis, some experts can still not see what some of us knew was going to happen, before the crisis happened. Without understanding the role regulatory arbitrage had in the crisis, forget about Volcker, Acharya, Gapper or anyone else getting a grip on any real measure of the banks.

Other financial reforms are much more needed than rebuilding of Glass-Steagall styled walls.

Sir “Obama’s bank plan is a start” by Viral Acharya and Matthew Richardson, January 22 though describing in much detail the “highly geared bet on credit, especially tied to securitised pools of residential non-prime mortgages” misses out so completely on putting forward the two main causes for the disaster that one almost become suspicious about the intentions.

First, the explosion of the “securitised pools of residential non-prime mortgages” happened because those securities achieved AAA ratings and what can be better than to sell long term high interest mortgages as AAA safe investments. A 30 year 11 percent mortgage of US$ 300.000 if sold to yield 6 percent is valued at US$ 510.000 providing a US$ 210.000 immediate profit.

Second, for the banks to hold these AAA rated securities on their books they had, courtesy of the regulators to put up only 1.6 percent in equity, compared with the 8 percent of equity required when lending to small businesses, entrepreneurs or ordinary citizens. No wonder that “When the market and liquidity risk materialised as a result of the collapse of housing prices, they had no capital cushion to bear it”

And what have those causes for the disaster have to do with “the lack of Glass-Steagall-style restrictions”? Almost nothing!

And now I can’t find the link to this article in FT!!!???

Here's another reference to that article, two days later.