If regulators artificially favor the access to bank credit of “the safe” “the safe” will turn risky, more sooner than later.

Sir, Gillian Tett writes “post-crisis regulatory reforms have forced financial institutions to load up with “safe” assets, too, to be used as collateral for deals… The net result is a dire squeeze on safe assets” “What pawnbrokers can teach central banks” April 29.

That is correct but, what about pre-crisis regulations? These allowed banks to leverage much more their equity with “safe” assets; and thereby earn much higher expected risk adjusted returns on equity with “safe” assets than with “risky” assets; and which therefore caused banks to lend too load up on “safe” assets, something that can be very risky.

So if you do not allow markets to allocate credit unencumbered by regulations, but favor the banks to lend to the safe, “the safe” havens are doomed to turned into dangerously overpopulated havens, sooner or later. And from what Ms Tett writes it seems that the “sooner” applies.

@PerKurowski ©

The World Bank’s bias against banks taking risks hurts the poor they want to help.

Sir, I refer to Michael Holman’s “The World Bank fails to credit the intelligence of the world’s poor” January 27.

It discusses the results of a very much commendable study carried out by the World Bank, when trying to establish how the bias of its professionals’ might influence the assistance it provides.

Holman concludes: “The consequences of bias are profound. The poorest in the world may be doubly burdened. Not only do they fight a daily battle against poverty. They may well have to cope with policies of well-meaning aid donors that owe more to the bias of those who frame them, than to the knowledge of those who are supposed to benefit from them.”

Indeed, that happens. As an Executive Director of the World Bank 2002-2004, and also from all what I later read in many of its reports, I concluded that one of the most dangerous biases of the World Bank, is its bias towards risk aversion. That is reflected primarily by its inability to criticize those Basel Committee bank regulations that are based on credit-risk-weighted equity requirements.

It is truly ironically that the world’s premier development bank, which should be the first to understand that risk-taking is the oxygen of any development, keeps mum on regulations which allow banks to earn much higher risk adjusted returns on equity when financing what is perceived as safe, mostly the history, than what is perceived as “risky”, mostly the future.

That is mindboggling sad. Of course banks need to take risks, like lending to small businesses and entrepreneurs. You must allow the animal-spirit resources to work with. And that is why the society must lend some support to bank depositors, for when the risk-taken by a bank might become excessive.

To support banks instructed to avoid risks as much as possible, seems to me an exercise in futility that should have a chance to enter the Guinness book of records. 

PS. As an example, in April 2003, when discussing the World Bank’s Strategic Framework 2004-2006 at the Executive Board, I urged: “Basel dictates norms for the banking industry that might be of extreme importance for the world’s economic development. In Basel’s drive to impose more supervision and reduce vulnerabilities, there is a clear need for an external observer of stature to assure that there is an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth. Once again, the World Bank seems to be the only suitable existing organization to assume such a role."

The Fed’s regressive bank regulations, makes it a biased source of information

Sir, Tom Braithwaite’s writes that “stock and bond prices for the banks would be more accurate if [the market] knew what the Fed thought about the strength of these banks and their management”, “Smoke needs to clear over Fed supervision of US banking system”, November 17.

Indeed, that sounds extremely rational but, unfortunately, if the views of the Fed are biased, the signals it sends out will of course make it worse for the economy as a whole.

I say this because it is clear that the Fed agrees with regressive regulations which much favors bank lending to the infallible, in detriment of lending to the risky, and so opining based on such mistaken criteria cannot lead to anything good.

Just look at the “Camels” ratings that Braithwaite refers to and that many want to be disclosed. These cover “capital adequacy, asset quality, management, earnings, liquidity and sensitivity to market risk”; with no indicator for what is most important for the real economy, and thereby implicitly in the medium and long run is also vital for the banks, namely if the bank allocates credit efficiently to the real economy.

And so, even if in the land of the free and the home of the brave, the Fed would rate much higher a bank that exclusively lends to the sovereign and the AAAristocracy, than a bank that dares lending to “risky” citizens and their small businesses. And if that helps anyone, that might be those very elderly in want of short-term safety, and clearly not the young who need banks to take risks in order to have a future.

And what is really hard to understand is when Braithwaite refers to Jose Lopez, an economist at the Federal Reserve Bank of San Francisco, opining in 1999 that the disclosure of Fed’s Camels ratings “could benefit supervisors by improving the pricing of bank securities and increasing the efficiency of the market discipline brought to bear on banks”. Does the Fed need the market to reassure it by reaffirming the Fed’s own biases? Is it not doing enough damage as is?

If you account for perfect information twice, you are valuing it imperfectly

Sir, suppose you have perfect credit information… what should you use it for? To set the interest rates you will charge, or to set the capital reserve you should have? If you use that perfect information twice you are valuing it imperfectly. That is the fundamental flaw with the main pillar of the Basel Committee regulations. Because it makes for the same risk information to be accounted for twice, it introduced a totally unwarranted bias in favor of what is officially perceived as “not risky” against what is officially perceived as “risky”.

Unless someone orders that the same interest rate should apply to all borrowers, which I am of course not proposing, then the only valid conclusion is that we must have one sole capital requirement for all lending.

By the way this does not exclude the possibility that the banks need to report what exposure they have to the different official credit risk categories, so as to provide the market a better way to gauge the risk taking of the bank. What happened now, with risk-weighted capital ratios, was that the banks could take on much more risk than what the market (and the regulators) really saw.

Financial Times, if you do believe in small state and open markets, you are certainly not showing it.

Sir in your editorial of April 7, “The UK must look beyond the crisis” you state with some hubris “The Financial Times stands for a small state social justice and open markets”. Sincerely, if that’s so, you’re not showing it.

Current Basel regulations require a bank to have 8 percent in capital when lending to a small business or an entrepreneur but if lending to a government of a sovereign rated AAA to AA- the banks needs zero equity, and this with any lens used is a clear expression of an immense bias in favour of the state.

On November 18, 2004 you published a letter I wrote that said “We wonder how many Basel propositions it will take before they start realizing the damage they are doing by favoring so much bank lending to the public sector. In some developing countries, access to credit for the private sector is all but gone, and the banks are up to the hilt in public credits.”

But since that, and after almost some 100 letters more on the same issue; and after you must have seen sufficient evidence of how banks all over the world, and especially in Europe, loaded up on public debt, not once have I seen express your disgust over something that most clearly goes against “a small state and open markets”.

A regulatory bias that favours the big prevails

Sir Clive Crook recommends to “Strike faster on death-wish finance” March 23 and he is right though that would clearly require a dramatic reversal of the regulatory bias in favour of the big that now prevails.

In May 2003, at a workshop on risk management for some hundreds of financial regulators held at the World Bank, as an executive director, I said the following:

“A regulation that regulates less, but is more active and trigger-happy, and treats a bank failure as something normal, as it should be, could be a much more effective regulation. The avoidance of a crisis, by any means, might strangely lead us to the one and only bank, therefore setting us up for the mother of all moral hazards—just to proceed later to the mother of all bank crises. Knowing that “the larger they are, the harder they fall”, if I were regulator, I would be thinking about a progressive tax on size.”

And, as you might guess, that recommendation went unheeded and I would even dare say unwelcomed… unfortunately.