“Risk Management”, yes, but for whom?

Any good financial investment advisor, depending on the age of his clients, would clearly give them different recommendations.

Sir, therefore, even when FT Special Report “Risk Management” specifies it is about “Financial Institutions”, full transparency would require it to clearly specify for whom.

The Basel Committee’s risk weighted bank capital/equity requirements too much favours what’s perceived (or decreed) as safe, e.g., public debt, residential mortgages and highly rated borrowers/securities, and too much fears what’s perceived riskier, e.g., loans to unrated small businesses and entrepreneurs. With that it is managing the risks of us older, like your journalists, than the risks of our children and grandchildren.

In reference to that holy intergenerational social contract he often spoke about, what would Edmund Burke opine about the Basel Committee?

Sir, Jesus Christ invited the Apostle to "put out into the deep" for a catch: "Duc in Altum" (Lk5:2) "When they had done this, they caught a great number of fish" (Lk5:6). The Basel Committee gave the banks of our Western world great incentives to fish from “safe” shores. And look where this has taken us.

PS. Not long ago I had a dialogue with ChatGPT on this issue.

https://perkurowski.blogspot.com/2024/09/ai-openai-chatgpt-as-grandfather-should.html

PS. And, of course, as you well know, this is not the first time that I have opined on the Basel Committee regulations, an issue that according to Martin Wolf I am obsessed with.

https://teawithft.blogspot.com/2009/10/please-free-us-from-imprudent-risk.html

Why does the world ignore regulations that totally disrupt the allocation of bank credit?

Sir, I refer to Martin Wolf’s “Shocks from war in Ukraine are many-sided. - The conflict is a multiplier of disruption in an already disrupted world” FT April 27.

The concentration of human fallible regulatory power in the Basel Committee has, since 1988, resulted in bank capital requirements mostly based on that what’s perceived as risky e.g., loans to small businesses and entrepreneurs, is more dangerous to our bank systems than what’s perceived or decreed as safe e.g., government debt and residential mortgages; and not on misperceived risks or unexpected events, like a pandemic or a war. 

What can go wrong? I tell you Sir.

When times are good and perceived risks low, these pro-cyclical capital requirements allow banks to hold little capital, pay big dividends & bonuses, do stock buybacks; and so, when times get rough, banks stand there naked, just when we need them the most.

And of course, meanwhile, these capital requirements, by much favoring the refinancing of the safer present over the financing of the riskier future, have much disrupted the allocation of credit

Why has the world for decades ignored this amazing regulatory mistake?

Sir, perhaps you could ask Martin Wolf to explain that to us.

PS. Two tweets today on bank regulators’ credit risk weighted bank capital requirements.

What kind of banks do we want?

Banks who allocate credit based on risk adjusted interest rates?

Or banks who allocate credit based on risk adjusted returns on the equity that besserwisser regulators have decreed should be held against that specific asset?

https://subprimeregulations.blogspot.com/2021/01/and-academia-kept-silence.html

Bank events' matrix

What’s perceived risky turns out safe

What’s perceived risky turns out risky

What’s perceived safe turns out safe

What’s perceived safe turns out risky

Which quadrangle is really dangerous?

Covered by current capital requirements?

NO!

https://youtu.be/TUdKhm6_a8Y

Bank regulators rigged capitalism in favor of the state and the “safer” present and against the “riskier” future.

Sir, Martin Wolf with respect to needed financial sector reforms mentions “Radical solution: raise the capital requirements of banking intermediaries substantially, while reducing prescriptive interventions; and, crucially, eliminate the tax-deductibility of interest, so putting debt finance on a par with equity.” “How to reform today’s rigged capitalism” December 4.

What has rigged capitalism the most during the last decades is the introduction of risk weighted bank capital requirements which rigs the allocation of credit in favor of the sovereign and that which is perceived, decreed or concocted as safe, and against the credit needed to finance the riskier future, like SMEs and entrepreneurs.

That distortion is no eliminated with general higher capital requirements like the leverage ratio introduced with Basel III, but only by totally eliminating the credit risk weighting.

Wolf expresses great concern “over the role of money in politics and way the media works” I agree. The reason why media in general, and FT in particular, have refused to denounce the stupidity with credit risk weighted bank capital requirements based on that what bankers perceive risky being more dangerous to our bank systems than what bankers perceive safe, is most probably not wanting to trample on bankers’ toes. As is, bankers are allowed to leverage the most; to earn the highest risk adjusted return on equity, on what they think safe. Is that not a bankers dream come true? As is, we are facing the dangerous overpopulation by banks of all safe havens, while the rest of us are then forced out to the risky oceans in search of any returns. 

“A ship in harbor is safe, but that is not what ships are for.” John A. Shedd.

http://teawithft.blogspot.com/2009/10/please-free-us-from-imprudent-risk.html

@PerKurowski

Three questions for Angus Deaton, the chair of The Institute for Fiscal Studies’ wide-ranging review of inequalities in UK

Sir, I refer to Angus Deaton’s “Inequality in America offers lessons for Britain” May 15.

I have three questions for him:

Regulatory subsidized credit for the purchase of houses, which has helped morph houses from being homes into investment assets, how much increased inequality has that caused between those who own houses and those who do not?

The increased benefits for those who have jobs, how much increased inequality has that caused when compared to those without jobs?

The risk weighted capital requirements for banks, which very much favors the financing of the “safer” present over the riskier future, how much inequality is it producing between current and future generations?

PS. Decreed inequality

@PerKurowski

If QE seems to have turned into irreversible and the economy even needs a QE4, does that not point to something not going right?

Sir, Michael Howell writes:“Modern financial systems have grown dependent on huge central bank balance sheets… our concern today is a growing shortage of central bank liquidity caused by the deliberate unwinding of the QE policies put in place to replace the private sector funding that evaporated in 2007-08” “Liquidity drain will force central banks towards ‘QE4’” February 20.

What does this mean? That ever growing central bank balance sheets are now to be a standard feature in our economy? If QEs is to replace private sector funding, are we not heading into central bank statism?

What has QEs achieved? Because of the risk weighted capital requirements, the liquidity injected has resulted in way too little financing of the “riskier” future (entrepreneurs) weakening the real economy; and too much to the “safer” present (mortgages, buybacks, AAA rated securities and public debt) creating bubbles.

If it comes down to a QE4 let’s pray regulators admit their mistake and throw out forever the idiotic risk weighting.

Idiotic? Yes, consider the following tail risks.

The best, that which perceived as very risky turning out to be very safe.

The worst, that which perceived as very safe turning out to be very risky.

And the risk weighted capital requirements for banks kills the best and puts the worst on steroids… dooming us to suffer an weakened economy as well as an especially severe bank crisis, resulting from especially large exposures, to what was especially perceived as safe, against especially little capital.

PS. Here is a current summary of why I know the risk weighted capital requirements for banks, is utter and dangerous nonsense.

@PerKurowski

If you want to fight short-termism, you have a better chance doing so by appointing teenagers instead of workers to the boards.

Sir, Prof Louis Brennan welcomes Senator Elizabeth Warren’s Accountable Capitalism Act proposal that “requires companies with more than £1bn in annual revenues” that which would require the largest corporations to allow workers to choose 40 percent of their board seats … “a welcome counterforce to the inherent logic in shareholder value that necessarily results in short-term decision-making”, “Humans will do things for which they are rewarded”, August 31.

In that respect I don’t understand why workers would be lesser humans and not so only do things for which they are rewarded. If you want to have a better chance for adding some long term views why not appoint some savvy teenagers to the board. They are the ones who have to live the longest with their decisions, and they are who probably are by means of social media those most held accountable to their peers.

If Senator Warren is really serious about fighting short termism, and is not only engaging in some redistribution profiteering, then she should be up in arms against the regulators’ risk weighted capital requirements for banks. These subsidize the access to bank credit of the safer present, and impose tariffs on the riskier future.

@PerKurowski

Bank regulators could derive valuable lessons from pension scheme difficulties.

Sir, Jonathan Ford while discussing Carillion’s pension schemes writes: “deficit repair should reasonably leave space for the company to foster future growth, and thus preserve the ongoing viability of the sponsor.” “Carillion’s pension crisis defies any magic legal cure” February 26.

Absolutely. But does that not apply to bank regulations too? As is the risk weighted capital requirements give banks huge incentives to stay away from financing the “riskier” future, like entrepreneurs, in order to refinance the safer present, like houses.

And Ford adds: The worst outcome would be one that simply encouraged trustees to “de-risk” schemes further by purchasing highly priced gilts to protect themselves against mechanical increases in short-term liabilities caused by falling market yields — a pro-cyclical practice known as “liability-driven investment”.

In essence that is what the risk-weighted capital requirements do. They doom banks to end up gasping for oxygen in dangerously overpopulated safe-havens against especially little capital, leaving the riskier but perhaps more profitable bays unexplored.

Ford argues: “It’s not clear though what any “tough new” rules could have done to help this messy situation.”

I know too little about Carillion but, what I do know, is that pension funds in general, government’s included, have been way too optimistic when estimating potential real rates of return in the order of 5% to 7%. 3% would be more than enough of an optimistic real rate of return, given the so many unknown factors out there.

@PerKurowski

If with Brexit Britain can break lose from Basel’s bank regulations, then it could come up on top of EU

Sir, Martin Wolf writes: “The recently leaked UK government analysis concludes that with Brexit, under a Canada-style deal, UK gross domestic product might be 5 percentage points lower than it would otherwise be, after 15 years — a loss of about a fifth of the potential increase in output by that time”, “Britain’s road to becoming the EU’s Canada”, February 21.

Has someone in the UK government analyzed what long term impact on UK’s gross domestic product the risk weighted capital requirements for banks have? I mean because since this regulation gives banks great incentives for staying away from financing the riskier future and just keep to re-financing the safer present, that most be causing some serious costs for the future.

Again, any bank regulations that is so stupidly based on the assumption that the ex ante perceived risks reflects adequately the ex post danger to the bank system, has to turn out incredibly costly.

So, if Brexit allows Britain the opportunity to break lose from these regulations, and Britain capitalizes it, while EU stay hooked on it, then Britain could come up over EU, and many in Europe would want to Baselexit too.

Why, when the world is going through so many not entirely understood changes, should Britain limit itself to cry over what it can lose with Brexit, while giving so little consideration to what it has to win, with our without EU?

PS. My 2019 letter to the Financial Stability Board
PS. My 2019 letter to the IMF

@PerKurowski

To base bank regulations on that ex ante perceived risks reflects the ex post possible dangers, is pure an unabridged naïve over-optimism

Sir, Martin Wolf writes “Over-optimism is the natural precursor of excessive risk-taking, asset price bubbles and then financial and economic crises.” “A bit of fear is exactly what markets need” February 14.

Indeed, and what is more a naïve “Over-optimism” than bank regulator’s risk weighted capital requirements for banks, based on ex ante perceived risks reflect the ex post possibilities?

Wolf writes of “the hope that those who manage systemically significant financial institutions remain scarred by the crisis and are managing risks more prudently than before”. Why should they? The incentives provided by the risk weighted capital requirements for banks still distort the allocation of credit. In this context “prudently” means more banks assets going to perceived, decreed or concocted safe-havens, some of which, as a consequence, are doomed to be dangerously overpopulated. 

Wolf admonishes, “If a policy [quantitative easing] designed to stabilise our economies destabilises finance, the answer has to be even more radical reform of the latter.”

I would argue that the “quantitative easing” was not correctly designed to help the economy, precisely because it ignored the regulatory distortions that impeded the economy to, by way of bank credit, use that liquidity efficiently.

Wolf correctly states “It is immoral and ultimately impossible to sacrifice the welfare of the bulk of the people in order to placate the gods of the financial markets”. But I ask, is that not what is being done by allowing banks to obtain higher expected risk adjusted returns on equity when financing the safer present, than when financing the “riskier” future our grandchildren need to be financed?

Again, I dare Martin Wolf to explain why he believes regulators are correct in wanting banks to hold more capital against what, by being perceived as risky, has been made innocous to the bank system, than against what, precisely because it is perceived as safe, is so much more dangerous?

Bank regulators have the right to be fearful, but they should fear more what is perceived safe than what is perceived risky.

PS. Here a brief aide memoire on the major mistakes with the risk weighted capital requirements

@PerKurowski

The worst problem with the dangerously growing debt is what it has not financed

Sir, Pascal Blanque and Amin Rajan write: “for central banks, global debt is like the sword of Damocles — an ever-present danger. It stands at about 330 per cent of annual economic output, up from 225 per cent in 2008… No one knows all the cracks into which excess liquidity has seeped — or what risks are being stored up”, “Beware the butterfly: global economies are on borrowed time” January 7.

Sir, if central bankers are only now waking up to this fact, then you must agree with that we are in much bigger problems that we thought.

Central bankers, lacking in character and not wanting to live up to their own responsibilities, dared not do anything but to push the 2007/08 crisis cart down the road, with their QEs and low interest rates. For someone who argued back in 2006 the benefits of a hard landing, that is bad enough.

But it’s so much worse than that. Blanque and Rajan argue that “Debt means consumption brought forward while low rates mean the survival of zombie borrowers and companies… High debt is not intrinsically bad so long as it is used to fund investments that deliver profits or create financial assets worth more than the debt. Data on this score are hard to come by.”

And there lies the fundamental problem. Because of risk weighted capital requirements for banks, bank credit has been used to finance “safer” present consumption; to inflate values of mostly existing assets; and way too little to finance “riskier” future production. It amounts to having placed a reverse mortgage on our past and present economy, in order to extract all of its value now, not caring one iota about tomorrow, and much less about that holy social intergenerational contract Edmund Burke spoke about.

It is clear the experts Blanque and Rajan have yet not understood what happened as they write: “The origins of the current worries predate the 2008 crisis which was caused when lending standards went from responsible to reckless: the siphoning of money into dodgy ventures such as subprime mortgages, covenant-light loans or sovereign lending based on creative accounting.”

The truth is that without truly reckless regulatory standards, those which allowed banks to leverage over 62.5 time to 1 with securities rated by human fallible rating agencies AAA; and, at least in Europe, allowing banks to lend to a 0% risk weighted sovereign like Greece against no capital at all, nothing of the above would have happened.

What to do? In my mind, in order to extricate the world of this problem, we need first to rid us completely of the credit distorting risk weighted capital requirements; and second, to be able to manage the transition to for instance a 10% capital requirements against all assets, including sovereigns, without freezing the whole credit machinery, perhaps bank creditors would have to accept, in partial payment of their credits, negotiable non redeemable common fully voting shares issued by the banks. If that helps to bring back undistorted bank vitality, it might be the best shares to have ever.

PS. Blanque and Rajan reference “S&P 500 corporates… stashing cash reserves outside the US.” What cash? Treasurers have not stacked away cash under corporate mattresses. Those surpluses are all already invested in assets, of all sorts, and which could suffer losses just like any other assets.

@PerKurowski

Sadly, banks must now to take on board rules that were not adjusted to what caused the crisis.

Sir, Martin Arnold, your Banking Editor writes: “In the coming year, much of the alphabet soup of post-crisis financial regulation will be completed — including Basel III, IFRS 9 and Mifid II — giving the industry the most clarity for almost a decade on the rule book it must follow.” “Lenders take on board rules of a post-crisis world” December 30.

We are soon three decades after regulators in 1988 with Basel I, concocted risk weighted capital requirements for banks, and 13 years after they put these on steroids with Basel II’s risk weights of 0% for sovereigns, 20% for AAA rated, and 35% for residential mortgages. That caused irresistible temptations for banks to create excessive exposures to these “safe” assets, which resulted in the 2007/08 crisis. And yet there is almost no discussion about that monstrous regulatory mistake.

So the risk weighting is still part of the regulations; and therefore the 0% risk weighted bank exposures to sovereings keeps growing and growing; as well as is the disortion of bank credit in favor of the “safer” present and against the “riskier” future. 

In this respect if I were to title something of this sort at this moment it would be more in line of “Lenders take on board rules that have not been adjusted to the crisis and therefore guarantee a world with even larger bank crises”

The irresponsibility and lack of transparency evidenced by the members of the Basel Committee is amazing. The lack willingness of media, like the Financial Times, to pose some simple questions to these regulators, is just as incomprehensible. 

When the next bank crisis, or the next excessive exposure to something perceived as very safe blows up in our face, how will your bank editor then explain his silence on this?

@PerKurowski

Mme Lagarde. With regulations that distort the allocation of bank credit, any recovery is on shaky grounds.

Sir, I refer to Chris Giles’ “IMF chief warns of risks to recovery” July 6.

Of course, with regulations that distort the allocation of bank credit to the real economy, any recovery is on shaky grounds.

To help Mme Christine Lagarde of the International Monetary Fund understand the issue, better, I have drafted a short and polite letter she could send to her friends the regulators in the Basel Committee and the Financial Stability Board. Their answer, or their no answer, should reveal a lot. 

Dear regulator.

You set your risk-weighted capital requirements based on the ex ante perceived risks already considered by bankers when determining the size of the exposure and the risk premiums to charge. Could that not imply that perhaps the ex-ante perceived risks are excessively considered?

I often wonder if it would not be wiser of you and your colleagues to set these based on those risk not having been adequately perceived, or that bankers are not capable of manage the risks they perceive; or with an eye to somewhat unlikely but nevertheless potentially catastrophic events.

You and I know that one vital function we expect our banks to perform is to allocate credit efficiently to the real economy. Remembering that context, I wonder if the risk weighting you and your colleagues customarily make in your regulatory function is perniciously, if also unintentionally, distorting capital allocation -- by favoring the safer? past over the riskier? future?

Sincerely,

PS. If they do not answer Mme Lagarde could find a summary of some of the mistakes with risk weighting here.

@PerKurowski

Dear Undercover Economist, in the case of banks, much more than deregulation it was/is ​very ​bad miss-regulation

Sir, Tim Harford writes: “As the world economy grows, one might expect markets to become more like the perfectly competitive textbook model, not less. Deregulation should allow more competition; globalisation should expose established players to pressure from overseas; transparent prices should make it harder for fat cats to maintain their position.” “This is the age of the Microsoft economy” May 19.

“Deregulation”? No way Jose! In the case of bank regulation it is missregulation. The globalised risk weighted capital requirements for banks favor directly the access to bank credit of the “fat cats” and so makes any on the ground competition harder.

Sir, it amazes me why this is so hard to understand, even for an undercover economist.

If you have $100.000 to invest, whether you or a financial advisor takes the decisions, you will most probably end up with a portfolio with some larger exposures to assets perceived in the market as safer, earning lower rates, and some smaller exposures to other assets that because these are perceived as risky, will earn you higher rates. And your portfolio will hopefully provide you with a risk-adjusted return that is acceptable to you.

But not once will you consider the $ invested into safe assets to be any different from the $ invested into risky assets… if you lose anyone of these it will hurt all the same.

Bank regulators decided that for banks, that was not to be. They split the banks’ capital into different $, allowing for different leverages, based on the perceived risk of those assets as such, meaning not on their risk for the bank system.

To top it up they came up with such a loony thing as to assign a 20% risk-weight to the so dangerous AAA rated and one of 150% to the so innocuous below BB- rated.

Of course that has distorted the allocation of bank credit in favor of what is perceived, safer, usually the past and present.

Of course that has hindered competition by making it harder for the riskier, usually the future, like SMEs to access bank credit (and who therefore often having to sell out their dreams to any huge safe incumbent).

Sir, Harford finalizes with: “In the very long run a superstar economy could become a technological utopia, where nobody needs to work for a living. That would require quite a realignment in our economic system”. Indeed that is why I have been arguing for quite some while that we need decent and worthy unemployments… something for which most likely a Universal Basic Income is required.

@PerKurowski

Until now any excesses in the use of power by President Trump would pale when compared to those of bank regulators

Sir, Gillian Tett writes: “Trump has managed to make the US constitution a live topic of debate…. the White House’s immigration clampdown… has created a real-time lesson on the limits of presidential power… The concept of “checks and balances” is no longer something written about in a school exam but instead is being breathlessly discussed on breakfast television… It is one thing to squeal with fury about the actions of the White House but what is badly needed is for voters (and journalists) to exercise a similar scrutiny over the operations of Congress and the judiciary, not to mention the lobbyists. “Our teenagers stand to profit from their awakening” February 18.

Sir, someday perhaps some grown-up grandchildren will awake and say: “During decades the risk weighted capital requirements gave banks incentives to refinance the “safer” past and present, and not to finance the riskier future we sorely needed to be financed. As a consequence many millions of SMEs and entrepreneurs around the world were denied that bank credit that could have created a new generation of jobs for us. Granma, please tell us you did not know anything about this, and yet said nothing”

@PerKurowski

Free Greece from regulatory shackles that make banks finance more the safer past & present than the riskier tomorrow

Sir, when commenting on the tensions between a “eurogroup” of ministers and the IMF about how to solve the problem called Greece you, as you should, clearly argue in favor of some additional relief of that debt “overhang that can only depress confidence”, “The IMF should stay in the Greek rescue squad”. October 12.

The problem though is that even if all Greece’s debt was condoned, but bank regulations stayed the same, that nation would just repeat its and most other countries’ recent mistakes.

Sir, nothing expresses a more depressed confidence in tomorrow as Basel’s risk-weighted capital requirements for banks. If Greece, and all the rest, is not freed from it, its banks have no chance of allocating credit so as to achieve a sturdy and sustainable growth. And besides if such growth does not happen, the banks’ own stability is also endangered.

That Europe, IMF, and the rest of regulators, do still seem to be unaware of what nasty effects their current bank regulations produce, is just amazing. Or perhaps they are all aware of it, but, with a little help from their friends, like FT, are just circling their wagons in order to defend their little mutual admiration club of technocrats.

There should be claw-back clauses for failed regulators and blind journalists (and editors) too!

@PerKurowski ©

Sir, I wonder, is it not time that Mr Martin Wolf looks into the possibilities that little me might have a point?

Sir, in the UK as in most other countries banks have been given the following instructions by their regulators:

If you invest in something safe, like lending to a good sovereign, lending to those with very high credit ratings, or financing residential houses, then you are allowed to hold little capital. That means that you then will be able to leverage your equity and the support society awards you a lot; meaning that you then will be able to earn high expected risk adjusted returns on equity.

But, if you invest in something risky, like lending to SMEs and entrepreneurs, then you need to hold more capital. That means that you then will be able to leverage less your equity and the support society awards you; meaning that you then will probably earn lower expected risk adjusted returns on equity.

Sir, those instructions clearly guarantee that bank credit will not be allocated efficiently to the real economy. Those instructions lead to the dangerous overpopulation of safe havens, and for the economy to equally dangerous under exploration of the riskier but perhaps more productive bays. Those instructions stop banks from financing the riskier future, making them only refinance the safer past. Those instructions will waste, or in some cases even make worse, all what stimulus like QEs, low interest rates, fiscal deficits and other are supposed to help and correct.

On this subject I have written Mr. Martin Wolf literally hundreds of letters over the last decade. Mr. Wolf besides kindly allowing me to publish on his Economists’ Forum in October 2009 an article titled “Free us from imprudent risk aversion”, has completely ignored the subject of the distortions caused by the Basel Committee’s regulations.

In July 2012 Wolf wrote that when "setting bank equity requirements, it is essential to recognise that so-called “risk-weighted” assets can and will be gamed by both banks and regulators. As Per Kurowski, a former executive director of the World Bank, reminds me regularly, crises occur when what was thought to be low risk turns out to be very high risk."

That was a reference to part of my arguments that I of course much appreciate but, as can be seen, it had only to do with how useless these regulations are in terms of guaranteeing bank stability.

Now I find that Mr. Martin Wolf quite lugubriously writes: “If the UK is to thrive economically, it will not be enough for it to manage Brexit, hard though that will surely be. Its policymakers must also start from a realistic assessment of the UK’s mediocre performance. This is no world-beating economy. It is not even a Europe-beating economy, except on creating what are too often low-wage jobs. It will have to do far better if it is to deliver the higher living standards its people want in the tougher environment ahead.” “Economic ills of the UK extend well beyond Brexit” September 29.

Sir, I just wonder, is it not time that Mr Martin Wolf looks into the possibilities that little me might have a point… and not only for the UK?

I mean it could be quite timely given the upcoming annual meetings of the IMF and World Bank in Washington and in which Mr. Wolf will again moderate a couple of events, one on inequality and one on jobs, both themes affected by the regulatory distortions.

PS. Unfortunately this year like last, I will not be in Washington so as to be able to participate as civil society and express my concerns there, also for the umpteenth time.

@PerKurowski ©

Central banks that only want banks to harvest what’s “safe” and not sow what’s “risky”, do not deserve any credibility

Sir, you write “central banks have resorted to ever more ingenious methods to convince a sceptical public that they still have the ability to create inflation”, “The growing challenge to central banks’ credibility” September 24.

Excepting those loving the current inflation in the values of assets, what sceptical public do you identify as wanting the core goal of central banks to be achieving higher inflation?

And as for their tools to obtain that “core goal” you mention the failures of QEs and low interest rates, and seemingly want them to dig deeper into negative interest rate territory.

No Sir! Any central banker that does not speak out against the risk weighted capital requirements for banks, that which have banks only refinancing the safer past and not financing the riskier future, do not deserve any credibility. Moreover they should be publicly shamed.

PS. Not only criminals and tax-evaders, but also ordinary people can beagainst restrictions on cash

@PerKurowski ©

How can expectations be high when you discriminate against the future, on account of it being riskier than the past?

Sir, John Kay writes: “It is not because interest rates are too high that eurozone consumption is sluggish but rather because expectations are so low. Fiscal austerity and the aftermath of the global crisis have dimmed the employment prospects of a generation of young Europeans. Low interest rates have as intended pushed up the prices of long-dated bonds and houses” “The twisted logic of paying for the privilege of lending”, September 10.

Frankly, how can expectations not be low, when we have regulators that order banks to hold more capital against what’s perceived as risky, the future, a job to be created; than against what is perceived as safe, the past, a house that has already been built?

And Kay writes: “There are obvious requirements for investment in the eurozone — to provide power through cleaner energy plants, to improve roads and relieve overcrowding on trains, to build houses, to accommodate tens of thousands of recent refugees and above all to fund the new businesses that will promote innovation on the continent.”

Yes, but, if so, why do we not have capital requirements for banks based on those purposes?

Mr. Kay, I tell you, it is not “dysfunctional capital markets, rather than any excessively high interest rates, that are behind an investment shortfall across Europe”. It is totally dysfunctional bank regulations.

Mr. Kay also reminds us of the “aphorism that people will lend you money so long as you can prove you do not need it”. But Sir, that is what Mark Twain told us long ago: “The banker lend us the umbrella when the sun shines and wants it back when it looks like it could rain”; and which is precisely why the Basel Committees’ risk weighted capital requirements for banks don’t make sense.

Mr. John Kay, wake up!... and you too Sir.

@PerKurowski ©

Bank regulators should not discriminate in favor of the “safer” past and present, and against the “riskier” future.

Sir, Mariana Mazzucato writes: “On the finance side, the problem is not quantity but quality: industrial and innovation policies require long-term, strategic finance, while the UK continues to reward short-term finance. The few attempts at building sources of patient public finance have been neglected” “A strong industrial strategy has many benefits” August 4.

What already exists, the past and present, is generally perceived as safer than what is planned to exist, the future.

And so when regulators decide that what is ex ante perceived as safe requires banks to hold less capital than what is perceived as risky, they allow banks to leverage their equity, and the support of society (taxpayers), much more with the past and present than with the future.

And since regulators have also decreed the sovereign to be infallible, and set the risk weigh for it at 0%, while the risk weight for an ordinary SME or entrepreneur is 100%, regulators similarly allow banks to leverage more when lending to the government than when lending to the private sector.

I have no objection to governments trying to do some of the pro-investment efforts that Mazzucato writes about in her article but, before that, and much more important for the long term, we need for the current regulatory distortions of the allocation of bank credit to the real economy to disappear.

What would the interest rate of public debt be if all hidden regulatory subsidies of it are removed? I have no idea, but perhaps then “the successful Green Investment Bank” might not be that successful.

@PerKurowski ©

Hardheaded bank regulators still believe they’re up against the expected while the real enemy is always the unexpected

Sir, Ben McLannahan discusses the consequences of changing “the current regime [in which] banks can hold off adding to reserves until the point at which losses on the loan become probable…[to one in which] banks will be made to log all expected losses over the life of the loan on day one, based on a combination of experience, their own forecasts and the state of the economy”, “Big lenders raise concerns over new loan loss rules” June 22.

One direct consequence of that is that those borrowers who are ex ante perceived as risky, will therefore force banks to recognize losses earlier than “when probable”. That might sound correct, but the real effect is that, when compared to those ex ante perceived as safe and which have lower probability of losses, it will discriminate against the risky.

And so when you layer this on top of the discriminations already produced by the risk weighted capital requirements for banks, the access to bank credit for those perceived as risky will only become more difficult. And all really without making banks much safer. The expected never causes major bank crises, it is always the unexpected losses for what had erroneously been perceived as safe that does.

McLannahan reports that Hal Schroeder, a board member at FASB, opines that the new rule — known as the Current Expected Credit Loss, or CECL — “aligns the accounting with the economics of underwriting, and the informational needs of investors”.

And to justify it Schroeder “noted that in the four years before the crisis, loans held by banks in the US rose 45 per cent, while reserves set aside for losses fell 10 per cent. That meant that loan-loss reserves as a percentage of gross loans were near a multi-decade low on the eve of the Lehman collapse.”

But why was that? That was the result of banks increasing their exposures to what was perceived as safe, because of lower capital requirements, and lowering their exposures to what was perceived as risky, because of lower capital requirements… and then being surprised when “super-safe” AAA-rated securities, backed with “super-safe” residential housing mortgages, and loans to sovereigns decreed as “super-safe”, like Greece, turn out, ex post, un-expectedly, against probabilities, to be very risky.

Sir, what’s being done here, especially without eliminating the risk-weighted capital requirements, evidences that the regulators still don’t understand that they are not up against the expected, their real challenge is the unexpected. Since what is perceived as safe has much more potential of providing unpleasant surprises than what is perceived as risky, their regulations just makes the bank system more brittle and fragile.

And to top it up by discriminating against the risky they hinder the banking system from taking the risks the real economy needs to move forward.

We need our banks to work for all, not just for the banks, and for those perceived as safe.

We need our banks to finance the riskier future of our young, not just refinancing the safer past of their parents.

@PerKurowski ©