Europe, America, G20, don’t walk away from Basel Committee risk weighted bank capital regulations…you’d better run!

Sir, John Dizard writes about a “meeting of the Basel Committee on Banking Supervision on November 28 and 29… is scheduled to agree a “standardised approach for credit risk” and impose limits on the use of internal models. The idea is that banks in the G20 countries, a group of the world’s most powerful economies, will not engage in regulatory arbitrage, or international game playing that results in a lowering of credit standards.” “Basel’s background noise for the next crisis”, FTfm, November 7.

Of course, the Basel Committee should prohibit banks from using their own models to define their own capital requirements; allowing it, is like letting children use their own nutrition models to pick between chocolate cake, ice cream, broccoli or spinach.

But, to impose a regulators’ defined “standardised approach for credit risk”, is just as loony; it suffices to have a look at what the standardized risk weights included in previous Basel Committee regulations.

One example: Basel II, 2004, set the risk weight for an asset rated AAA to AA at 20% while that of an asset rated below BB- was set at 150%. Anyone believing that what is rated as highly speculative, almost bankrupt, below BB-, is more dangerous to the bank system than what is rated AAA to AA, must be smoking some weird stuff.

Sir, unfortunately Dizard, as most of you in FT, shows little understanding for the whole issue when he questions: “under the current version of the Basel “standardised approach”, unsecured lending to a non-public, below investment-grade corporate borrower requires the same bank capital commitment as project financing secured by assets, liens on equity and cash lockbox arrangements. Based on the past low loss rates for project lending, that is between two and three times as much capital as the risk should require.”

If that is so, should not the difference in risk reflect itself sufficiently in the interest rate and the size of exposures? Why should that same perceived risk also have to be reflected in the capital? Does Dizard (or you Sir) not know that any risk, even if perfectly perceived, leads to the wrong decision if excessively considered?

Sir, ask Dizard: “Why should a bank when lending to a below investment-grade corporate borrower have to hold more capital than when lending to “safe” projects? Will not the “risky” corporate anyhow get less credit and pay higher risk premiums than the “safe” project? 

Sir, again, for the umpteenth time, bank capital should not be required to cover for expected risks; it should be there to cover for the unexpected.

Sir, again, for the umpteenth time, the risk weighted capital requirements for banks have introduced absolutely insane distortions in the allocation of credit to the real economy. If Europe, America, G20, or the whole world do not run away from the regulators’ senseless doubling down on ex ante perceived risk, their economies are doomed to stall and fall.

@PerKurowski

The Supreme Court should order Obama to stop quitting smoking

Sir I could not agree more with the general tone of Christopher Caldwell’s “No smoke without ire” December 27.

I was a smoker and it took me years to break my habit, or at least not give in to it more, but during my quitting time of about two years, and to the extent that I was unable to write any cohesive ideas on paper, I was an impaired person.

In this respect to think of the president of the most powerful country of the world, in these extremely difficult times, impairing himself just to set an example is about the worst example he could give his country.

Maybe the Supreme Court in exercising their checks and balances should order Obama to smoke a number of cigarettes a day while his presidency last. Or is this an issue for Congress?

Obama will be risking his life. In the line of duty? As a Commander in Chief? You’ve got to be joking!

Are there other alternatives than snus?

Sir, in How Europe can help snuff out smoking John Gapper points in the direction of the Swedish “snus”, a grinded tobacco you place under your stiffly curved upper lip. I have used it, 40 years ago, I liked it, but I can also testify against its total absence of esthetics, when brown liquid tobacco drips down between your front teeth. In fact giving up smoking this way might also require giving up other things as well, like dating.

An interesting alternative was also presented in 2005 by two professors of the University of Wisconsin-Madison, Robert Haveman and Jon Mullahy who then proposed a scheme for their local community where bars could trade smoking permits as a mean let the market arbitrage the difficulties of imposing non-smoking bans. Though cute, the idea seems not to have taken off, and I suspect is primarily because if a bar wanted to be a non-smoking bar it would always come out as a seller of smoking rights, while a bar that wanted to allow smoking would always be a buyer, something that does not rhyme well with market efficiency. The possibility of assigning a fix number of smoking permits per square foot/hour and auctioning them off to the patrons on a continuous basis, with any rights so acquired expiring within a short time period, could be an option favored by the derivatives community, as it would allow for the trading in second hand smoke risk and perhaps even a market in not-smoking-guarantees.

Whatever, the difficulties enocuntered in the area of quitting smoking should be used when analyzing the practical and ethical aspects of quitting carbon emissions, like for instancce when we think of leaving the solutions for the climate change in the hands of the trading of carbon-emission rights, and which though reminiscent of the indulgencies (shamefully) traded by the Catholic church centuries ago, lately seem to have captured the interest of some mainly protestant countries.