Bank regulators need Business Education… perhaps Finance professors too… if not, they sure need History Education

Sir I refer to your special magazine “FT: Business Education”, September 11, 2017.

If you were a banker, of that type that until 1988 (Basel I) existed for about 600 years, you would, in order to obtain the highest risk adjusted return on equity, and while keeping a close eye on your whole portfolio, lend money to whoever offered you the highest risk adjusted interest rate… of course as long as all your other costs were covered.

If for instance you had to hold 10% capital, perhaps so that your depositors or regulators felt safe, then your expected return of equity would be the average of those net risk adjusted interest rates times 10 (100%/10%)… this before taxes of course.

If an SME or an entrepreneur offered the bank a perceived risk adjusted net margin of 1.25% while an AAA rated only offered 0.75%, the banker would in that case naturally prefer giving the riskier borrower the loan... though probably it would be a much smaller loan.

Sir, do you agree with that? No? Why?

Because when bank regulators introduced risk adjusted equity requirements, they completely changed banking. Since then the risk adjusted net margins borrowers offered, have to be multiplied, by the times these margins can be leveraged on equity.

For instance Basel II, 2004, with a basic 8% bank capital requirement, assigned a risk weight of 20% to any private sector exposure rated AAA, which meant banks needed to hold 1.6% (8%*20%) against these exposures, which meant they could leverage equity 62.5 times (100%/1.6%).

That same Basel II assigned to for instance an unrated SME or entrepreneur, a risk weight of 100%, meaning a capital requirement of 8%, meaning banks could leverage only 12.5 times their equity with this type of loans.

So now what happened? The AAA’s 0.75% net risk adjusted margin offer would become almost a 47% expected risk adjusted return on equity, while the riskier’s 1.25% would only represent about a 16% expected risk adjusted return on equity. Therefore the bank would now by much prefer the AAA rated… Bye-bye SMEs and entrepreneurs.

To earn the highest perceived risk adjusted ROE on the safest, must clearly be a wet dream come true for most bankers; well topped up by the fact that requiring so little capital from their shareholders when lending to the “safe”, left much more profits over for their bonuses.

Did not regulators know their risk weighted capital requirements would distort in this way the allocation of bank credit to the real economy? Seemingly not and that is why I suggest they should go and get some basic business education… after the professors who did not see this have also gone back to the most basic basics.

That because, if regulators did know about the distortion they would cause, then they have no idea of history… or worse, they are financial terrorists. That because no major bank crisis have never ever resulted from excessive exposures to what is ex ante perceived as risky; these have always, no exceptions, resulted from excessive exposures to what was ex ante perceived, and never ever from what was ex ante perceived as risky.

Sir, come to think of it you and most of your collaborators, perhaps all, should also go back to a business education 101.

@PerKurowski

Was the US Office of Strategic Services’ “The Simple Sabotage Field Manual” used by the Basel Committee?

Sir, John Kay refers to “The Simple Sabotage Field Manual — produced in the second world war by the US Office of Strategic Services, a forerunner of the Central Intelligence Agency — was designed to illustrate how, at little risk to themselves, saboteurs in occupied territories could damage organisations.” “Absurd roots of modern regulatory practice” December 23.

When we see how some few bank regulators, apparently with absolutely no risk for themselves have, by means of credit risk weighted capital requirements, managed to distort the allocation of bank credit to the real economy in most of the world, we could ask whether that field manual fell into the hands of the Basel Committee for Banking Supervision, and about that committee’s intentions.

And when Kay refers to FM Cornford’s procedural rules as an instrument to silence any objection and to “obscure troublesome considerations… and relieve the mind of all sense of obligation towards society”, then we might understand better the continuous rule expansion in Basel II, Basel III and those Basel’s still to come.

Frankly, nothing has sabotaged more our economies than Basel Accord's Basel I’s risk weights of zero percent for the sovereign, and 100 percent for the private sector. To me that was an act of statist regulatory terrorism. I am sure most members in the Basel Committee did it unwittingly… but, frankly, all of them?

@PerKurowski ©

Why is real fear of credit risks not as transitory as fear of terrorism?

Sir, Tim Harford writes about when recalling a flight taken after “watching the Twin Towers of the World Trade Center collapse on television”, he was “in a state of mortal fear”, but how that fear seems so foolish to him now. And that’s because “each year an American citizen has a one in 9,000 chance of dying in a motor vehicle accident, and… Even in 2001, the chance of an American being killed by a terrorist was less than one in 100,000”, “Nothing to fear but fear itself?” November 14.

Harford then argues: “Perhaps the true impact of terrorism is psychological… The terrorists’ best hope lies in provoking and overreaction. Too often they succeed”

Absolutely. And the question then is: What terrorism impacted our current bank regulators into believing so much that those who are perceived a risky credits cause more damage to our banks, than those who perceived as safe can turn out to be very risky?

The worst part of that belief is that seemingly it is not as transitory as Harford argues fear to more normal terrorism to be. Today, years after the explosion of what was considered safe by regulators, like AAA rated securities and loans to Greece, we still have much higher capital requirements for banks against what is perceived as risky than against what is perceived as safe.

@PerKurowski ©

Mario Draghi, for Europe’s and our young's sake, go home. And for your own, stop embarrassing yourself.

Sir I refer to Claire Jones’ “Draghi warns central banks against blind risk taking.” May 15.

Who understands it? “Mario Draghi has warned central banks to beware of the risk that aggressive monetary easing, including mass bond buying, [that which he has been promoting in the ECB] could lead to financial instability and worsen income inequality.

How shameless can you be? As the former Chairman of the Financial Stability Board he is as responsible as anyone else for bank regulations that have completely distorted the allocation of bank credit to the real economy.

He is quoted saying “After almost seven years of a debilitating sequence of crises, firms and households are very hesitant to take on economic risk”. Yes but the truth is that by means of the credit-risk-weighted equity requirements for banks he supports, he and his colleagues are de facto ordering the banks not to finance economic risks.

And he has the toupee of arguing that if ECB had refrained from its QE action, this “would have penalized young people”. No! There is nothing that penalizes young people as much as excessive sissyesque risk-aversion present in current bank regulations. Mr. Draghi, do you really know what is a real terrorist attack on our children’s future? I tell you, again: A risk weight of 0 percent for a sovereign and of 100 percent for SMEs or entrepreneurs.

And Draghi also has the toupee of warning that ECB’s policies could “exacerbate wealth disparities”. Amazing. He must by now be well aware of that current regulations impede bank credit going to where it is most needed, to finance the future and give those who have little opportunities; and directs credit to where it is “safe”, to refinance the past and keep up the value of the assets that exist and already have owners.

Mario Draghi, go home.

@PerKurowski

Regulators believe those perceived as “safe”, will originate less unexpected losses for banks than the “risky”. Loony!

Sir, I refer to your Special Report “Risk Management – Property” April 27.

It mentions the risks of: climate change, cyber security breaches, terrorism, earthquakes… all those risks that are difficult to currently estimate but that can produce extraordinary unexpected losses… including for banks.

But those risks are not considered at all by regulators who, when setting their equity requirements for banks, use the expected losses derived from perceived credit risks as a proxy for the unexpected… more-credit-risk-more-capital and less credit-risk-less capital

It sort of translates in that regulators would seem to believe that risks, like those listed affect more the “risky” like the SMEs, than the sovereigns and the members of the AAArisktocracy. I can’t believe you believe that too.

@PerKurowski