The seeds of the next debt crisis are to be found in the kicking of the 2008 crisis can forward, without correcting for what caused that crisis.

Sir, I refer to John Plender’s “The seeds of the next debt crisis” March 4.

Plender writes: “From the late 1980s, central banks — and especially the Fed — conducted what came to be known as “asymmetric monetary policy”, whereby they supported markets when they plunged but failed to damp them down when they were prone to bubbles. Excessive risk taking in banking was the natural consequence”

Not exactly “risk taking”! The risk weighted capital requirements caused excessive dangerous bank exposures, not to what was perceived risky, like loans to entrepreneurs, but to what was perceived safe, like residential mortgages; or decreed as safe, like the sovereign; or concocted as safe, like what banks’ internal risk models produced.

Plender asks: “Has the regulatory response to the great financial crisis been sufficient to rule out another systemic crisis and will the increase in banks’ capital provide an adequate buffer against the losses that will result from widespread mispricing of risk?”

No, it has not been sufficient. That because the incoherent response to a crisis caused by AAA rated securities backed with mortgages to the US’s subprime sector, was to keep on using risk weighted bank capital requirements based on perceived EXPECTED losses, and not on UNEXPECTED losses.

Plender writes: “The central banks’ quantitative easing since the crisis, which involves the purchase of government bonds and other assets, is, in effect, a continuation of this asymmetric approach”

Indeed, in 2006, when an upcoming crisis was slowly being detected by some, FT published a letter in which I argued for “The long-term benefits of a hard landing”. Sadly, central bankers and regulators wanted nothing of such thing, on their watch, and kicked the 2008 crisis can forward to our children and grandchildren, as hard as they could, and here we are… with world borrowings up to the tilt, and lenders waiting to be blown away by a coronavirus.

PS. At this moment, this letter not included, in my TeaWithFT blog, there appears 2.948 letters sent to you over soon two decades on the issue of “subprime banking regulations”.

@PerKurowski

Perceived credit risk is all about expected losses, while bank capital should be a buffer against unexpected losses.

Sir, John Kay writes that Warren Buffet, “In a revealing moment, when asked about the absence of conventional due diligence in his acquisition process; acknowledged that Berkshire had made bad acquisitions, but never one that could have been avoided by the kind of information that due diligence might have revealed.” “The Buffett model is widely worshipped but little copied” May 4.

Translate the above into bank regulations and it would mean: Banks could always lose but not because of the information a credit analysis might have revealed… much more dangerous than the expected, is the unexpected.

And that Sir is one of the many reasons why I believe current regulators are worse than fools. They defined the capital banks should be required to have, in order to confront unexpected losses, based on expected perceived credit risks. 

Please don’t tell me you think that is smart. In fact, the safer something is perceived, the greater is its potential to deliver huge unexpected losses. In fact, from this perspective, the safer something is perceived, the larger should the capital requirements for a bank be.

By the way let me make it clear that I am arguing this only to make a point, and I am not now suggesting we should distort the allocation of bank credit to the real economy in the other direction, favoring the risky.

Sir, if we are to distort, let us at least, as a minimum minimorum, do so with a purpose. For instance make the capital requirements for banks based on job creation and earth sustainability ratings.

PS. Here are plenty of reasons for why I believe the bank regulators in the Basel Committee are complete idiots… or something worse 

@PerKurowski ©

Mervyn King, for bank regulators to use the expected, as a direct proxy for the unexpected was, and is, radically dumb

Sir, John Plender, March 3, reviewed Mervyn King’s book “The End of Alchemy: Money, Banking and the Future of the Global Economy" And in doing so Plender writes that King argues that in a world of what economists now call “radical uncertainty”, it is not always possible to compute the expected utility of any action. There is simply no way of identifying the probabilities of all future events and no set of economist’s equations that describe people’s attempts to cope with that uncertainty.”

And according to Plender, King proposes a “central bankerly pawnbroking” facility to supply “liquidity, or emergency money, within a framework that eliminates the incentive for bank runs… That would displace what King regards as a flawed risk-weighted capital regime ill-suited to addressing radical uncertainty.”

And John Kay ends his discussion of King’s book with: “There is a world of difference between low-probability events drawn from the tail of a known statistical distribution and extreme events that happen but had not previously been imagined”, “The enduring certainty of radical uncertainty”, April 6.

Hold it there has all that really anything to do with the current risk weighted capital requirements for banks? Absolutely not!

What happened was that since the regulators did not know how to estimate the unexpected losses, those that bank capital is foremost to safeguard agains, they went out and used the expected credit risks. And since those risk were already cleared for by banks, with interest rates and the size of exposures, credit risks, when also used to set capital requirements, were given too much consideration.

And, for the umpteenth time: any risk, even if perfectly perceived leads to wrong actions if excessively considered.

And Plender also wrote about King arguing: “Banks satisfied investors’ desperate search for income by creating increasingly complex and risky financial products based chiefly on mortgage debt. Bank balance sheets grew explosively as property lending ballooned. At the same time, the capital of banks shrank as they took on more risk.

Again that is not really so! The increasingly complex and risky financial products chosen were entirely based on that these could be argued to be very safe, and therefore require banks to hold less capital. For instance mortgage debt would never ever have exploded as it did, if instead of receiving a 35 percent risk weight, it had the 100 percent risk weight assigned to “risky” SMEs and entrepreneurs.

And Plender also wrote about King arguing: “They were trapped by what game theorists call a prisoner’s dilemma. If they retreated from riskier lending and trading strategies while reducing their borrowings, a decline in short-term profits relative to their competitors would have caused staff to defect in pursuit of higher bonuses elsewhere and prompted calls for the chief executive’s head.”

Those “short tem profits” are not some absolute profits, but returns on equity, and so banks, searching for the highest profits, naturally favored those exposures that provided the highest expected risk adjusted returns on equity, in other words those that could be most leveraged.

Sir, I have no respect for a regulator like Mervyn King. He and all his colleagues decided to regulate banks without defining their purpose. Had they done so they would have known, that the most important social purpose of banks is to allocate credit efficiently to the real economy.

Now our banks do not finance the riskier future they just refinance the, for the short time being, safer past.

“A ship in harbor is safe, but that is not what ships are for.” John Augustus Shedd, 1850-1926 

I can understand journalists covering the reputation of old friends… but is that really their role and duty? “Without fear and without favor”… Hah!

@PerKurowski ©

Bank regulators have set their highest bank capital requirements for what poses the least dangerous tail risks

Sir, I refer to your “World economy of so-so growth and fat tailed risk” January 4, and your reporters “Unlikely suspects are in the wings for 2016” of January 2.

The latter states: “Some risks are quotidian. Will a company struggle to generate cash flow, or will a particular asset fall out of vogue. Then there are outcomes that exist in the narrow, far reaches of statistical probability distributions, known as “tail-risks”. A hefty blow to investments is usually the result when such shocks occur.”

And with respect to current bank capital requirements, those that are supposed help cover for unexpected losses I have two questions for your reporters.

First, what can cause more unexpected losses, quotidian risks like credit risks, or the kind of events that they exemplify as some possible dangerous tail risks?

Second, in the case of credit risks, what has the capacity to produce the most sizable unexpected losses, what is perceived as safe or what is perceived as risky?

The correct answer to those questions should indicate the absurdity of setting the highest capital requirements for that that in terms of a quotidian credit risk is perceived as risky.

Think of it. The risk weight for a private sector asset rated below BB- was set at 150 percent, while that of an AAA to AA rated was only 20 percent. Is below BB- rated, something which scares away any risk adverse banker, really more dangerous to the banks than what is AAA rated? 

Sir, how long will your reporters ignore this sad truth? Is there a tail risk they personally have to be afraid of?

Laura Noonan in “EU board budgets for 10 bank failures” December 4, writes that the Single Resolution Board is seeking €40m in accounting advice, economic and financial valuation services and legal advice, to be used in the resolution of struggling Eurozone banks from 2016 to 2020.

Sir, have any of the possible big shot candidates for that consultancy ever informed bank regulators that their capital requirements make no sense? Sorry, just asking.

@PerKurowski ©

Bank regulators’ magnificent pro-cyclical machine is fueled by credit rating downgrades

Sir, Eric Platt writes: “US corporate downgrades soar past $1tn as defaults gain pace” December 5.

He discusses several of its implications but forgets one of the most important, namely its impact in the capital requirements for banks. As is, because of the risk weighted capital requirements for banks, these will be required to hold more capital, meaning they will be able to lend less, or even have to dispose of assets, meaning everything will get worse, all the courtesy of dumb and useless pro-cyclical regulations.

The moment a bank puts an asset on its books, that is the moment when it needs to have sufficient capital, and that sufficiency should obviously include the possibility of a future downgrading.

How is it bank regulators cannot understand that the safer something is perceived the larger the potential for bad news?

@PerKurowski ©

Bank regulators make sophisticated remarks about the need of countercyclical regulations and design pro-cyclical ones.

Sir, I refer to Joe Leahy’s “Rating agency pressure on BTG Pactual” November 27.

Downgrading… depending on whether it crosses some regulatory thresholds, could mean banks are required to hold more capital against loans assets so affected. Were it to happen, this could, in a pro-cyclical fashion, only help to increase the resulting problems.

And what would usually trigger such a credit degrading? Mostly some unexpected events, like in this case the arrest of BTG Pactual’s chief executive, André Esteves.

And this evidences, for the umpteenth time, the dangers with using ex ante perceived expected credit risks to define the capital banks should hold against unexpected losses.

When the outlook is rosy and so many could be perceived as safe then the capital requirements go down, so bank can leverage even more, so bank can give even more credit, and everything will look even rosier.

When the outlook is darker and many could be perceived as risky, then the capital requirements go up, so bank can leverage less, so banks have to contract the credit they have awarded, and so everything will look even darker yet.

Regulators fill their mouths with sophisticated remarks about the need of countercyclical regulations but manage somehow, with a little help from silent FT, to avoid being held accountable when they design pro-cyclical nonsense.

@PerKurowski ©

A ‘light touch’ does not distort. Risk weighted capital requirements for banks was pure ‘heavy-handed dumb touch’

Sir, commenting on “Bank of England’s damning report on the 2008 failure of HBOS — seven years since the financial crisis” you write: “A [drawback] is that the regulators themselves — and the politicians who established the “light touch” regulatory regime for the City of London that encouraged the HBOS failure — do not face similar action… Meanwhile, the FSA, which was supposed to ensure that the UK’s biggest banks did not run aground and put the taxpayer at risk, was broadly deficient in its job. It operated within the prevailing political assumption of the time that the FSA “had to be ‘light touch’ in its approach and mindful of the UK’s competitive position”, “Better late then never for banking discipline”, November 20.

Twice you reference ‘light touch’. Wrong! A ‘light touch’ does not distort. The portfolio invariant credit risk weighted capital requirements for banks was pure and unabridged ‘heavy handed dumb hugely distortive touch!

I have explained it to you and your columnists and reporters a thousand of times, in hundreds of different ways, and so here comes a reprise of some of my arguments:

Bank capital is to be a buffer against unexpected losses. To base them on expected credit losses does not make any sense.

Any risk, like credit risk, even if perfectly perceived, causes the wrong actions if excessively considered.

All major bank crises have resulted from excessive exposures to assets perceived ex ante as safe, never from excessive exposures to what was perceived as risky.

To allow banks to hold less capital against some assets allow the banks to earn higher risk adjusted returns on equity on these. And that distorts the allocation of bank credit to the real economy.

To allow some banks to use their own risk models to determine the capital requirements is like allowing kids decide how much ice cream and chocolate to eat that leaves out the spinach and the broccoli.

Without these regulations banks would never ever have been allowed to leverage as much as they did.

To regulate banks without considering their purpose, like allocating bank credit efficiently to the real economy, is utterly irresponsible.

To allow some few credit rating agencies to have such importance for the capital banks needed to hold was to invite systemic risk.

Sir, it was clear that with this piece of regulations banks would dangerously overpopulate safe havens and, equally dangerous for the real economy, underexplore risky, but potentially very rewarding, bays. And that is what happened, and still you have difficulties of seeing it, I do not understand why. Is the difference between ex ante risks and ex post realities too much to handle?

Not understand the role of risk-taking in keeping the economy moving forward so as not to stall and fall, shows lack of vision and wisdom.

And you know I could go on and on.

You write: “By naming [some] who ran HBOS “without due regard to basic standards of banking” and recommending that several face possible bans from working in the industry, it clarifies responsibility.

I wish that would be valid for failed bank regulators too. Most of them have been promoted and are busy hiding or ignoring their own responsibilities.

@PerKurowski ©

Stop bank regulators from distorting bank credit allocation to the real economy, based on their anxiety de jour.

Sir, Barney Jopson and Gregory Meyer report, “The Fed wants to use capital charges to discourage banks from risky activities involving hazardous materials that could threaten their survival in the event of a catastrophe… like costly disasters such as tanker spills or gas pipeline explosions.” “Banks face capital call for commodity disaster costs”, November 4.

With their credit risk weighted capital requirements for banks regulators already discourage banks from lending to those perceived as risky, like SMEs and entrepreneurs, now they also want to discourage lending to what could produce a gas spill or a gas explosion. Where will all this risk aversion end?

When will they realize that something perceived risky like handling hazardous materials is by definition much less risky to the banking system than something that has an AAA credit rating?

Banks should of course hold capital against unexpected losses but regulators should of course also have the intellectual capacity to understand that the really dangerous unexpected, has much greater potential to appear among what is perceived as safe, than among what is perceived as risky.

Please let us have an 8 to 10 percent capital requirement on all bank assets based on that regulators simply do not know what they do, instead of having them to distort the allocation of bank credit based on their anxiety de jour.

@PerKurowski ©

Insurance sector: Again loony regulators are trying to cover for unexpected losses by analyzing the expected ones.

Sir, I refer to Alistair Gray’s report on “the capital [insurance companies] must hold against unexpected losses” “Insurers face tough new safety rules” October 5.

In it Gray writes: “A paper to be published quantifies the higher capital requirements for the designated insurers. The size of the hit will depend on each company’s mix of business and how systemically important regulators deem them to be. So-called non-traditional and non-insurance (NTNI) activities carry the largest surcharges, of between 12 per cent and 25 per cent.”

So again we have regulators, like those of banks, who set capital requirements for unexpected losses based on the expected risks they perceive. Loony! Do regulators really think they can perceive risks better than the insurance companies? Is there not a huge risk that both the insurance companies and the regulators will perceive the same risks, and so that there therefore will be an overreaction to these risks, which obviously means a sub-consideration of other risks? And boy, are these regulations just screaming to be gamed?

Also, at a moment that so many want infrastructure projects to be started as a way of reactivating the economy, who of the regulators is thinking about the fact that many of the risky long term projects, often financed by insurance companies… could perhaps not happen only because of wrong and distorting capital requirements.

Where have all humble regulators that know of the importance of not interfering gone? When will they ever learn, when will they ever learn?

Why do they in order to cover for unexpected losses not just set for instance a 10% capital requirement on all assets? Are they scared they would then look like less sophisticated regulators to the general public? If so, God save us from regulators suffering an inferiority complex.

@PerKurowski ©

Mark Carney should not warn other about climate change risks, if he neglects to do what is in his hands to do about it

Sir, you write that BoE is rightly worried about the dangers posed by climate change “Carney’s warning on carbon’s financial risks". October 1.

Of course the consequences of climate change, and of the regulations designed to stymie it, and of the gaming of those regulations, represent a huge potential of unexpected losses. But, if Mark Carney were really concerned about climate change then, as the current Chair of the Financial Stability Board, instead of casting himself as Cassandra in order to warn others, he would see to that bank regulators duly considered that risk.

For instance he could try to convince his colleagues that banks, in relative terms, should be allowed to hold less capital when helping to finance sustainability, so that they earn higher risk adjusted returns on equity when they finance sustainability, and so that banks finance sustainability a lot.

But instead Carney and his colleagues have set their risk based capital requirements for banks solely based on ex ante perceived credit risks, basically the only expected risks that banks already clear for. If that is not dumb what is?

Sir, what we now have is unbelievable. Banks, those who concentrate the most knowledge about evaluating credit risks, and should therefore be the first line of credit-risk takers for the society, by lending to for instance SMEs and entrepreneurs, are being allowed to earn much higher risk adjusted returns on their equity when minimizing credit risks… which leaves the risk-taking soldiering to all us other… widows and orphans included.

And, talking about moral responsibilities, should not Mark Carney have warned all aspiring “risky” entrepreneurs that, because they were usually perceived as risky from a credit point of view, they should forget their plans and dreams as they could no longer count on a fair access to bank credit?

And, talking about moral responsibilities, should not Mark Carney warn all our young that, henceforth, banks would not be financing sufficiently their future, as that requires a lot of risk-taking, but would mostly be dedicated to refinancing a safer past.

And, talking about moral responsibilities, how can bank regulators ignore the fact that it is not what is perceived as risky that poses the major dangers for our banking system, it is always what can be erroneously perceived as absolutely safe.

Sir, as I see it the Basel Committee regulators have and are producing losses of almost a climate change scale… and FT refuses to warn about it.

@PerKurowski

Psychological barriers to entrepreneurship, like an overanxious nannie mentality, thrive in developed nations too.

Sir, Sarah Murray writes: “the biggest barriers to entrepreneurship are psychological.”, “A variety of barriers thwart entrepreneurs in poor nations” September 15.

Indeed, so it is, and not only in poor nations.

Entrepreneurs, because they are most often ex ante perceived as poor credit risks, need to pay higher risk premiums, and have access to smaller loans; and therefore represent, ex post, quite little danger for banks.

Those ex ante perceived as very good credit risks, are required to pay much smaller risk premiums, and have access to much larger loans; and therefore, if ex post they turn out to be risky, represent much bigger dangers to banks.

Unfortunately, because of some psychological weakness, a sort of overanxious and overprotective nannie mentality, the current batch of bank regulators confuse the ex ante expected losses with the ex post unexpected losses, and so require banks to hold more capital when lending to “risky” entrepreneurs, than when lending to “safe” sovereigns and highly rated private sector borrowers.

And that allows banks to earn much higher risk adjusted returns on equity when lending to the safe than when lending to the risky… and we know what that means to the access to bank credit of the entrepreneurs.

@PerKurowski

#1 Macro-prudential rule is never take for granted those in charge, like bank regulators, know what they are doing

Sir, Richard Milne quotes Stefan Ingves with “sailing a small boat on the ocean: it’s good if you know how to sail.”, “Riksbank head warns on tools to tackle crises”, September 14.

But let us not forget that Stefan Ingves is the current chairman of the Basel Committee, and as such, we could presume he agrees entirely with the current risk-weighted capital requirements for banks. In essence that regulation implies the following:

The better things are going for some assets, and so the safer these look (like house mortgages), the less capital are banks required to hold against these, and so the more incentives do banks have to lend, and thereby make these assets look even better yet… that is until the overcrowding of those safe havens become so dangerous that the whole banking system fails.

The worse things are going for some assets, and so the riskier they look (like loans to SMEs), the more capital must banks hold against these, and so the more incentives will banks have to reduce lending, and thereby make these assets look even worse yet… that is until riskier but perhaps more productive bays are left so unexplored that the whole economy fails.

Sir, the first and most important macro-prudential rule is that of never taking for granted that those in charge of sailing the boats know how to sail. And as I have argued for years, current bank regulators, which include Mr. Ingves, have no idea about what happens out there on the real oceans… their experience might be restricted to having played with toy boats in bathtubs.

The second most important macro-prudential rule with respect to banks, and boats, is that instead of by all means trying to stop these from going under, assist these to fail expeditiously, whenever they seems to be insufficiently seaworthy.

If it were up to me, and knowing these are to cover against unexpected losses I would set the capital requirements for banks based of cyber attack or being struck by asteroids, so as not have to spell out these as based on risks of bankers not knowing how to manage perceived risks, and worse, on risks of regulators trying to manage risks.

PS. “Gud gör oss djärva” “God make us daring” is a Swedish psalm. It would do us much good if bank regulators tried to understand its message....perhaps Riskbank would be a more appropriate name than Riksbank for a nation that has prospered thanks to risk-taking and much reasoned audacity.

PS. Axel Oxenstierna, 1648: “An nescis, mi fili, quantilla prudentia mundus regatur?”, “Do you not know, my son, with how little wisdom the world is governed?”, “¿No sabes, hijo mio, con que poca sabiduría el mundo esta gobernado?”, “Vet du inte, min son, med hur litet förstånd världen styrs?” 

@PerKurowski

We must make sure our bank regulators possess sufficient mental bandwidth to perform their duties

Sir, Tim Harford writes that a study in 2006 led by David Strayer, a psychologist at the University of Utah, found that: “The problem with talking while driving is not a shortage of hand. It is a shortage of mental bandwidth” “Multi-tasking: a survival guide” September 6.

What an interesting piece of information. Now we only have to find a reliable way to measure mental bandwidth, so as to be able to make sure vital decision makers have sufficient of it.

Clearly that was not the case of bank regulators. As a minimum these should have sufficient mental bandwidth so as to be able to simultaneously regulate against the risks of the banking system collapsing, and make sure that banks adequately achieved their purpose, like that of allocating credit efficiently to the real economy.

As is their mental bandwidth was so scarce they could (and can) only handle the risks of individual banks failing. As a result our whole economy is failing here and there.

Had they had enough of it they would have understood that the speedier an individual bank that cannot perceive adequately risks or manage these fails, the safer the whole system.

Had they had enough of it they would have understood that the last thing they should do in order impose capital requirements as a shield against unexpected losses, was to base these on about the only risk that was already being sufficiently cleared for, namely credit risk. 

Had they had enough mental bandwidth they could have set their capital requirements based on a thousand more appropriate risky events, like cyber attacks, China’s economy imploding, an asteroid hitting the earth, or central bankers not having a clear idea of what they are doing. 

@PerKurowski

We urgently need “Flop Pickers” or “Harbingers of Failure” to test those who are being picked as bank regulators.

Sir, I refer to Tim Harford’s “Meet the Flop Pickers” August 29. Boy could some good “Harbingers of Failure” have come in handy to stop the disastrous bank regulations flop.

What did the members of the Basel Committee for Banking Supervision do?

They based their capital requirements for banks on perceived credit risks, blithely ignoring that those risks, by means of interest rates and size of exposure, were about the only risks already being cleared for by the banks.

They assigned much of the role in determining credit risk to some very few human fallible credit rating agencies.

They based their capital requirements for banks, those that are primarily to cover for unexpected losses, on the credit risk perceptions about expected losses, blithely ignoring that the safer something is perceived, the larger its potential of delivering unexpected losses.

They regulated banks not caring one iota about the purpose of banks, and so they blithely ignored the vital function of banks of allocating bank credit efficiently to the real economy.

And so, by allowing those perceived as absolutely safe to have even more and cheaper access to bank credit than normal, while those perceived as “risky”, like unrated SMEs and entrepreneurs to have even less and more expensive bank credit than normal, they have made a great mess of banks, one of the most important components of our financial system.

And, to top it up, they decided governments were much safer than the private sector and that therefore bank needed to hold minimum capital when lending to governments, something that de facto meant that regulators believe government bureaucrats can use bank credit more efficiently than the private sector.

So you tell me… would it not be extremely important to have access to “Flop Pickers” or “Harbingers of Failure” to test those who are to be picked as bank regulators?

Could you please ask Eric Anderson, Song Lin, Duncan Simester and Catherine Tucker to see if they could find us some adequate Herbs to tests bank regulation products?

Urgently... since the same failed regulators keep on regulating without even acknowledging, and much less correcting their mistakes!

PS. They have blamed credit rating agencies though... without understanding that their regulations would cause dangerous distortions even if the credit ratings were perfect.

@PerKurowski

A Leverage Ratio makes banks hold equity on all exposures, to cover specially for unexpected losses, like cyber attacks

Sir, I refer to the letter signed by financial sector representatives: “Leverage ratio threat to the cleared derivatives ecosystem” August 27.

What is argued, that segregated cash margins, held to guarantee the commitments of clients, should be deducted from a bank’s actual exposure, sounds quite reasonable since the current construct of the leverage ratio “fails to consider existing market regulations that mitigate…losses”.

But when it is said that: “The leverage ratio is designed to require banks to hold capital against actual exposures to loss”, that is wrong. The leverage ratio is there to cover for any exposures to losses, most importantly any unexpected losses.

It would for instance be easier for regulators to just state that the leverage ratio is to cover against cyber-attacks… so as to clear the air, while moving towards a completely different Basel IV.

@PerKurowski

If John Kay truly believes in liberal education, he should help question the decisions of the job-specific trained.

Sir, John Kay writes: “the capacities to think critically, judge numbers, compose prose and observe carefully — the capacities that education can and should develop — will be as useful then as they are today” “The timeless benefits of a liberal education” August 26.

Indeed but that requires that the capacity of thinking critically gets a chance to be heard by those who certify having job-specific skills. And for that to happen those who write newspaper columns have a very special role in forwarding the observations.

Here just one example: Bank regulators, with supposedly many job specific skills, decided for instance that assets rated BB- present immensely more possibilities of generating unexpected losses than assets rated AAA. And as a consequence they require banks to hold much more capital against BB- assets than against AAA assets.

And there are freethinkers like me who holds that to be utter nonsense, because clearly the riskier an asset is perceived, by definition the less are its possibilities to generate unexpected losses. 

But, can I get help to forward this and many other similar observations on our current bank regulations? No - because journalists clearly believe much more in the regulators' job specific skills than in any liberal education and critical thinking. Is it not so Mr. Kay?

@PerKurowski

Sovereign Debt Restructuring Mechanisms (SDRM) starting with salvaging and not with preventing, are moral hazards

Sir, Elaine Moore’s when reporting on Sovereign Debt Restructurings Mechanisms quotes Anne Krueger with: “Government should be able to declare bankruptcy, just as companies do. Instead of bailouts and lost decades of austerity, they should be able to wipe the slate clean and start again.” “Economist in a hurry” August 8.

“No!” if it means irresponsible governments will find it easier to start from clean slates

“No!” if it means irresponsible creditors will be bundled together with responsible ones.

“Yes!” if it means responsible governments will have a chance to restart their country.

“Yes!” if it means odious creditors will be required to assume the largest share of sacrifices.

And for the latter to happen, nothing better than assuring that any Sovereign Debt Restructurings Mechanism developed, diminishes the possibilities of being needed.

In this respect I believe any acceptable SDRM should begin with:

First and foremost by eliminating all incentives that can help governments contract too much debt… like banks being allowed to hold much less capital when lending to sovereigns than when lending to citizens.

And then by defining clearly what, when compared to ordinary credit to the public sector, should be deemed as odious credit. For instance, credit not awarded in a transparent way, or awarded when it was clear that the resulting debt might not be sustainable, and was therefore of speculative nature, should not receive the same treatment in a SDRM, as public credit awarded transparently and when there was no doubt about the sovereigns capacity to serve it.

Anne Krueger holds “If you get to a stage where a country’s debt is so large that it cannot grow, then you need to rethink”… and that to me, as an ordinary citizen, is best done by thinking and rethinking about how it landed itself in such a mess.

PS. The article ends quoting Krueger with “And there will be a next crisis, though where it comes from is likely going to take everyone by surprise”. If only she could convince our bank regulators of that. They still believe that the unexpected problems, for which banks need to hold capital, should be based on the expected problems derived from credit risk.

@PerKurowski

Citizens should question the purpose of banks, but FT should also have a duty to forward those questions.

Sir, Saker Nusseibeh writes that citizens should question the purpose of the financial system “Systemic moral hazard is embedded in current economic view”, FTfm August 2.

Indeed, but that is mostly because the regulators never found it necessary to define the purpose of our banks, before regulating these.

With technocratic arrogance they decided that when banks lend to “safe” governments and to members of the AAArisktocracy, these should be allowed to hold much less capital (equity) than when lending to the “risky”, like to the SMEs and entrepreneurs.

That meant that banks would then in relative terms lend more and at lower rates to “safe” governments and members of the AAArisktocracy, than they would in the absence of these regulations.

And that means, almost explicitly, that regulators believe “safe” governments and members of the AAArisktocracy can use bank credit more efficiently than what SMEs and entrepreneurs can do. And that is of course pure and unabridged lunacy.

I have been questioning those capital requirements, for more than a decade, in soon 2.000 letters to the Financial Times. Long time ago I was told these were ignored because I was becoming tiresome and monotonous… as if that has anything to do with the fundaments or importance of my questions.

Again, FT why do all of you believe capital requirements for banks, those which are to cover for unexpected losses, should be higher for the risky than for the safe, only because the former present higher expected losses? I dare you to give me one single reason for it and then be willing to debate it publicly.

@PerKurowski

PS. From a 2003 World Bank workshop on bank regulations: “I have been sitting here for most of these five days without being able to detect a single formula or word indicating that growth and credits are also a function of bank regulations.”

The Basel Committee, with its bank regulations, represents a dangerous cult gone mainstream.

Sir, Douglas Coupland writes: “When it comes to the sharing of an ethos, history shows us that the more irrational a shared belief is, the better. The underpinning maths of cultism is that when two people with self-perceived marginalised views meet, they mutually reinforce these beliefs, ratcheting up the craziness until you have a pair of full-blown nutcases” “WE ARE DATA-The future of machine intelligence” July 18.

That, for us the truly rational, describes indeed the real great danger of the Internet; but also of course, for some lonely brain nuts, its real advantages. Before it could take you a lifetime to find a likeminded nut… now you are almost guaranteed to find plenty of them, in seconds, with only a couple of few searches. And, if not, you can always support yourself by using aliases.

But that said, if we include in cultism the following definition: “A usually nonscientific method or regimen claimed by its originator to have exclusive or exceptional power in curing a particular disease.”, then we should never forget that cultism can extend much further than to people with “self-perceived marginalised views”

Take for instance the Basel Committee: Its members designed a totally nonscientific method they thought could contain bank crisis, and managed to impose it worldwide. In other words they made a cult go mainstream… and clearly that has to be more dangerous than any cult exercised on the web.

“Unscientific”? Of course! They based their capital requirements for banks not on empirical evidence about what has caused all major bank crises in history, which is always excessive exposures to something erroneously perceived as safe; but on the perceived credit risks of banks assets, as if the banker was totally oblivious of these perceptions.

“Unscientific”? Of course! To figure out an estimate for the unexpected losses for which they should require banks to hold at least some capital, they used as a proxy the expected losses… entirely ignoring that the potential of unexpected losses for banks that an asset can cause, is always higher the safer that asset is perceived.

@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