August 19, 2017

Tim Harford do not compare hurricane Katrina to our 2007/08-bank crisis. The first was nature the second was manmade

Sir, Tim Harford with respect to the global financial crisis, and referring to the fact that Hurricane Ivan of 2004 should have better prepared New Orleans for Katrina in 2005 asks: “even if we had clearly seen the crisis coming, would it have made a difference?” “Mental bias leaves us unprepared for disaster” August 19.

That is indeed a question, but a more precise one would be: “If we had clearly understood why a crisis had to come, would it have made a difference?”

Here is my simplified version of that issue.

Suppose a SME offered to pay the bank 6.5% in interest rate, which the bank saw as 2% for it’s cost of funds, 3% for the risk of the SME and 1.5% in net risk adjusted margin. Suppose also an AAA rated offering to pay 3.5% in interests, which the bank sees again as 2% for it’s cost of funds, 0.5% in risk premium and so therefore yielding a resulting risk adjusting net margin of 1%.

In all those more than 600 years of banking before the risk weighted capital requirements were introduced, bankers would lend to whom offered the largest risk adjusted net margin perceived, in the previous case to the SME.

But, after Basel II banks could leverage the SME’s offer 12.5 times, which would produce the bank an expected ROE of 18.75%, while the AAA rated could be leveraged 62.5 times, yielding an expected ROE of 62.5%.

Then of course the banks would naturally have to lend to the AAA rated, as not doing so would actually be ignoring their fiduciary responsibility to their shareholders.

So here is the real question. If that distortion in the allocation of bank credit had been duly understood, would it have made a difference? My answer would be a qualified “Yes!” That because, as a minimum minimorum, regulators would have understood that since their capital requirements were (loony) portfolio invariant, they would have to be especially careful with excessive growth of “safe” investments... like those AAA rated securities. 

Harford writes: “10 years on, senior Federal Reserve official Stanley Fischer is having to warn against ‘extremely dangerous and extremely short-sighted’ efforts to dismantle financial regulations.”

Sir, I warn instead against not dismantling entirely those financial regulations that caused the crisis… and that now keep sending all QE and low interest stimuli down unproductive roads.

PS. And not to speak about the 0% risk weighing of sovereigns, that which caused the excessive bank exposures to for instance Greece.


One day, Stanley Fischer, like most current central bankers and regulators, will ask himself, why did I not see that?

Sir, Sam Fleming writes: “Fischer worries about attacks by lawmakers on global regulatory bodies such as the Financial Stability Board, arguing that the rules it proposes are good for the world if everyone adopts them.” “Lunch with the FT Stanley Fischer ‘It’s dangerous and short-sighted’” August 19. Like Gershwin wrote it, “It ain’t necessarily so!”

In November 1999 in an Op-Ed in Venezuela I wrote: “The possible Big Bang that scares me the most, is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause its collapse”

In April 2003 as an Executive Director of the World Bank I argued that Board that "A mixture of thousand solutions, many of them inadequate, may lead to a flexible world that can bend with the storms. A world obsessed with Best Practices may calcify its structure and break with any small wind."

And in January 2003, FT published a letter in which I stated: “Everyone knows that, sooner or later, the ratings issued by the credit agencies are just a new breed of systemic errors, about to be propagated at modern speeds”

Sir, had regulators not introduced their risk weighted capital requirements for banks, made worse by the importance given to some few human fallible credit rating agencies, the 2007/08 crisis would not have happened; and the economy, net of automation and demographic factors, and considering the outlandish stimuli, would not be as stagnant as it is now.

PS. That Op-Ed I referred to above also included: “I recently heard that SEC was establishing higher capital requirements for stockbroker firms, arguing that “. . . the weak have to merge to remain. We have to get rid of the rotten apples so that we can renew the trust in the system.” As I read it, it establishes a very dangerous relationship between weak and rotten. In fact, the financially weakest stockbroker in the system could be providing the most honest services while the big ones, just because of their size, can also bring down the whole world. It has always surprised me how the financial regulatory authorities, while preaching the value of diversification, act in favor of concentration.”

Let me translate that into the current risk weightings. “It establishes a very dangerous relation between risk and the right to access credit. The “risky”, like SMEs, could be providing the most important additions to the real economy, while sovereigns and AAA rated, just because of their perceived “safety”, could bring the whole world down.”


August 18, 2017

In crossroads where some cars are allowed to speed through at 62.5, and other at 12.5, which would cause the greatest accidents?

Robert A Denemark writes: “the financial system provides incentives to engage in risky behaviour that tends toward crisis… It is a good idea to avoid accidents even when there are no traffic laws, but if vehicles collide there can be no official blame. Legitimacy, the focus of the editorial, comes from the recognition of most people that the rules make sense. Do they?” “Financial system itself makes crises likely” August 18.

Do current rules make sense? Let me answer that question this way: In that crossroad where bankers take decisions about credit, regulators allowed bank equity to be leveraged much more with the net margins if these came from “safe” borrowers than when produced by “risky” ones. For instance Basel II, allowed a 62.5 times leverage for the AAA rated and only 12.5 times for SMEs.

Sir, where would you think the biggest and most dangerous crashes could occur?

The 20% risk weighted AAA rated securities, and 0% to 20% risk weighted sovereigns, like Greece, is a good hint for you to come up with the right answer.


Odious debts, odious credits and odious regulations are all yin-yang elements of the financial sector

Sir, M Shepherd, when commenting on Alex Pollock's letter "Sovereign debt has a pretty bad record" August 16 writes that “All too often, debates about defaults on government bonds focus on the borrowers and neglect the lenders.” “The other side of the sovereign debt story”August 18.

Absolutely, and that is why when I write about odious public debt, like that contracted in Venezuela, I always follow it up with one about odious public credit, like those awarded to Venezuela.

But, of course I have to add a point. For instance the immensely excessive public debt in Greece would never have happened had regulators not, for the purpose of setting the capital requirements for banks, assigned Greece a zero percent risk weight.

Those regulators have not been held accountable either, among others because of the network solidarity FT has showed them … in fact they have been promoted to central banks… and our banking system still lives under the distorting thumb of risk weights.


August 17, 2017

In order to find common Nafta ground, US, Canada and Mexico must begin by clearing for robots and automation

Shawn Donnan and Jude Webber quote Robert Lighthizer, US trade representative, having told negotiators. “Thousands of American factory workers have lost their jobs because of these provisions.” “Canada and Mexico rebuke US as Nafta renegotiation starts” August 17.

If Nafta members take notice of what robots and automation has done to manufacturing jobs, in all of their nations, then instead of facing each other as enemies they would be sharing a challenge.

It still amazes me how the recent American elections failed to recognize the job opportunities lost to automation. Had that not happened, Donald Trump would have had to speak about a Wall against robots instead, and would not have become president… not that that would have solved much either.

Jobs lost to robots and automation is not an easy problem to handle as it does produce good results too. If I was Nafta I would begin by asking my partners: “How do we make sure our grandchildren will be able to live surrounded by 1st class robots and smart artificial intelligence and not end up with 3rd class ones and dumb AI? That would be a real positive and constructive challenge for it.


August 16, 2017

Britain, don’t let all your hard and well-earned goodwill in Europe go to waste with dumb Brexit negotiations

Sir, Josef Joffe describes well the kind of goodwill Britain has in Europe. That goodwill is being horribly wasted in the Brexit proceedings, among other by those Remainders that want to get Brexit failures, in order to argue their petty “I told you so” “Brexit Britain has displaced Germany as the land of dreamers” August 16.

Had I been a citizen of Britain wanting decent Brexit negotiations, or one wanting to remain in EU, I would have reached out to all the millions of Josef Josses in Europe with the message of: “The Brexit vote indicates not all is well in EU, what can we do, and how can you help us to convince our fellow country men of not leaving?”

And if that had not opened up new roads, then my minimum minimorum plea would be: “Europeans, make sure your relations with Britain are mot harmed more than necessary by means of leaving Brexit negotiations, unsupervised, in the hands of EU-technocrats who have suffered a love spat or want to show off as though macho negotiators.


Its worse! To central banks’ holdings of public debt we must add that of normal banks holding it against zero capital

Sir, Kate Allen and Keith Fray with respect to the QEs write that “The Fed’s balance sheet has expanded significantly several times in the past, including during the second world war when it soaked up debt sales in a bid to improve market conditions. But the current era is the first time in history that such a large group of central banks has undertaken such a substantial volume of co-ordinated buying over the space of nearly a decade.” “Decade of QE leaves big central banks owning fifth of public debt” August 16.

That’s not the only “first time in history” event. Thomas Hale and Kate Allen, in “Europe weighs potential ‘doom loop’ solution” write “A critical factor in deciding demand for sovereign bonds is risk weightings, which determine how much capital a bank needs against its investments in different kinds of asset. Sovereign bonds in Europe have benefited from a zero risk weighting, making them highly attractive to banks, many of which borrowed cheaply from the European Central Bank to buy sovereign debt after the crisis.”

That should make clear for anyone not interested in hiding it that, to whatever public debts the central banks hold, we must add those that all banks hold only because they are allowed to do so against zero capital. Q. What is a 0.1% return worth if you can leverage it 1000 times? A. 100%

Sir, as I have told you umpteenth times before, in 1988, one year before the Berlin wall fell, that which was taken to be a big blow to statism, bank regulators, through the back door, introduced a zero risk weighting of sovereign debt. The statists have been playing us for fools ever since.

And now, when reality is catching up, they want to package and hide all this public debt in some securities they have the gall to name these European Safe Bonds “ESBies”, issued in order to “make the continent’s financial system safer”. Or, as Gianluca Salford, a strategist at JPMorgan disguises it, to “transport sovereign risk to a place where it’s more manageable”.

Sir, try to sell all central banks’ and banks zero weighted held public debt into a free market and see what rate you get. Taking current artificial public debts for real, or for being revenue neutral rates, or for being risk free rates, or for justifying public investment in infrastructure, is either stupidity or a shameful manipulation of truth. 

Sir, the day our citizens discover what is being done by these statist they will flee all sovereign debts and governments will be left, like Maduro in Venezuela, with central banks that can only print money to keep the can rolling and rolling until…

PS. Mr Salford argues: “Securitisation is not an innately bad thing — it can be used well as a stabilising source” No! If securities are sold at their correct securitized risks they do not provide remotely as much profits as those sold incorrectly offering securitized safety. In other words, suffering from innately bad incentives damns these.


August 14, 2017

Our dear George Banks, having anteceded the Basel Committee, would never have dreamt about current bank bonuses

Sir, Jonathan Ford writes: “As Andy Haldane of the Bank of England points out, there are few ways for banks to bolster their returns to shareholders. One is to loosen underwriting standards and so increase the riskiness of assets they invest in. The other is to squeeze the amount of regulatory capital they set against the investments they make.” “Banking bonuses ought to be dead and buried by now” August 14.

Haldane is wrong about the increase of riskiness of assets, to improve the return on equity that is of little and doubtful sustainable value (bankers have even been fired for that); but he is absolutely correct about the regulatory capital.

When current bank regulators were taken for a ride by bankers and convinced, like for instance with Basel II of 2004, to set the capital requirements against something rated AAA to AA at only 1.6%, meaning an authorized leverage of equity of 62.5, they allowed bankers to earn returns on equity beyond their shareholders’ wildest dreams, and this even after keeping for themselves huge eye-watering bonuses.

Place a 10% capital requirement on all bank assets and those bonuses would immediately begin to vanish in the air as a result of shareholders becoming again important to banks.

As a huge bonus for the rest of the economy, that would also eliminate the current odious distortion of bank credit in favor of “the safe”, sovereigns, AAArisktocracy and houses, and against the risky, SMEs and entrepreneurs.

George Banks (the first)


What’s 100% political correct has not even to be close to real feelings on Main Street

Sir, Gideon Long strangely thinks it is important to quote one obscure member of an unconstitutional assembly that represents perhaps less than 15% of Venezuelans with “If you think of invading us we’ll make [the] Vietnam [war] look small,” and then to describe that this member’s shouts “earned him a rapturous standing ovation”. “Trump threat ‘lets Maduro blame US for his woes’” August 14.

To reaffirm the validity of that Long refers to a poll in which “9 per cent of respondents felt the crisis would only be resolved by foreign military intervention”.

Suppose instead a poll asking: “If foreign military intervention was the only way to get rid of the current regime, (as Long quotes a Venezuelan woman believing) would you approve of it?” The way I read the feelings in my homeland (albeit from a foreign land), that question would be responded affirmative by a majority of Venezuelans.

Of course if that would happen, once the necessity has been removed, Venezuela’s Main Street would most probably, sort of thanklessly, again align itself to more political correct attitudes and blame Yankee imperialism for much. C'est la vie! 

PS. The way Gideon Long transmits information about Venezuela makes me think he might be one of those who can't resist a lefty talking purty.


August 12, 2017

The crisis can of ten years ago was kicked down some roads leading to nowhere

Sir, in your “Ten years on, the crisis leaves a dark legacy” of August 12 you rightly write, “A newly minted mortgage-asset securitisation industry had turned the borrowed capital into very liquid but little-understood securities”; but you so wrongly silence the fact that if these securities were just rated AAA to AA, regulators, with their Basel II of 2004, had allowed banks to leverage their capital (equity) an amazing 62.5 times to 1. If banks only obtained a 0.5% percent margin on these, they would earn a 50% return on equity.

And you recount: “The freeze in money markets hit global banks that had [authorized by regulators] leveraged their balance sheets to astonishing levels. They could not bear the strain… The rest — bank bailouts, recession, central bank intervention — is history. The history is unspooling still”

That’s true, but why is that so? The answer, because our baby-boomer leaders, egged on by failed regulators not wanting to understand or confess their mistakes, were to coward to bite the bullet, and so just kicked the can down some roads. Those roads, because of the distortion produced by the risk weighted capital requirements for banks in the allocation of credit to the real economy, lead to nowhere. If we do not completely eliminate this source of distortion, our capitalism, that which has served the Western world so well, will never regain legitimacy again.

You argue, erroneously I believe: “Financial crises end because market prices for tainted assets are established and credit flows again. In this case, only dramatic action by government made that possible.” On the contrary, had the markets been allowed to act, like what I suggested in 2006 with my letter “Long-term benefits of a hard landing”, we would probably already be clearly out of the woods, and the too big to fall banks would not have just grown bigger still.

Besides Sir, what capitalism do you refer to, that in which bank regulators assigned a risk-weight of 0% to the sovereign, and one of 100% to the citizens? To me that sounds pure and unabridged statism. Could it be you all in FT are devout statists, and that is why you have so insistently silenced my arguments?


August 10, 2017

Amazing how an anthropologist, like Gillian Tett, can believe that our financial markets are driven by lust for risks

Sir, Gillian Tett writes: “if we want to avoid a replay of 2007, we must keep questioning our assumptions — and peering at the parts of the system that seem “boring”, “geeky” and “dull”. Our mental bins can sometimes hold time-bombs” “The next crash risk is hiding in plain sight” August 10.

Indeed! And one of the greatest drivers of such time-bombs is confusing ex ante perceived risks with ex post risks.

But Ms. Tett also writes “Sometimes, market shocks occur because investors have taken obviously risky bets — just look at the tech bubble in 2001”. What? Does FT’s in house anthropologist really believe investors were taking “obviously risky bets”? Was it not much more the illusion of very high-risk adjusted returns that caught the investors’ attention?

But Ms. Tett also writes: “Most investors assume that Treasuries are the risk-free pillar of modern finance”. What? If there is anyone who has really assumed that, it is the bank regulators when they, in 1988, with Basel I, began to assign 0% risk-weights to sovereigns.

Ms. Tett also writes “precisely because the system has become so flush with cash — and seemingly calm — there is complacency; and not just about the dangers of clearly risky bets (say, Argentine bonds), but about the perils of “safe” assets too”.

Not really, the complacency about clearly risky bets is almost non-existent when compared to that related to safe assets.

As an example of riskiness Tett points out “an obscure “Inverse Vix” ETF that benefits from low volatility… the world’s 34th most actively traded equity security…[and] that has returned almost 100 per cent this year. What? Is she really arguing that something which offered the expectations of large returns and that has actually provided almost 100 per cent return this year, is riskier than holding 10 year German bunds yielding certain negative rates?

Sir, it is so hard to understand how Ms. Tett, and most of you, even when acknowledging that “The next crash risk is hiding in plain sight”, seem unable to wrap your minds around the fact that what is really dangerous, for instance to our banking system, is what is perceived as safe… and that therefore the current risk weighted capital requirements, besides dangerously distorting the allocation of bank credit to the real economy, are incredibly dumb.

Sir, were you a part of the inquisition, you would most certainly be prosecuting Galileo.


August 08, 2017

Could the Venezuelan National Assembly sue Goldman Sachs on behalf of Venezuelans for aiding and abetting a dictator?

Sir, Mitu Gulati writes: “a judge could find that the holders of Maduro bonds must have known that they were transacting with an unrepresentative or illegitimate agent of the people… Agency law goes beyond merely voiding the contract between the principal and the third party; a third party who suborns a betrayal of trust by the agent may be answerable in tort to the principal”, “Maduro bonds” Alphaville July 8.

Gulati also writes: “It is the Constituent Assembly itself and all of its works that the post-Maduro government must argue are unauthorized, invalid and illegitimate. And the longer that the Constituent Assembly stays in power, and makes the laws of the country, the more it begins to look like the real legislature”

That begs the question, if a President of USA, like Donald Trump had managed to create something as odiously farcical as Venezuela Constituent Assembly, how long would it take for it to begin to look like the real legislature? 100 years?

PS. A simple but complex question from a humble Venezuelan economist to an outstanding Venezuelan international lawyer


August 07, 2017

Should not regulators know that what is perceived safe has the largest potential of being what’s dangerous for banks?

Sir, John Authers writes: “In January 2007, credit was priced on the assumption that virtually all US sub-prime mortgages (to people with poor credit histories), would be repaid in full. House prices were already falling. Several subprime lenders went bankrupt in early 2007, with no great effect on credit prices. Banks felt obliged to stay in the market”, “Warning signs existed during decade before credit crunch” July 7.

Of course signs of distress in the housing markets were already seen. In August 2006 you published a letter I wrote to you in response to an editorial titled “Hard edge of a soft landing for houses”.

But to say that these credits were based on some direct assumptions or knowledge about subprime mortgages is blatantly wrong. It was strictly based on the AAA ratings that credit rating agencies issued to many of the securities backed with mortgages to the subprime sector.

And Sir, when with Basel II of 2004 regulators had authorized banks to leverage their capital 62.5 times when investing in what carried an AAA rating, but only 12.5 times when lending to for instance SMEs, there were absolutely no incentives to question such ratings. Banks did not feel obliged to stay in the market they loved it.

It all comes back to one of the fundamental mistakes made by current regulators, namely that of believing what is perceived as risky to be more dangerous to the banking system than was is perceived safe.


What the $150bn in US fines paid by banks has caused the real economy, can best be described as financial sadism

Sir, Kara Scannell writes: “Demands for accountability ushered in an era where the US government was willing to penalise financial institutions severely, yet most crisis-related actions were civil rather than criminal and few bankers went to prison” “Banks rack up $150bn in US fines since start of the financial crisis” July 7.

If we use Basel II’s basic capital requirement of 8%, that represents an authorized leverage of 12.5 to 1. If we multiply that number times the $150bn in fines paid by banks, we can see that the real economy might have obtained $1.9tn less access to credit.

And of course, punishing the shareholders of banks that way, must cause the cost of bank capital to increase and, as a result, borrowers having to pay more for loans.

And of course, banks tight on capital, will not lend to what requires them to hold more capital, which currently means those perceived as risky, like entrepreneurs and SMEs, something that can only reduce the dynamism of the economy.

Sir, that is pure and unabridged financial sadism. That amount of killed bank credit potential represents about 50% of the Fed’s current QE balance. Need we say more?

PS. I remember having written a similar comment about 3 years ago.


Why is it so hard to understand Basel I’s 1988 statist regulatory distortion of credit in favor of sovereigns?

Sir, I have written 59 letters to John Plender over the years, mostly about the distortions in the allocation of bank credit to the real economy the risk weighted capital requirements cause. These letters, as well as other 2500 to you, denouncing the serious and fundamental flaws with the Basel Committee’s risk weighted capital requirements, have been basically ignored… let us say censored.

For instance in May 2016 I wrote: “I am amazed John Plender leaves out the fact that… courtesy of the Basel Committee, banks currently need to hold especially little capital against that public debt... for which “the issue of solvency would resurface”

And all that because unilaterally the regulators, in 1988, with the Basel Accord suddenly decided that sovereigns posed no credit risk, and no one protested the statism that was thereby de facto introduced.

To workout our banks out of such bind, will take huge amounts of fresh bank capital and very specialized knowledge, or intuition on how to go about it, without disastrously affecting the bank lending to the rest of the economy.”

And in November 2004 FT did publish one letter in which I wrote: “I also wonder in how many Basel propositions it will take before they start realizing the damage they are doing by favoring so much bank lending to the public sector. In some developing countries, access to credit for the private sector is all but gone, and the banks are up to the hilt in public credits.”

Now, John Plender writes: “The risk-weighted Basel capital adequacy regime, despite post-crisis tweaking, is fundamentally flawed. Sovereign debt enjoys excessively favourable treatment so eurozone banks stuff their balance sheets with the IOUs of seriously over-indebted governments”, “Lessons from the credit crunch” July 7.

Sir, when in a year or two I might publish a book on my impossibilities to communicate with FT, you or someone in FT will have some explanations to do.

In this world of fake news, shutting up someone who might be denouncing something that could be akin to financial sector terrorism is just as bad.


August 06, 2017

ECB’s Mario Draghi’s star quality would evaporate had he to publicly answer some hard questions on bank regulations

Roger Blitz writes: “Mario Draghi, president of the European Central Bank, will be the star at the annual Jackson Hole symposium in Wyoming this year.” “Weak dollar remains centre stage” August 5.

Sir, if Mario Draghi, a former chair of the Financial Stability Board, and the current chair of the Group of Governors and Heads of Supervision (GHOS) of the Basel Committee, and therefore one of the most responsible for current bank regulations is the star of anything, that is only because he has never been made to fully answer some questions about current bank regulations in public, by his peers or by for instance FT’s journalist.

There are many many questions I could think of, but let me just indicate two:

First: Mr. Draghi. Do you not think that allowing banks to leverage more their equity with the net margins offered by those perceived safe than with those same margins when offered by those perceived risky; which means it is easier for banks to obtain higher returns on equity with “the safe” than with “the risky” does not distort the allocation of credit to the real economy?

If Draghi answers no, then there is nothing to do, as he would be evidencing he is clueless about finance on Main Street. If he answers yes then follow up with: Don’t you think this could be dangerous for the real economy and who authorized you and your colleagues to do so?

Second: Mr. Draghi, obviously current risk weighted capital requirements for banks, more perceived risk more capital, less risk less capital, indicates you the regulators believe that what is perceived as risky, is what is risky for the bank system. So, will you please tell us when there has ever been a bank crisis that has resulted from excessive exposures to what was perceived as risky when placed on the balance sheets of banks? As far as I gather from history all bank crisis, no exceptions, have been caused by unexpected events, criminal behavior or excessive exposures to what was perceived as safe when incorporated on banks’ balance sheet but that later, ex post, turned out to be very risky.

If Draghi answers yes, then he is deaf and has not heard the question. If he answers no, then ask him to explain why Basel II assigned a standard risk weight of 20% to what was AAA to AA rated and a 150% to what was rated below BB- and would therefore not be touched by bankers even with a ten feet pole.

Sir, Mario Draghi at ECB and others at the Fed with QEs and low interest rates, have just been kicking the 2008 crisis can down the road. The risk weighted capital requirements have caused that can to roll on the wrong roads. That is an act of terrorism against our economies.


August 05, 2017

More intelligent but less uncontrollable, or dumber and more controllable robots, that is the real tough question

Sir, you write “some researchers have called for greater “robot transparency” — safeguards to ensure that humans can always grasp what the most sophisticated machines are doing, and why… Robots can help people with their work and unleash social and economic benefits. But they must be trusted, or the humans will vote to take back control”, “Intelligent robots must be trusted by humans” August 5.

Sir, what do you prefer, more intelligent but less uncontrollable or dumber and more controllable robots?

What are we to do if controlling our intelligent robots makes these weaker than those of our future enemies, whoever these will be?

I ask this because the revised version of that Chinese curse that holds "may your children live in interesting times", could very easily be, may your children lived surrounded by 3rd class robots and dumb artificial intelligence. 

So even if “The era in which robots might redesign themselves constantly and advance beyond human understanding, is far into the future” their education, like that of the humans, might very well start in quite early childhood. 


August 04, 2017

The risk weighted capital requirements give banks great incentives to hide risk from their regulators.

Sir, Eric Platt and Alistair Gray write “US regulators have joined investors in voicing concern over risky bank lending… particularly when projections make a company appear more creditworthy… ‘The agencies continue to see cases of aggressive projections used to justify pass ratings on transactions that examiners consider non-pass’… although they said the number of cases was “at much lower levels than in prior periods” “Wall Street watchdogs sound alarm over risky bank lending” July 4.

In good old banking days, around 600 years, before Basel Committee’s risk weighted capital requirements, bankers argued their clients riskiness in order to collect higher risk premiums. Now banks argue more their clients safety, in order to convince regulators that they can hold less capital. That distortion makes the efficient allocation of bank credit to the real economy.

“The Fed and its fellow regulators… give deals a pass or non-pass rating which is then used to build a picture of banks’ lending activities.”

Considering that bank crisis only result from unexpected events or excessive exposures to something perceived, concocted or decreed as safe, and never ever from something perceived as risky, does this pass or non-pass rating activity make any sense? Absolutely not! It is as silly as can be… except for those who earn their livings from working on bank regulations. 

If banks keep on thinking on how to for instance pass some ratings, so as to be able to leverage more their capital in order to obtain higher rates of return on equity, than on the real risks of their clients… they will again, like in 2007/08, go very wrong, more sooner than later.

If banks keep on thinking on how to for instance pass some ratings, so as to be able to leverage more their capital in order to obtain higher rates of return on equity, than on the real risks of their clients… they will again, like in 2007/08, go very wrong, more sooner than later.

“the agencies said that risks had declined slightly but remained “elevated”. Lending considered to be non-pass had fallen from 10.3 per cent to 9.7 per cent of the overall shared national credit portfolio” As I see it, we could just as well argue that where the real dangers lie, increased from 89.7% to 90.3%.

Sir, again for the umpteenth time, without the elimination of the insane risk weighted capital requirements, there is no way our banks will recover their sanity. I am amazed on how you have decided to keep silence on this.


July 30, 2017

On Main Street what’s perceived ultra risky, is de facto much less dangerous than what’s perceived ultra safe.

Sir, Simon Kuper writes: “The Republican plan to strip health insurance from 22m Americans (including 18m adults), it would kill about 32,700 adults annually (using the mid-range estimate). That’s gruesome. But boring old obesity kills far more.”, “How to solve the obesity epidemic” July 29.

That presents a perfect opportunity to explain again, for the umpteenth time, what regulators did wrong with their risk weighted capital requirements for banks.

They would have assigned a higher risk weight to the Republican plan, because even though it might kill less it is perceived (or decreed) as riskier, than what they would assign to what though more dangerous for society, obesity, is perceived as safer.

In Basel II, the ultra dangerous ultra safe AAA rated got a 20% risk weight, while the totally innocuous ultra risky below BB- rated got a 150% risk weight. 


The only real game changer for Venezuela would be sharing out all its net oil revenues equally to all Venezuelans

If Venezuelan oil revenues had been shared out equally to all Venezuelans, the current Venezuela tragedy would not be happening. It is as easy as that. To centralize those revenues in the hand of the government is an invitation to, sooner or later, have these to be managed by well-intentioned fools, outright bandits, or a poisonous combination of both, like now.

One sole change in the article 12 of Venezuela’s constitution, in order to declare the Venezuelan citizens to be the owners of all oil reserves, instead of the government, would be one of the biggest game changers ever.

In such a case could Venezuela’s creditors go after the oil belonging to about 32 million Venezuelans and not one government? How would a judge decide if he knew that creditors were trying to go after each Venezuelan’s US$30-40 per month, that which could help stop millions of human beings from starving or dying from the lack of medicine?


Solving problems by raising taxes and having bureaucrats have a go at these, only risks to complicate matters further

Sir, Rana Foroohar writes: “College students who manage to graduate do so with the highest average levels of debt in the country, since state funding has been so dramatically cut over the past several years. Meanwhile, roughly half of the population has only a high-school degree, which guarantees them a $15-an-hour future.” “New Hampshire: a tale of two Americas” July 29., strangely in that FT’s Weekend Magazine I do not receive as a subscriber in Maryland, USA.

That begs two sets of questions: First, is not ample availability of student debt a much larger driver of high student debt than lack of state funding? Would university fees be nearly as high if these were not so easily financeable? Is not student debt a business driven more by financial profiteers than by pure educational considerations? If students already find it hard to repay their debt, is it logical for taxpayers to foot that same bill? In short should not higher education be reorganized more in terms of being joint ventures between students and universities?

Second, in these times of robots and automation, how on earth can Foroohar presuppose having more than a high school degree would guarantee the young a more than $15-an-hour future? And if she supports the idea of a $15 an hour minimum wage, what does she suggest to do with all those who with or without high school degree cannot reach up to that bar.

Sir, much of this easy talk of solving coming problems the usual statist way by raising taxes and having bureaucrats have a go at it, only risks to complicate matters much more. As a Venezuelan I know that to prevent social order from breaking down is always better than trying to reconstruct it. We are facing a new world, we now already need decent and worthy unemployments. A universal basic income, funded with real money, which provides a step stool to reach up to the gig economy, seems like the only real, peaceful tool at hands… though of course the redistribution profiteers hate it as it diminishes the value of their franchise.

Foroohar also writes: “My husband… employs cleaners, plumbers and tradesmen, some of whose parents worked in the same jobs for his mother. It’s hard not to think of this as a kind of neo-serfdom, given the lack of other options for those without a college degree.”

Well I am sure that there will come a day, quite soon, when many with a college degree will deeply envy the income of plumbers, especially if these are serving the one percenters.

PS. This article strangely appears only in that FT’s Weekend Magazine I do not receive as a subscriber in Maryland, USA.


July 27, 2017

Current bank regulations also guarantee Canadian covered bonds will have more demand than Italian.

Sir, Thomas Hale while explaining the appetite for Canadian covered bonds quotes Michael Spies, a strategist at Citi with: “I’m buying a collateralised bank bond rated triple A, from a bank which is rated double A, in a country which is rated triple A,” he adds. “Now let’s put this together and compare it to an Italian covered bond.” “Canada’s housing rally owes a debt to Europe” July 12

That is not the whole story. Those Canadian covered bonds can, as a consequence of the risk weighted capital requirements, be held by banks against less capital than those “risky” Italian ones; and so therefore the banks can multiply their equity with more Canadian net risk margins than with Italian; and so banks will earn higher expected risk adjusted returns on equity with the Canadian than with the Italian; and so the Canadian covered bonds, when compared to the Italian, will have more demand than these would have had in the absence of the risk-weighting, and the Italian less.

That the distortion in the allocation of bank credit to the real economy the risk-weighted capital requirements for banks cause is not more discussed, is one of the great mysteries of our times.

PS. I was kindly informed of that "The risk weighting for a highly rated Italian covered bond is actually significantly lower (10%) than for a Canadian covered bond of the same rating (20%). This is because the European legislation (CRR) affords preferential treatment to issuers in the European Economic Area." I did not know that, but it sure makes me question whether Canada is aware of that it is subjected to this kind of European regulatory protectionism. 


Are those who impose regulations that create generous incentives for these to be gamed entirely without blame?

Sir, Brooke Master while discussing regulations for carmakers and banks refers to “mis-sold mortgage-backed securities and payment protection insurance” “The diesel scandal echoes bankers’ woes” July 27.

The regulators, with Basel II of 2004, allowed banks to leverage 62.5 times if a AAA to AA rating was present… while for instance only 12.5 times if there was no credit rating. That temptation set up the banks to, sooner or later fall into a trap. Are these regulators innocent?

In the same vein carbon emission controllers set up procedures that evidently could easily be cheated on. Are these controllers also entirely innocent?

I ask these questions because from what we have seen neither regulators nor controllers have been demoted, on the contrary, at least with respect to banks many, like Mario Draghi and Stefan Ingves, have been promoted.

Had the credit-rated-risk-weighted capital requirements for banks that distort the allocation of credit to the real economy not been introduced, the 2007/08 crisis and the ensuing slow growth would not have happened.

If a country decides to impose a 1.000% tax on liquor, does it not have any responsibility in that its citizens (including its legislators and tax collectors) start smuggling liquor?


Sadly Bolivar did not free Venezuela from its natural resource curse

Sir, Gideon Long writes about the immense significance Simon Bolívar has for all Venezuelans. “Bitter enemies invoke spirit of Bolívar as vote looms” July 27.

As a Venezuelan I can only agree with most of it but, unfortunately, in October of 1829, Bolivar ordered the continuance of what had been decreed in 1783 by Carlos III of Spain, namely that all precious metals and “juices of the earth” reserves belonged to the Republic.

With that Bolivar guaranteed the Venezuelan governments would not depend exclusively on the citizens and that, sooner or later, some would capture the government to steal it blind.

If we Venezuelans are to gain real independence all our net oil revenues have to be shared out entirely to the citizens.

Had that been achieved earlier, the current disaster would not have had a chance to happen.

It is a great tragedy that freeing Venezuela from the curse of centralized oil revenues is still not on the agenda of anyone the most important opposition leaders.


July 23, 2017

Like social bonds’ growth the antisocial bonds’ seem also to be doing fine

Sir, Kate Allen writes: “a host of other financial products have begun to emerge, promising to tackle social issues including homelessness, access to education, clean water, crime prevention and helping disadvantaged children…. The market is still small — just $3.5bn of social bonds were issued in the second quarter of 2017” “Ethical investing branches out from green roots” July 18.

And small it might really be when comparing to all of the antisocial financing that goes around. As an example just in that quarter the Maduro government of Venezuela, that one who is publicly and notoriously violating human rights and has its people starving and dying because of lack of food and medicines, sold $2.8bn in bonds. These antisocial bonds were initially picked up for a mere $800 million by a “with those possible returns, why should we give a shit about ethics”' Goldman Sachs.

Allen points out the fact that “The [social] bonds must perform socially as well as financially.” Yes, and if they don’t perform socially, as is clearly the case with Venezuela, then they should not perform well financially either. The Western civilization has an obligation to put a stop to odious anti-social financing. Otherwise our heirs will end up having to refer to that civilization as a once was.

Hopefully we will see an important socialite publicly disinviting a seemingly totally unrepentent Lloyd Blankfein from an important social event, because of Venezuela.

PS. I wonder how much $ in bonuses Blankfein will receive from this operation.


July 22, 2017

FT, you have a fake understanding on what is wrong with current bank regulations, and you have silenced my real one

Sir, Gillian Tett, your US Managing Editor, referring to the responses to an article by her titled “Why a divided America has united against the media”, July 14, strangely published only in that FT Weekend Magazine I do not receive here in Washington D.C. writes: “Readers and viewers say they want the media to be “less biased” and to “focus on the facts” but the problem of how to finance and organise serious non-partisan journalism for the mass market remains largely unsolved. The trouble is that partisan social media is free – and readers seem to be hungry for this. So how can we support real news when most voters keep flocking to entertaining stories that are (at best) partisan and (at worst) deliberately fake?” “Want to change the media? Don’t get mad – get even”, also solely in FT Weekend Magazine, July 22. 

The following is a very brief version of my relation with FT, as an opinionated subscriber.

FT and its columnists, with relation to banks’ crisis and regulations, have consistently written about deregulation and excessive risk-taking.

I on the other hand and in that respect, have with over 2.500 letters to FT consistently written to FT about misregulation and excessive risk-aversion; which results in dangerous excessive exposures against too little capital to what is ex ante perceived as safe, like sovereigns, the AAArisktocracy and residential housing, but could ex-post be very risky; and too little exposures to what is ex ante perceived as risky, like SMEs and entrepreneurs.

As one of the frontlines on this issue of the risk-weighted capital requirements for banks we find that in Basel II regulators assigned a risk-weight of only 20% to what is rated AAA to AA, and that which therefore could be very dangerous, and 150% to what is rated below BB- and that by just that fact alone is ex-ante made so innocuous to the banking system.

In one sentence, regulators regulate the banks based on the ex ante perceived risk of the banks assets, and not based on the risk ex post of the assets for the banking system.

And my criticisms have included many other aspects… like for instance the runaway statism present in the risk weights of Sovereign 0% and citizens 100%.

But for soon a decade, my arguments have been met with absolute silence, because as one of you informed me, I was just obsessed with the issue. Sir, I am reporting on a regulatory bomb that is destroying the future economy for our grandchildren, and you really don’t want me to be obsessed?

Now Tett, one of the frequent recipients of my comments writes: “the next time you complain about the media, ask yourself how you expect “fair” mass-market journalism to be funded and run – and if you are willing to pay for it. That question doesn’t let journalists off the hook: we writers need to dignify our craft. But building a better media is a task that involves journalists and non-journalists alike. Being angry is not enough; we need solutions.”

Sir, it is quite worrisome to read “Without fear and without favour” FT’s Tett confessing to “commercial pressures that are increasingly encouraging private sector media outlets to be more partisan”. Have you informed your shareholders about this? I would see it the other way, the more fakes and partisanship there is in the media, the more valuable do bastions of truth and diversity become. Or not?

Shaming out fakes and partisans must also be part of societies responsibility. For instance I have started to look for a collaborator to write a book tentatively titled “Me, Subprime Banking Regulations and FT”


July 20, 2017

Where would China be if western world had not placed a reverse mortgage on their economies, in order to keep on buying?

Sir, with interest I have read Martin Wolf’s “How the developed world lost its edge” July 20. In my opinion Wolf ignores two major events that had these not happened would have radically changed the current outlook.

First, regulators told banks: “Go out in the market and negotiate the best risk-adjusted net margins you can. And then, in order to make sure you do not take risks, we will allow you to multiply these margins much more in the case of assets perceived as safe than in the case of risky assets.”

That of course led to the accumulation of excessive exposures and against very little capital (equity), to something ex ante perceived decreed of concocted as safe, like AAA rated securities and sovereigns, which when ex-post turning out very risky caused the 2008-crisis.

And then central banks, with their QEs and ultralow interest rates, hindered the necessary market cleanup, and kicked the 2008-crisis can down the road, a road made unproductive by previous mentioned regulatory risk aversion.

So what resulted? No adjustment and further indebtedness, which allowed prices of assets to increase and demand (among other of Chinese production) to be sustained… further allowing the Chinese to save. 

Wolf writes: “The rapid growth of both trade and cross-border financial assets and liabilities and trade, relative to global output, has come to a halt. In the case of finance, plausible explanations are risk-aversion and re-regulation”. “Risk-aversion”? Yes, but not any new one but that which result from regulators loading up, on top of bankers’ natural risk aversion, there own aversion based on the same perceived risks. The bankers lend you the umbrella when the sun shine’s Mark Twain, would never have believed his eyes had he seen such regulatory nonsense.

Sir, as I’ve written to you many times before, never ever has a generation taken on so much debt to finance their own consumption, and shown so little respect for the needs of future generations, those needs that include bankers lending to risky SMEs and entrepreneurs.

How can a Western world made great by taking risks, not lose its edge by avoiding it?

Wolf concludes with: “Rising populist pressure across the high-income economies makes managing these shifts far more difficult.” Indeed, but let us not forget that this mess began when some truly inept populist technocrats, like real life Chauncey Gardiners, convinced governments they knew what they we doing.

PS. Martin Wolf also fell for it.


July 19, 2017

World Bank has thrown a very timely and important spanner into the works on how to combat climate change

Sir, Henry Sanderson reports on a report of World Bank that states: “Technologies needed to meet the Paris climate agreement from wind, solar and electricity systems are “more material-intensive” than current fossil-fuel supply systems, a report by the bank says.

The mining or extraction of metals and rare earth elements could create environmental problems in terms of energy, water and land use” “World Bank flags up renewables resource risks” July 18.

This makes of Trump’s refusal to play along with the Paris Agreement, a truly minor event. That the reports comes up only now, further evidences how green-business’ interests is skewing the whole debate. I have for years held that if our fight for saving the environment is planned or commandeered by profiteers, we are toast.

If the world adopts a revenue neutral carbon tax the resulting price signals will not only reduce the demand for carbon containing energies but will also allow for a more efficient allocation of resources. 


Not just China needs to allocate capital to the more productive, dynamic and employment-generating parts of the economy

Sir, Eswar Prasad, a professor at Cornell University and senior fellow at the Brookings Institution, writes: “Fixing the financial system is not just about managing risks and avoiding disaster, but also about allocating capital to the more productive, dynamic and employment-generating parts of the economy.”, “How to fix China’s unstable financial system” July 19.

How do you do that, not only in China but everywhere, with bank regulators who do not care one iota about the efficient allocation of credit to the real economy, but only about banks avoiding what is perceived as risky?

Especially since 2004’s Basel II, banks have been allowed to multiply their capital with many times more the net risk-adjusted margins when investing in something “safe”, like the past and the present, like sovereigns, the AAArisktocracy and residential houses, than when investing in something “riskier”, like the future, like SMEs and entrepreneurs.

That has completely distorted credit allocation and for no particularly good reason, since there is never ever major bank crisis that result from excessive exposures to something ex ante perceived as risky when placed on banks’ balance sheets.


Those profiteering on the employed, moneywise or politically, make us ignore, to our peril, the unemployed.

Sir, Kiran Stacey and Anna Nicolaou report on “Emerging nations in South Asia and beyond are pinning their development hopes on creating millions of low-paid manufacturing jobs over the next decade. Advances in automation threaten to derail the plan.”, “Stitched up by robots”, July 18.

And Rajiv Kumar an economist and founder of the Pahle India Foundation says: “Robotics and artificial intelligence are the next revolution. They are going to be more disruptive than any of the revolutions we have seen in the past — steam, electricity, the assembly line or computers — because they are going to replace not just routine but complex mental functions. The fear is that our so-called demographic dividend could become a demographic nightmare.”

Absolutely! In 2003 I already wrote about the possible need for sitting around in a great human circle, scratching each other backs, and paying good money for the service

And in 2012, more desperate, I called out that “We need worthy and decent unemployments

Currently there are too much resources wasted, dedicated to trying to generate employments, and too little trying to make unemployment socially livable. Why? Might it be because the employed have more resources with which to pay their defenders?

We must do something, perhaps like a universal basic income, before social order breaks down. Reconstructing social order is so much harder. I as a Venezuelan should know.


July 16, 2017

Had our current bank regulators been instructed by robots, we might not be in this mess

Sir I refer to Jeevan Vasagar’s “My first robot” July 13.

Why do I argue the possibility indicated in the title? Because perhaps robots could have been able to help their students to shake off sentimentalities and primal emotions a bit more, and taught for instance our regulators that what is risky for banks, is not what they also intuitively could feel to be risky to our banks, but quite the opposite.

What is fervently believed safe, like something with an AAA rating, is what can cause banks to generate excessive and dangerous exposures; on the contrary, what is believed risky, as something rated below BB-, is what bankers won’t touch with a ten feet pole.

But what did the regulators educated by humans do? In Basel II they assigned a risk weight of 20% to what is AAA rated, and one of 150% to the below BB- rated.

And so we would not ended up with a 2007-08 crisis caused by an excessive exposure to AAA rated bonds and sovereigns like Greece; and we would not be suffering a slow response to all QE and low interest stimuli, caused by the lack of loans to “risky” SMEs and entrepreneurs.


Brexit should be an affair between Europeans, not between some EU technocrats resenting a love spat.

Sir, I refer to Robert Shrimsley’s ironizing “Your country needs you: Brexit’s patriot act” July 15. There he writes: “Fox has said some journalists would rather see Britain fail than Brexit succeed”.

Well so do I! When I read so many opinions in FT stating categorically that Britain EU has much more to lose from Brexit than EU without acknowledging EU’s huge and delicate Brexit problems; when I see no one trying to capture the support of Britain that undoubtedly exists among Europeans; when I see no one wanting to go out and ask what kind of punishment they want the not so popular, the not elected by vote executioner Barnier to enforce on Britain, I do feel that most of you have an existential necessity of the Brexit affair turning out real bad for your country… or a shameful lack of willingness to defend what is yours, meaning not only Britain but also Britain’s future relation with Europe.

Can you imagine Britain during World War II communicating solely with the Vichy government of France and not reaching to La Résistance?

The Brexit morning after do you think Europeans want to see Britain gone for good? I doubt that, Britain is much more part of the glue that holds EU together than you seem to want to know.

Per Kurowski

A Venezuelan but also a Polish citizen, and therefore a European who is strongly in favor of Britain… though I admit the last could just be the result of not being up to date.


July 15, 2017

High house prices, besides a function of low interest rates, is a function of senseless bank regulatory favoritism

Sir, You write: “With or without a price crash, [resulting from interest rates rising] thinking about real estate must change… A house is not, after all, a productive asset. It is a shelter.”, “When property becomes a roof and a floor again”, July 15.

With Basel II regulators allowed banks, when financing residential houses, to multiply their capital with 35.7 times the net risk adjusted margin, in order to obtain their return on equity. When lending to an unrated SME or entrepreneur, those who could help create new jobs, banks were only allowed to multiply that same margin 12.5 times.

The only reason for that senseless distortion was and is that regulators, as did and do the banks, considered financing houses something much safer than financing some risky enterprises. 

Sir, compared to the case in which such regulatory differences did not exist, what gets much more credit than it should, and what much less? Or are you among those naïve enough to believe bankers have a responsibility, for the good of society, to overlook such skewed incentive structure?

Extrapolates that, and the logical result is the future, we would all end up sitting in ample homey shelters, but with no jobs to be able to pay mortgages, utilities or food.

Sir, such is the short-termism of regulators you have cared nothing about to understand and denounce. On the contrary, you have dedicated yourself to silence my warnings.

PS. By the way if an AAA rating was present, like in the AAA rated securities backed with mortgages to the subprime sector, banks could multiply that margin by 62.5.

PS. Where do you think fiscal sustainability is heading if house prices crash and much property tax revenues vanishes?