February 17, 2019

If only regulators had analyzed their risk weighted capital requirements for banks in terms of bets.

Sir, Tim Harford refers to Nassim Taleb, warning of “the ‘ludic fallacy’ — treating the unknown risks of life as though they were the known risks of a game of chance”, “Experimental living beats thinking in bets” February 17.

That is somewhat like when regulators treated the unknown risks in banking and set their risk weighted capital requirements. 

Harford also mentions Annie Duke’s recommendation “that we should always be willing to ask ourselves, ‘do I want to bet on that’ — it’s easy to be overconfident if there are no obvious consequences for being wrong. A bet forces us to think about the odds and the possibility that someone else may know better.”

Oh, if only our bank regulators have asked themselves: “Do we want to bet our bank systems on that what gets an AAA to AA rating, issued by human fallible credit rating agencies, is so safe we should only need to require banks to hold 1.6% in capital against such assets and so allow them to leverage 62.5 times with these?” Had they posed that question, the crisis resulting from excessive exposures to AAA rated securities backed with mortgages to the subprime sector would not have happened.

“We have risk-weighted the capital requirements for banks in order to make our bank system safer.” Someone has either played tricks on them or they are bluffing. The sad part is that so few dare to call them out on it. And, when I do that, many just brush me off with a “he’s just got an obsession”.

Though Harford accepts that “Thinking in bets is a rigorous and admirable habit” for many cases he favors “Thinking in experiments [as that] allows us to learn [and might be] less painful.

In case of bank regulations experiments are not needed. Just go out and look at all the crises and try to find one that was caused by excessive exposures to something perceived as risky when placed on the balance sheets of banks. None! Should that not tell you something about our unwillingness to learn when the lessons are hard to swallow? 

Sir, using Edward Thorp’s real casino risks, in banking, the Basel Committee represents “the crooked dealer” and the risk weighted capital requirements “the poisoned coffee” 

Casino games, like roulette, are all based on offering all possible bets exactly the same expected payout adjusted for their respective probabilities. If it was not so, no casino would survive. So it was in banking, until risk weighted capital requirements offered banks higher risk adjusted return on equity for what was perceived, decreed or concocted as safe (betting on a color), than for what was perceived as risky (betting on a single number). The consequence? Our bank systems will fail especially bad, by building up especially large exposures to what is especially perceived as safe, against especially little capital. The 2008 crisis, and Greece, were just canaries in that mine.

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

@PerKurowski