The regulators, by helping bankers have their wet dreams come true, worsened our young’s future perspectives.

Sir, Martin Sandbu writes: “The giants of the US asset management industry have held secret meetings since August to discuss how to push company executives to make more long-term decisions. Participants included veteran investor Warren Buffett, JPMorgan CEO Jamie Dimon, and leaders from Blackrock, Fidelity and other major managed fund providers.”, “From boardroom to Shangri-La”, February 20.

And Sandbu refers to: “Negative externality” is the economist’s term for the harm a company’s activities cause to the world around it… lobbying for government rules that privilege one sector over others may, in the longer term, make the rest of the economy less efficient. Indeed and there are no better examples of that that current bank regulations.

Mark Twain is rumored to have said: “A banker is a fellow who lends you his umbrella when the sun is shining, but wants it back the minute it begins to rain.”

And with their risk weighted capital requirements of banks, the current regulators added “A banker is a fellow authorized to leverage equity immensely much more when lending out his umbrella when the sun is shining, than when it seems it looks like it could rain.”

And with that banks have now realized their wet dreams of earning much higher risk adjusted returns on equity when lending to the safe than when lending to the risky, like SMEs and entrepreneurs; and with that banks no longer finance the risky future, they only refinance the safer past.

And all for nothing since major crises are never ever the result of excessive exposures to something ex ante perceived as risky, always of something ex ante perceived as safe but that ex post turned out to be risky.

Sandbu also refers to that Yngve Slyngstad, the head of Norges Bank Investment Management stated that “Norway’s sovereign wealth fund demands that boards pay particular attention to climate change, water management and child labour”

Though I generally believe it arrogant and dangerous to intervene in the markets, if Mr Slyngstad really wanted to help, he should then better support purpose weighted capital requirements for banks. Those would allow for higher risk adjusted returns on bank equity when financing something society finds has special merits… like water management and creating jobs for our young ones.

@PerKurowski ©

The regulators’ search for financial stability has distorted the allocation of bank credit to the real economy.

Sir, you hold “G20 governments would do well to recognize that financial instability can rapidly translate into trouble for the real economy.” “Central banks alone cannot conjure growth” February 20

Sir, you should know by now the regulators’ search for financial stability, has already created much trouble for real economy.

You quote Zhou Xiaochuan, governor of the People’s Bank of China, with “The central bank is neither God nor a magician who can turn uncertainties into certainties.”

The correct reply to that would be: So why then do central banks, as regulators, act like God or magicians arrogantly imposing their besserwisser founded credit risk weighted capital requirements for banks?

If you allow banks to leverage more their equity (and the support they receive from society/taxpayers) with assets ex ante perceived as safe, than with assets perceived as risky; then what is perceived or deemed to be “safe” will produce higher risk adjusted returns on equity than what is “risky”.

And anyone who does not understand how that distorts the allocation of bank credit on Main Street, has never walked on Main Street; has never seen how difficult it is for SMEs and entrepreneurs to access bank credit even without the regulators making that harder for them.

And if you do not understand how useless such distortion is, because major bank crises never ever result from excessive exposures to something ex ante perceived as risky, then you have not read financial history.

Who authorized bank regulators to decide on the allocation of bank credit to the real economy?

Or is it really so bad that banks regulators are not even aware of that they distort the allocation of bank credit to the real economy?

PS. In 1999 in an Op-Ed 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”

@PerKurowski ©

For credit we now might need shadow-banks. For intellectual capital free from network incest, do we need shadow-universities?

Sir, Martin Wolf writes: “In its origins and still today, a university is a special institution: a community of teachers and scholars. Its purpose is to generate and impart understanding, from generation to generation. The university is a glory of our civilization.” “Running a university is not like selling baked beans”, February 19

Indeed but from this perspective does it really follow that “Four of the 10 top-rated universities in the world, five of the top 20 and 10 of the top 50 are British” makes UK a “superpower” in higher education? Could not the truth be that in much all universities everywhere are failing and need to be rethought?

For instance, how much of our universities is being used not to promote understanding but to self-promote those who understand? Current research clearly seems to suffer from cronyism: “I Reference You and You Reference Me”? And, excessive cross-referencing within small mutual admiration networks cannot produce much good.

Also, what university in the UK, or anywhere else for that matter, have really debated something so fundamentally important as bank regulations that could be fatally distorting the allocation of bank credit to the real economy? And where is the university that has questioned the whole (nutty) concept of a zero risk weight for the sovereign and a 100 percent risk weight for the private sector?

The Department for Business, Innovation and Skills, in a discussion document titled “Fulfilling our Potential”, presents the idea to “open up the [university] sector to greater competition from new high-quality providers”. And Martin Wolf expresses some well-founded concerns about that.

Banks are currently, because of regulatory risk-aversion, kept away from fulfilling adequately their most fundamental role in the economy. In this respect I have often said that our next generations might find among some shadow-banks their best chance to finance the risky future.

And so, in the same vein, who knows if not our best chances “to generate and impart understanding, from generation to generation” could be found among some new formal university competitors, or even among some shadow-universities?

@PerKurowski ©

Does BoE’s core mission not include assuring bank credit is allocated as efficiently as possible to the real economy?

Sir, I refer to the letter written by Andrew Bailey and Sir Jon Cunliffe of the Bank of England titled “Proposals designed to fulfill BoE’s core mission”.

“They write “BoE’s proposals about the appropriate capital requirements for the UK’s banks are the product of two years of careful reflection and stress-testing, and are designed to fulfil our core mission of making the banking system safe and sound.”

But then we read about equity requirements expressed as percentages of “risk-weighted assets” and I must again ask the following:

Is not also part of the core mission of BoE assuring that bank credit is allocated as efficiently as possible to the real economy? I ask this because risk weighted capital requirements, by allowing banks to earn higher risk adjusted returns on equity on assets ex ante perceived as safe than on risky assets, distorts horrendously the allocation of bank credit to the real economy.

And by the way, by distorting that credit allocation they will make the real economy unsound and thereby, sooner or later, also threaten the safety of the banking system.

And by the way, just as an aide memoire, I remind them of that no major bank crisis ever result from what is ex ante perceived as risky, these are always the consequences of excessive exposure to something that ex ante was perceived as safe but that ex post turned out to be risky.

@PerKurowski ©

The blindness of Financial Times (FT) to the most dangerous bank regulation blunder of all times is mindboggling

Sir I refer to your “Simplicity is the key to a resilient banking regime” February 17.

Therein you write about the need to “ensure that lenders have clear capacity, primarily in the form of equity capital, to absorb large losses if a crisis hits. Of course, this is a balancing act: regulators must weigh the benefits of more resilient banks against the higher costs of equity funding, which are likely to result in slightly higher borrowing costs in the real economy, constraining household and business borrowing.”

There it is, right in front of you. You accept that the level of bank equity carries costs, but yet you refuse to acknowledge that different levels of required equity for different borrowers, those which result from the risk weighted capital requirements, distorts the allocation of bank credit to the real economy. Why?

Also when you specifically mention that more bank capital would constrain “household and business borrowing.” you are ignoring that these “risky” borrowers are already much more constrained by the regulatory advantages awarded to other “safe” borrowers like sovereigns, the AAArisktocracy and housing finance.

You are absolutely correct in that “Setting the level of equity banks should hold is a judgment call” but, setting different levels of equity based on perceived risks already cleared for by banks, is a call that just shows a total lack of judgment.

And, to top it up, the current risk weighted capital requirements for banks only guarantee that when what ex ante has been perceived as very safe ex post turns out to be very risky, that banks will stand there very naked because of having especially little to cover themselves up with.

PS. Sir I don’t refer here to the discussion between John Vickers and Bank of England (Mark Carney), since for all practical purposes they are just as blind as you Sir.

@PerKurowski ©

It would be helpful if Martin Wolf finally realizes the dangers the risk weighted capital requirements for banks pose.

Sir, now, more than 12 years after Basel II was approved Martin Wolf writes: “If one ignores the vanishing trick of risk-weighting, the true leverage of many large banks remains at more than 20 to one.” “Banks are weak links in the economic chain” February 17.

But, of course, the real question though is, why have regulators ignored the dangers “the vanishing trick of risk-weighting” poses? Not only can that risk weighting that was envisioned to provide better and more comparable information on banks confound the markets more; it also provides banks with an versatile instrument to game the regulations; and, worst of all, it distorts the allocation of bank credit to the economy.

On that last, the distortion, Wolf might at long last begin to wake up as he writes: “Banks are highly leveraged plays on economies. If economies are sick, banks are likely to be sicker.” So now let us hope that from that he could deduct that the way bank credit is allocated to the real economy carries real significance to the health of the economies and the banks.

And then, Hallelujah, Martin Wolf finally accepts “that banks are exposed to almost everything”. That should allow him to understand the idiocy of re-weighing for basically the only risk that banks with interest rates and amounts of exposure already clear for, while leaving the whole universe of other risks a bank faces out of the regulatory equation.

Sir, as you well know by now I will with much interest follow where Wolf goes to now because it would of course be very useful if the leading economic commentator of the Financial Times opened his eyes to what has and is really happening with our banks.

Currently, by regulators allowing banks to earn higher risk adjusted returns on equity financing on what is perceived or deemed as safe than on what is perceived as risky, banks have stopped financing the riskier future and settled on refinancing the safer past… and that cannot be good for anyone, least so for our children and grandchildren.

And of course, all for nothing because major bank crisis never ever result from excessive exposures to something ex ante perceived as risky.

@PerKurowski ©

ECB, Mario Draghi, before bank regulation distortions are eliminated, should not be allowed to waste any more in QEs

Sir, James Shotter reports that Mario Draghi, “the ECB president, said the central bank would pay close attention to the impact of the recent falls in oil and commodities prices, as well as the ability of banks to pass on the ECB’s monetary policy” “Draghi’s speech hints at further stimulus measures for the Eurozone” February 16.

Mario Draghi, as the former chair of the Financial Stability Board must know that the risk weighted capital requirements for banks, dramatically distorts the allocation of bank credit to the real economy, which impedes banks to pass on efficiently any stimulus measures. And, if Draghi does not yet know that, it’s even worse.

Shotter also refers to Draghi opining that reforms since the financial crisis had boosted the resilience, “not only of individual institutions but also of the financial system as a whole”, and presenting as evidence “that the Eurozone’s banks had boosted their core tier one capital ratios — a key measure of financial strength — from 9 per cent to 13 per cent.”

And Draghi must know that it most surely is the result of banks shedding or swapping assets against which they are required to hold a lot of capital, like loans to SMEs and entrepreneurs, for assets against which they are allowed to hold much less capital. And therefore that strengthening could be absolutely meaningless for banks, or even increase the systemic risk in the banking system; as well as a great source of weakness for the economy. And, if Draghi does not yet know that, it’s even worse.

ECB, Mario Draghi, before bank regulation distortions are eliminated, should not be allowed to waste any more in QEs or other similar stimulus.

One could also ask, how long Europe will stand for having financial authorities that, demonstratively, are not up to the task?

@PerKurowski ©

What bank regulators do not yet understand and do not yet discuss, is truly scary stuff

Sir, John Vickers who chaired the Independent Commission on Banking (ICB) writes: “A central lesson of the crisis of 2008 was that banks had woefully inadequate equity capital” “The Bank of England must think again on systemic risk” February 15.

That is dangerously imprecise! The central lesson of the crisis was that banks had woefully little capital against assets that had ex ante been perceived or deemed very safe as a result of woefully wrong regulations.

The regulators allowed banks to hold much less equity against safe assets; which allowed banks to leverage much more their equity with safe assets; and which allowed banks to earn higher risk adjusted returns on equity on safe assets than on risky assets.

And the fact that regulators are still not able to comprehend that it is not their role to regulate based on what assets a bank has, but based on how banks manage those assets, is just scary.

And the fact that regulators are still not able to digest the truth that the assets that are really dangerous to the stability of the banking system are not the risky but those perceived as safe, is just scary.

And the fact that the distortions in the allocation of bank credit to the real economy that risk weighted capital requirements produces are not yet even discussed, is just scary.

@PerKurowski ©

Even though there is hunger, could Venezuela be servicing religiously its debt because of who the bondholders are?

Sir, even though Venezuela is suffering lack of food and medicines, it is doing all it can to pay its foreign bondholders. Andres Schipani quotes Bank of America’s Francisco Rodriguez in that “Venezuela could continue paying bondholders for longer than it keeps paying Maduro’s salary”, “Maduro’s Venezuela on the brink of default" February 12.

Could it be that all these bondholders are in fact the same usual local friends of the government and who in these bonds have just found another way to further exploit this poor-rich country? I mean it is hard to visualize any ordinary reasonably responsible investor, no matter how big the spreads, putting money in Venezuelan bonds while knowing without doubt that the resources raised by debt will be wasted just the same way as the greatest oil-boom in history has been wasted.

The world needs a sovereign debt restructuring mechanism (SDRM) but, for that to serve us citizens any useful purpose, and not even be counterproductive, it must begin by establishing clearly the differences between bona fide lending and odious credit.

@PerKurowski ©

The CET1 (common equity tier 1) divided by the leverage ratio, gives you a Gross Risk Hiding Ratio

Sir, James Shotter and Laura Noonan, while admitting that “the absolute level of the CET1 (common equity tier 1) is only part of the equation, they do compare Deutsche Bank’s CET1 with that of other banks. “Deutsche focus turns to towering task ahead.” February 10.

The common equity tier 1 ratio is calculated with the bank’s core equity in the numerator and with in the denominator the risk weighted assets, calculated with risk weights not assigned by me. So the safer the assets are perceived or deemed to be, the higher the CET1.

And the Leverage Ratio uses in the denominator the gross value (of most) assets.

As FT should know by now, I have always felt much more nervous about the assets a bank (or regulators) could perceive as very safe than with assets perceived as risky. And so I do give more importance to the leverage ratio than, for instance, to the CET1 ratio.

But the regulators would not allow us data on the leverage ratio, because, in their opinion, that would not reveal the real leverage to us and it would therefore only confuse us. And so they decided to credit-risk weigh the assets, and came up with the CET1 ratio or the slightly more generous Tier 1 Common Capital Ratio.

And of course that made many in the market feel much more comfortable with that the banks were quite adequately capitalized.

But one needs to adapt, and so I felt that new interesting ratios would be found in the market whenever the leverage ratio was published. And among these the CET1 ratio to the leverage ratio-ratio, because that ratio could be said to represent, the Gross Hiding Risk Ratio.

Though I admit I could be using wrong data, I found the following leverage ratios at end of 4th quarter 2015: Deutsche Bank 3.9; Goldman Sachs 5.9; Wells Fargo 8.0; and Morgan Stanley 8.3.

And if we take the CET1 ratios reported in the article and divide these by the leverage ratios we obtain the following Gross Risk Hiding Ratios: Deutsche Bank 2.85; Goldman Sachs 2.19; Wells Fargo 1.34 and Morgan Stanley 1.70

So if these calculations are correct then no wonder why Wells Fargo “is often described as the US’s safest banks [and] there are no [current] calls for a capital raising”… and no wonder Deutsche Bank faces quite bigger challenges.

@PerKurowski ©

Rod Stewart, it would be hard for you to find your way back home, it has been castrated.

Sir, Martin Wolf opines: “The battle over Brexit matters to the world” February 10. But does that matter the most to Britain?

Rod Stewart in “Way Back Home” remembers his childhood with: “And we always kept the laughter and the smile upon our face. In that good-old-fashion British way with pride and faultless grace”

And his song ends with Winston Churchill reciting in the background: “We shall fight on the beaches. We shall fight on the landing grounds. We shall fight in the fields, and in the streets. We shall fight in the hills, we shall never surrender”

But Rod, for your info, Churchill’s England has indeed surrendered to risk aversion, thanks to its bank regulators.

In Britain the banking sector represented so much. And just to think about the reasoned and astute daring of their merchant banks should make any Britt proud.

But you have a Britain that now allows foreign bank regulators in the Basel Committee, to allow its banks to hold less equity against what is perceived as safe than against what is perceive as risky; and therefore Britain now allows its bankers to make higher expected risk adjusted profits when lending to “the safe” than when lending to “the risky”; which of course is de-testosteronizing, or outright castrating Britain’s banks.

Therefore much more important for Britain than a Brexit, is a Baselexit, which means ignoring all those regulators who ignore that: “A ship in harbor is safe, but that is not what ships are for.” John Augustus Shedd, 1850-1926

@PerKurowski ©

Were bank regulators sufficiently vetted, or did those who appointed them simply not understand what banks are for?

Sir, Laura Noonan writes: “Here lies the big bank that once loaned billions to local businesses, but is now unwilling and unable to support the economy. Fondly remembered by its risk-adverse managers and overzealous regulators, its passing is deeply regretted by local business owners. Rest in peace… Surveys from the Bank of England chart an almost uniform contraction of lending to UK businesses from banks and building societies in recent years”, “Challenger banks move to stand out from the crowd” February 9.

Was it really a case of “overzealous regulators”? No! It was a case of dumb regulators who allowed banks, depending on how the risk of an asset was perceived or deemed to be, to have different levels of capital (equity); and who thought that would not distort the allocation of bank credit to the real economy. Or, worse, did not care one iota about if that happened.

How many of you in FT have read Basel Committee’s 29 Core Principles for effective banking supervision? To read these, and to think about their implied regulatory arrogance, should cause anyone to ask whether someone has properly vetted these bank regulators, before they were assigned with the responsibility of writing the rules for all of our banks… or did not vet them because they did not want to admit they did not understand what was being argued?

We have recently read about the extraordinary self-created reputational extravagances of a Paolo Macchiarini, and how some uncritical acceptance of these is even questioning the committee of the Karolinska Institute of Sweden that selects the Nobel Prize for medicine.

After so many years, and so many unanswered questions about current bank regulations, I have all the reasons to suspect something equally terribly wrong could be happening in Basel.

Adam Cyralsky wrote about Paolo Macchiarini in ‘The Celebrity Surgeon Who Used Love, Money, and the Pope to Scam an NBC News Producer”, Vanity Fair January 2016.

And there Cyralsky, in order to understand how “someone of considerable stature could construct such elaborate tales and how he could seemingly make others believe them”, turns to Dr. Ronald Schouten, a Harvard professor who directs the Law and Psychiatry Service at Massachusetts General Hospital. The answer he gets is: “We’re taught from an early age that when something is too good to be true, it’s not true… And yet we ignore the signals. People’s critical judgment gets suspended. In this case, that happened at both the personal and institutional level.”

And I translate this to perhaps mean that when bank regulators said: “We can save you from banks failing” and backed it with something that sounded so reasonable as “more risk more capital and less risk less capital”, then the critical judgment of those who appointed them got suspended.

But the world can ill afford such suspension. The credit risk adverse regulations cause banks to finance less and less the risky future; and only refinancing more and more the “safer” past. That has to stop, for the good of our children and grandchildren.

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

@PerKurowski ©

“A free lunch?” That depends a lot on who is doing the cooking. The Basel Committee’s lunch is both expensive and bad

Sir, Lawrence Summers writes: “The strengthening of regulation reduces the incidence of financial crises, thus improving economic performance while promoting fairness by helping consumers.” “No free lunches but plenty of cheap ones” February 8.

That could happen, but please let us not confuse strengthening with dumbing.

Right now the pillar of bank regulations is the risk weighted capital requirements for banks; more ex ante perceived risk more capital – less ex ante perceived risk less capital.

That, by making the access to SMEs and entrepreneurs, “the risky”, more difficult than the one for “the safe”, sovereigns and AAArisktocracy, hardly promotes fairness, it actually promotes inequality, and neither does it help consumers in need of job opportunities.

But let us also not ignore that major bank crisis never result from excessive exposure to something that was ex ante perceived as risky, but always from excessive exposure to something ex ante perceived as safe but that ex post turned out to be very risky. And, in this respect, these regulations, allowing for too little capital when real shit hits the fan, also increase the severity of the really big financial crises.

“No free lunches?” Well as we can see that would also very much depend on who is doing the cooking, and of who are having lunch. Currently our bank regulators are serving us both a very expensive and lousy lunch. 

@PerKurowski ©

Tim Harford. Avoiding the risky and embracing the safe, is that a good New Year resolution for banks at the Basel gym?

Sir, Tim Harford, a self-declared undercover economist, writes about incentives in “How to keep your gym habit” February 6. It is very interesting but, as an economist writing for FT, he should perhaps be more interested in the incentives that guide the actions of our banks.

The regulators, by means of risk weighted capital requirements; which allow banks to leverage more with assets perceived or deemed safe than with assets perceived risky; which allow banks to earn higher expected risk adjusted returns on equity with assets perceived or deemed as safe than with assets perceived as risky; have created great incentives for banks to stay away from what’s “risky”, like the SMEs and entrepreneurs, and to embrace what’s “safe” like sovereigns, the AAArisktocracy and housing.

To me, also an economist, that would, in terms of a gym, indicate incentives for banks to stay away from anything that could break out a sweat; and in terms of a diet, to stick with chocolate cake and forget the spinach.

Short term everyone but “the risky” can love it; higher expected risk adjusted profits on what’s safe than on what’s risky sounds like a banker's wet dream. But, in the not so long run, that is clearly unsustainable and will cause a dangerous increase of obesity among banks and in the real economy. 

And so, in the particular case of banks, it is not that the incentives don’t work, it is the New Year resolution imposed on banks by the Basel Committee that is plain wrong.

@PerKurowski ©

With their credit risk weighted capital requirements for banks, regulators doomed our economies to obese growth.

Sir, you refer to growth in the US and hold that the “bearish case for the US rests on the travails in China, and events in the oil market, conspiring to expose “The small but serious threat of a US recession” February 6.

You, as you have done the last decades, simplistically suppose all economic growth is equal. But, the truth is we can have obese economic growth, based on carbohydrates, such a financing consumption, housing and refinancing the safer past; or we can have muscular economic growth, based on proteins, such as taking risks on SMEs and entrepreneurs. And guess which one of these is the sustainable growth?

Ever since regulators, with their credit risk weighted capital requirements, set the banks on a credit risk aversion path, all growth we have perceived has been of the not sustainable obese type.

So no! Whatever happens in China, or with the oil price, if the US, and Europe, insist on having the same failed bank regulators regulating their banks, their economies will go downhill more sooner than later.

You quote Bill Dudley, president of the New York Federal, as noting, in your face, “credit conditions have already tightened as risk aversion has caused a selloff of risky assets.

Dudley should be ashamed. As one of the regulatory community he must know that regulators, long time ago, de facto gave banks the incentives they needed to avoid creating “risky” assets. They made bankers’ wet dreams, that of making the highest expected risk adjusted profits when financing what was perceived as the safest, come true.

@PerKurowski ©

When financing art, should Old Masters be credit rated based on their value volatility?

Sir, I refer to John Dizard’s discussion of “the business of lending against art collateral”, “Art world may be struggling but lenders are still happy to rely on an Old Master” February 6.

Dizard writes about a “an avalanche of loan applications from Europe” but “the banks that made lending facilities available in the past are not doing so any more” because the banks “are under tremendous regulatory pressure. Every European bank is scrambling for sufficient capital.”

It is a very interesting article. But, sincerely, should FT not be much more concerned with all the financing of SMEs and entrepreneurs that is not happening in Europe for precisely the same reasons… namely that capital scarce banks are allowed to hold much less capital against assets ex ante perceived or deemed as safe?

That said… might there be room for credit rating of art? That could allow banks to hold less capital against some Old Master that possesses less value volatility. Or would that only incentivize the production of more AAA rated Leonardo Da Vinci fakes?

@PerKurowski ©

A Cloud should provide us with legally non-contestable statements of our investments, a nanosecond before a cyber-blackout.

Sir, I refer to Robin Wigglesworth “HFT chief warns of ‘hole’ in electronic system”, February 5.

Getting into the paperless, and the soon perhaps currency-less society, requires someone somehow to provide security for everyone… from the holder of a small savings account to the plutocrat with a billion-dollar portfolio.

I believe everyone would sleep better were they sure they had access to a legally non-contestable file that proved what assets they held since the last transaction recorded, and until that nanosecond before the horror of a blackout occurred.

Is that something a government should offer? They might contract it out, I don’t mind, but this is clearly among the security sovereigns should provide their citizens… although external auditing and extra guarantees would not be bad to have in the case of the so and so existing sovereigns… and in the case of the in waiting so and so sovereigns, which could, sooner or later, be all sovereigns.

@PerKurowski ©

How could central bankers, and Martin Wolf, convince us (me) they know what they are doing?

Sir, Martin Wolf asks: “What might central banks do if the next recession hits while interest rates were still far below pre-2008 levels?” And he answers, “the most important part of such preparation is to convince the public that they know what to do.” “Prepare for the next recession”, February 5.

Not an easy task. For example I have always felt more uneasy with what banks might ex ante consider safe, than with what they could perceive as risky. But regulators, with Basel II, introduced risk weighted capital requirements for banks in which they for instance assigned a risk weight of 150 percent to assets rated as ‘highly speculative’ below BB-, while only a meager 20 percent risk weight for ‘prime’ AAA rated assets.

That not only seriously distorted the allocation of bank credit to the real economy but also set up banks for, when any ex post credit risk realities could sink in, that they stand there with little equity to cover themselves up with.

But seemingly there is no way I can convince central bankers, regulators, or Martin Wolf, that is a dangerous nonsense and so, at least in my view, I am convinced they do not know what they are doing.

Wolf also comments on the notion that doing nothing, searching for a “cleansing depression” is “crazy, given the damage it would do to the social fabric”. I am not sure. In August 2006, FT, before I was censored, published a letter I wrote titled “Long term benefits of a hard landing” and nothing about the many efforts to achieve a soft landing I have seen, have really made me change my mind.

@PerKurowski ©

Redistribution profiteers who committed economic crimes against humanity sequestered Venezuela

Sir, I refer to Ricardo Hausmann’s sadly true “It could be too late to avoid catastrophe in Venezuela” February 4.

These days when so much is said about fighting inequality, Venezuela is a tragic example of what happens when a country falls into the hands of shameless redistribution profiteers. All countries need to develop more transparent government accounts that allows us them to measure the real costs of redistributing wealth.

For instance in the case of Venezuela the fact that the prices of petrol (gas) have not increased once since Chavez came to power 17 years ago has signified that just in free petrol the country has over the last years given away more than in all their other social programs put together… if that is not an economic crime against humanity (and environment) what is. I have tried to denounce it to the Organization of American States but they are more interested in conventional and traditional crimes against humanities.

Over the last 15 years the poor of Venezuela might not have received even 10 percent of the oil wealth that was redistributed… which would indicate a redistribution commission of 90 percent.

Clearly if other methods like direct oil revenue sharing with citizens had been used, the 10-90% figures here could have been 98-2%. And of course, had the oil revenues belonged to the citizens, the government could not have “used it to quadruple the foreign debt.”

Set into this context it is obvious that all should closely study experiments like Finland’s substituting with a basic monthly income for all the bureaucrats’ management of benefits.

PS. One of the most sad events in my lifetime has been when the US did not follow through on the idea of promoting oil revenue sharing in Iraq. Had it done so the whole middle east, and of course Venezuela, if following the example, could have been facing much better realities.

@PerKurowski ©

Former Executive Director at the World Bank, for Venezuela, 2002-04

Caring more about us, the targets, would go a long way to improve advertising efficiency on the web, and reduce fraud.

Sir, John Gapper describes some tip of icebergs in the word of online advertising “Regulators are failing to block fraudulent ads”, February 3.

But I also assume that those paying for the ads do not pay, or stop the advertising, if the ads fail to translate into profits.

We, the targets, we used to be hit with some few advertising bullets while reading a paper, looking at TV or listening to radio… now, on the web, more and more we are hit with thousand of ad pellets, which give very little consideration to the physical limits of our attention span. If the computer has a malware that keeps it reading ads while I sleep I don’t care… but when I sit there and try to use the web for its original purposes the ads are really getting into my way and into my nerves.

What could be done about it? I have suggested the advertisers, with the help of ad-blockers, take contact directly with us the targets. I am sure we could work something out. I my case I have offered to hire out my very scarce attention span for 30 seconds against the low price of US$ 1… initially!

@PerKurowski ©

But what if the elite does not possess the necessary qualifications to function as an elite?

Sir, it is interesting how Martin Wolf, as FT`s leading economic commentator a part of the elite, is able to distance himself from the elite in order to recommend to the elite what to do. “Bring the elites closer to the people” February 3.

Wolf suggest for example: “capitalism must be kept competitive… One response is to promote competition ruthlessly. This will require determined action”.

Indeed, but yet Wolf has steadfastly refused to object current bank regulations that clearly curtail, more than what is usual, the capacity of those perceived as “risky”, like SMEs and entrepreneurs, to compete for bank credit in fair terms.

During soon three decades the pillar of bank regulations have been the risk weighted capital requirements for banks. What kind of crazy elite could feel so empowered so as to dare introduce regulations that utterly distort the allocation of bank credit to the real economy? And, to top it up, base it on one of the few risks that are already cleared for by banks? And, to top it up, base it on the risk of the assets of the banks, and not on the risks that banks cannot manage the risk of their assets?

The regulators, in Basel II, set the risk weight for ‘prime’ AAA rated assets at 20 percent, and at 150 percent for ‘highly speculative’ below BB- rated assets. I just ask again, for the umpteenth time, what have we done to deserve regulators who believe that what is ex ante perceived as so risky is more dangerous to banks than what is perceived as so safe?

In Basel I they set the risk weight of sovereign at zero percent and that of the private sector at 100 percent. And I just ask again, for the umpteenth time, what have we done to deserve regulators who impose such statism through the backdoor?

Wolf writes: “The governance of complex modern societies requires technical knowledge” — and he mentions that a Republican candidate has been described as a “mountebank”. I don’t know about that but “mountebank”… charlatan, is a term quite applicable to the members of the bank regulatory elite… and to their little helpers and defenders.

Sir, an elite that acts like members of a mutual admiration club, is a totally useless elite. The elite, in order to fulfill its functions, needs to be able to socially sanction its members.

PS. At this moment, when clearly it is important to find ways to fight growing inequality, it is also the responsibility of the elite to make sure that endeavor is not commanded and carried out by some redistribution profiteers… which would just make it all much worse… as we Venezuelans can testify.

@PerKurowski ©

Regulators impede many who represent the driving force of capitalism from competing for bank credit in fair terms

Sir I refer to John Thornhill’s interesting discussion of organizations’ internal obstacles to competition and innovation “The path to enlightenment and profit starts inside the office” February 2.

Thornhill states “As the driving force of capitalism, competition gives companies a purpose, a mission and a sense of direction” but unfortunately “The incentive structures of many companies are to minimise risk rather than maximise opportunity. “Innovation is often a young company’s game.”

But let me pick up on that to remind you, for the umpteenth time, of the nasty consequences of current credit-risk-weighted capital requirements for banks. These allow banks to leverage more with exposures to the safe than on exposures to the risky; and so banks are therefore able to earn higher expected risk adjusted returns on equity when lending to the safe than when lending to the risky. And so the current regulatory incentives given to banks are set in order to minimize their exposure to any “risky” assets, rather than to maximize the opportunities that could easier result were banks free to allocate their credit to the real economy without distortions.

Thornhill mentions: “Innovation is often a young company’s game.” Yes and it is precisely “young companies” that usually are perceived as “risky” and are therefore now blocked from competing for access to bank credit in fair terms.

PS. Thornhill also refers to Herman Hesse’s “Knowledge can be communicated. Wisdom cannot.” In 2003, as an Executive Director of the World Bank, and in relation to the financial sector I wrote the following in a formal statement delivered at the Board:

“As the financial sector grows ever more sophisticated, making it less and less transparent and more difficult to understand for ordinary human beings, like EDs, it is of extreme importance that the World Bank remains prudently skeptical and vigilant, and not be carried away by the glamour of sophistication. In this particular sense, we truly believe that the World Bank has a role to play that is much more important than providing knowledge per-se and that is the role of looking on how to supply the wisdom-of-last-resort.”

Unfortunately, even though the World Bank is the world’s premier development bank, it has not yet explained to the world that risk-taking is the oxygen of any development.

@PerKurowski ©

At least Lucy Kellaway defends with honor the “Without fear and without favor” motto of the Financial Times

Sir, Lucy Kellaway does great living up to “Without fear and without favor” when she socially sanctions all the full of themselves experts, and those who socially suck up to these. Well done! “Boneheaded aphorisms from Davo’s windy summit.” February 1.

It is a real pity there are not many more like her at FT. The world could benefit a lot if the journalists at FT dared to, for instance, question more current bank regulators on what they are up to… like for instance with their zero risk weight to sovereigns and the 100 percent risk weight for that private sector that makes the sovereign strong.

@PerKurowski ©

“In a world where debt overhang holds growth back for years” what could happen to the safety of “safe assets”?

Sir, David Oakley writes about the possibility that “QE will only properly end when all the bonds purchased mature”. And “For fund managers, it means government bonds may have a more lasting appeal as yields remain lower for longer because of an underlying demand for safe assets in a world where the debt overhang holds growth back for years.” “We are the QE generation, and it is quite a burden” February 1.

But a more relevant question could be: “in a world where the debt overhang holds growth back for years” what could happen to the safety of those “safe assets”?

Here we are with central banks sitting on a great portion of sovereign bonds they cannot retire without affecting the market too much; while at the same time they fix the risk-weight of these bonds, for the purpose of the capital requirements for banks, at zero percent, while that of those who are the only ones who could help growth, the private sector, has a risk weight of 100 percent. Is that not an example of sheer human lunacy that has us begging urgently for some artificial intelligence to bail us out?

@PerKurowski ©

The central banks monetary policies are hampered more by distorting bank regulations than by bad communications.

Sir, I refer to your “Central banks struggle to make things clear”, January 30. In it you hold that the monetary policy is hampered by bad communications. No Sir, their monetary is hampered much more by bad bank regulations.

Central bankers are also commercial bank regulators. Just look at this list:

Mario Draghi of ECB and Mark Carney of BoE are the former and current chairs of the Financial Stability Board.

Jaime Caruana of BIS and Stefan Ingves of Sveriges Riksbank are the former and current chairs of the Basel Committee for Banking Supervision.

In such a role they have all for years supported credit risk weighted capital requirements for banks which indicate that ‘highly speculative’ below BB- rated assets are far more dangerous to the bank system than ‘prime’ AAA rated assets.

In Basel II the risk weight for ‘highly speculative’ below BB- rated assets is 150 percent while the risk weights for ‘prime’ AAA rated assets is a meager 20 percent.

And therefore according to Basel II banks need to hold 12 percent in capital (basically equity) against ‘highly speculative’ below BB- rated assets, while only 1.6 percent against ‘prime’ AAA rated assets. 7.5 times less!

Honestly, when have banks created excessive dangerous financial exposures to what ex ante is perceived as ‘highly speculative’? Have these all not been created around assets ex ante perceived as ‘prime’ but that ex post turned out risky?

But the stability of the banks is not the most important problem with those capital requirements. The real problem in that they completely distort the allocation of bank credit to the real economy and thereby nullify all central banker’s monetary policies.

Nothing but central bankers' self-inflicted damage!... for which we all suffer.

@PerKurowski ©

Martin Wolf, as elite, why have you not spoken out against lousy bank regulators and redistribution profiteers?

Sir, Martin Wolf cries out: “Elites have become detached from domestic loyalties and concerns, forming instead a global super-elite. It is not hard to see why ordinary people… are alienated. They are losers, at least relatively; they do not share equally in the gains… After the financial crisis and slow recovery in standards of living, they see elites as incompetent and predatory. The surprise is not that many are angry but that so many are not… Elites need to work out intelligent responses. It might already be too late to do so” “The losers are in revolt against the elites” January 27.

Of course Wolf is absolutely right… but that requires the elite to be willing to call out the truth, even when that truth hurt other in their mutual admiration club of elites.

For instance, how can the elite gather in a Davos WEF event, year after year, and not tell central bankers and banks regulators in their face, that it is outright stupid to distort the allocation of bank credit to the real economy, especially based on credit risks already cleared for by banks.

For instance, has Martin Wolf himself dared to ask Mark Carney, Mario Draghi, Jaime Caruana, Stefan Ingves about why they believe ‘highly speculative’ below BB- rated assets pose more dangers to the banking system than those ex ante perceived as ‘prime’ AAA rated?

And what about “The wealth of 62 richest equals that of 3.6 billion poorest” message sent out this year by some “NGOs” to all those in Davos. Who said anything there about that being a deviously false and odiously divisive statement?

I do not claim to belong to any elite, especially not the wealthy elite, but, as a father and a grandfather, I know we cannot sit still and not do anything about the growing inequalities, whether the local or the global.

But I also know that if we are going to do something effective about it, we cannot afford to keep failed bank regulators blocking opportunities, or fall into the traps of redistribution profiteers.

December 31, 2009, on the eve of the new decade, FT published a letter I sent titled “The monsters that thrive on hardship haunt my dreams” In it I basically shared and expressed the same concerns Martin Wolf is expressing now. What happened?

@PerKurowski ©

But why does FT’s John Kay not find it wrong when regulators restrict the competition for access to bank credit?

Sir, John Kay writes: “to restrict competition is to damage both the process of innovation and the public interest” “What the other John Kay taught Uber about innovation”, January 27.

Indeed but why does FT’s John Kay steadfastly refuse to apply the same criteria when regulators restrict the competition for access to bank credit?

Regulators tell banks: “You can leverage your equity, and the support we give you by for instance deposit insurance schemes, much more with the net risk adjusted margins paid by “The Safe”, than with the same margins paid by “The Risky”

And by that, regulators are de facto restricting the competition for bank credit for all those who ex ante are perceived as risky, like the SMEs and entrepreneurs.

And that also damages the process of innovation and the public interest.

@PerKurowski ©

The huge bonuses paid to bankers were enabled by lousy regulators, and were not the result of free market capitalism

Sir, John Plender writes: “Like the robber barons, today’s bonus-hungry bankers have shown once again how capitalists excel at giving capitalism a bad name”, “Capitalists excel at giving themselves a bad name” January 25.

No! Free market capitalism would never ever have enabled the payment of extraordinary high bonuses to bankers… because in free market capitalism banks would have had to hold much more equity than what banks currently hold, and so therefore not only would the risk adjusted returns on equity be lower than what has been seen, but there would also have been less left over for bankers’ bonuses.

With Basel II regulators allowed banks to hold extremely little capital (equity) against assets perceived as safe… for instance only 1.6 percent when lending to the AAArisktocracy. That allowed banks to leverage extraordinarily the explicit and implicit support given by society, for instance by deposit insurance schemes… while having to provide a decent return on very little equity… which left of course a lot of margin to pay the huge bonuses.

The real question is how come these extremely lousy regulators are getting away with what they did and are doing… having even been promoted for it.

@PerKurowski ©

Can journalists wash their hands about the (dis)empowering of citizens and of keeping failed elite in power?

Sir, Gillian Tett referring to “how the global elite converged on Davos this week” writes: “The most interesting issue revolves around something the WEF calls the “(dis)empowered citizen”. This arises because the internet makes voters feel more powerful than ever… The bitter irony is that although the internet gives people the impression they have a voice, in most countries power remains firmly with the elite.”, “The big illusion of empowerment for the masses”, January 22.

Tett holds “This creates disappointment and frustration: ordinary people have the illusion they are vocal. But although they use their mobile phones to exercise power over some issues, they cannot easily use them to change important issues such as politics.”

But, do journalists have no role to play in that? Are they not suppose to in many ways represent ordinary people in front of the elites?

For instance I do not call the Financial Times on the mobile phone (except perhaps when I will travel and suspend my subscription for a week or so) but I have sent thousand of letters to FT, including to Ms. Tett on issues like the following:

Four very important central bankers in Europe; ECB’s Mario Draghi and BoE’s Mark Carney, former and current chairs of the Financial Stability Board; BIS’ Jaime Caruana and Sveriges Riksbank Stefan Ingves, former and current chair of the Basel Committee for Banking Supervision, with their approval of risk-weighted capital requirements for banks, believe that ‘highly speculative’ below BB- rated assets are far more dangerous to the bank system than ‘prime’ AAA rated assets.

Since ex ante perceived ‘highly speculative’ below BB- rated assets have never ever set of a major bank crisis, as these have always resulted from excessive exposure to something ex ante deemed as safe but that ex post turned out very risky; that should raise some very serious questions about the risk management capabilities of those four highly empowered technocrats.

But, would Ms. Gillian Tett raise such question when meeting them? I don’t think so but, if she has, and has not reported back on the answers, to me or to you Sir, then she is just much more complicit in the cover up of the elite’s blunders than I thought possible.

@PerKurowski ©

Europe’ banks are in hand of regulators and central bankers who prefer dreaming about the safer past than a riskier future.

Sir Mark Mazower writes: “I was going to write — “critics and supporters of the European dream”. But there is no dream any longer and that is in some ways the biggest problem of all.” “Fresh ideas and lessons from the past are key to Europe’s survival” January 22.

A dream could be about a better future or about conserving a better past. Europe’s bank regulators, with their credit risk weighted capital requirements, which allow banks to earn much higher risk adjusted returns on equity when refinancing the safer past, than when financing the riskier future, clearly evidence what they dream about… poor Europe’s youth.

Let me refer to four extremely important European central bankers: ECB’s Mario Draghi and BoE’s Mark Carney, former and current chairs of the Financial Stability Board; BIS’ Jaime Caruana and Sveriges Riksbank Stefan Ingves, former and current chairs of the Basel Committee for Banking Supervision

All these gentlemen fully support credit risk weighted capital requirements for banks, which de facto means they believe that ex ante perceived ‘highly speculative’ below BB- rated assets, are far more dangerous to the bank system than ‘prime’ AAA rated assets. Europe, if that’s not scary, what is?

@PerKurowski ©

Too much fighting for a safe haven dissipates its safety and turns in into a dangerously overpopulated haven.

Sir, Tim Harford writing on the “dissipation of economic rents” holds that “They’re frustrating, because value is being frittered away in the competition to secure them… the entire value on offer will be consumed by the race to grab it.” “How fighting for aprize knocks down its value”

How come it is seemingly so hard for Harford and other economists to apply the same concept to the “dissipation of credit safety”?

If regulators allow banks to hold less capital against what is perceived as safe, which means they can leverage more with these assets, and which means they will earn higher expected risk adjusted returns on assets perceived as safe than on assets perceived as risky … then they will hold more and more of safe assets perceived as safe… until the safety of these assets dissipates.

Harford asks: “Can anything be done about … rent-dissipating behaviour?” and answers “One approach is to tax it.” 

Since dissipating credit security is the result of a regulatory subsidy in favor of safety, in that case an easier and more sustainable solution would be just to get rid of dumb regulators, those who think that what is ex ante perceived as safe is more dangerous to the banking system than what is perceived as risky. 

@PerKurowski ©

Mark Carney's worries over financial risks, are influencing the results of BoE’s monetary policy.

Sir, Martin Wolf writes: “Worries over financial risks are legitimate. But they must not determine monetary policy” “Carney is right not to follow in the Fed’s footsteps” January 21.

But worries over financial risks have influenced the results of monetary policy for quite some time now, but few seem to care.

The credit risk weighted capital requirements that allow banks to earn higher risk adjusted returns on equity on assets perceived as safe than on assets perceived as risky, act like hidden capital controls, and clearly distorts the allocation of bank credit to the real economy, favoring The Safe and discriminating against The Risky. And, as a result, the benefits of the low interest rates that are here discussed flow much more to “The Safe” than to “The Risky”.

Current bank regulations reflect the belief that for instance ‘highly speculative’ below BB- rated assets, is far more dangerous to the bank system than the ‘prime’ AAA rated. I find that to be a crazy notion. But, since Mark Carney, chair of the Financial Stability Board and Martin Wolf seems to agree that it is so, I must confess being a bit at loss when it comes to value their recommendations.

@PerKurowski ©

Could bank regulators, like Mark Carney, have accepted responsibilities for something they are not really qualified for?

Sir, you write: “Mr Carney acknowledges the concern that keeping interest rates very low for a long time may fuel a sharp rise in risky lending. It does not take a genius to see this, he adds, showing some frustration at the chorus of commentators warning of a credit bubble.” “Carney is right to keep UK interest rates on hold” January 20.

But, forget the interest rate for a second. Carney also wears the hat of the Chair of the Financial Stability Board. And, does it take a genius to understand that allowing banks to earn the highest risk adjusted returns where they most want to earn it, where it is perceived as very safe, will create, sooner or later, a bank credit bubble?

Here below is a question that we do not know how Mark Carney would answer it, because seemingly it looks that no one dares to make it… at least not FT.

Introduction:

The Basel Committee decided that in order to make banks safe, these need to hold more capital (equity) against assets perceived as safe from a credit risk point of view than against assets perceived as risky. 

For instance in Basel II a private sector asset rated ‘prime’ AAA carried a 20 percent risk weight while an asset rated ‘highly speculative’ below BB- had a 150 percent risk weight. That meant banks needed to hold 7.5 times more capital against a below BB- rated asset than against an AAA rated asset.

Allowing banks to leverage their equity differently based on credit risks obviously distorts the allocation of bank credit to the real economy, something that by itself could also be very dangerous for the safety of banks.

And the only way those risk weighted capital requirements for banks could be justified, would be if they really made banks safer.

And so the question:

Mark Carney, Sir, would you be so kind so as to provide us with one example of a major bank crisis that has resulted from excessive bank exposures to assets that were perceived as risky when placed on the balance sheet of banks.

I mean we can think of many instances were bankers were lulled into a false sense of security by good credit ratings, but I cannot for my life imagine bankers building up excessive exposures to something rated below BB-. Can you?

Sir, if Carney is not able to answer that very straightforward question adequately, it might indicate he has accepted a responsibility he is not fully up to and that should be worrisome… wouldn’t it?

Could it not be this bank regulatory distortion that impedes low interest rates and other stimulus to reach where it is most needed, like to SMEs and entrepreneurs?

@PerKurowski ©

How can we wean the world off horrendously mistaken bank regulations?

Sir, Robert Zoellick writes: “After seven years of extraordinary governmental stimulus, the world needs a shift from exceptional monetary policies to private sector-led growth… Three possible ways to generate growth stand out for 2016.” “How to wean the world off monetary stimulus” January 19.

Then Mr Zoellick lists: Lawrence Summers’ “big government spending, especially on infrastructure, financed by borrowing at extremely low interest rates”;

Kenneth Rogoff’s “ease debtors’ plights by keeping rates low or even negative, and by restructuring debt, while setting the stage for productive investment”;

Michael Spence’s, and Kevin Warsh’s “emphasise that the demand that will drive private capital investment, which should support higher wages and profits, is expected future demand [so] policies intended to boost demand in the near term can actually discourage business confidence in the future”

And finally “others call for tax and regulatory policies to encourage private sector investment and employment”

I find myself squarely among the latter. Getting rid of that nonsense of credit risk weighted capital requirements for banks would eliminate that distortion that impedes bank credit reaching where it could do the most good, namely to those SMEs and entrepreneurs who most depend on bank credit to lend them the opportunities for helping to move theirs and ours economies forward.

As a member of Civil Society, whatever that now means, at a Civil Society Town-hall Meeting during the 2010 Annual Meetings, I had the opportunity to pose the following question to Dominique Strauss-Kahn, the Managing Director of the International Monetary Fund, and to Robert B. Zoellick, the President of the World Bank:

“Right now, when a bank lends money to a small business or an entrepreneur it needs to put up 5 TIMES more capital than when lending to a triple-A rated clients. When is the World Bank and the IMF speak out against such odious discrimination that affects development and job creation, for no good particular reason since bank and financial crisis have never occurred because of excessive investments or lending to clients perceived as risky?”

I got, not splendid but reasonably good answers from both. Unfortunately, 5 years later very little has been done about how to wean the world off some lousy bank regulations, probably because regulators are more concerned with covering up their mistakes.

PS. In 2011, in the same venue, I repeated a similar question, all to no avail.

@PerKurowski ©

#WEF, the world needs some ordinary people (like me) to ask the salon experts in #Davos2016 some awkward questions.

Sir, John Thornhill titles his review of World Economic Forum’s Klaus Schwab’s recent book, “The world’s problems solved the Davos way”, January 18. 

And he begins it with: “The World Economic Forum does a remarkable job of forging the conventional wisdom among the global elite. The trouble is that conventional wisdom is invariably wrong.”

Indeed, and that is especially true considering that among the experts there gathered, there will always be too many who, in John Kenneth Galbraith’s words, qualify as those who by pretending to knowledge they do not posses, cannot ask for explanations to support possible objections.

And there are many urgent questions waiting to be made about the nakedness of experts. Among these the following:

Regulators currently allow banks to leverage their equity, and the support the society gives them with deposit insurance schemes and implicit bailout promises, much more when lending to what is deemed or perceived as safe, like infallible sovereigns and the AAArisktocracy, than when lending to the risky, like SMEs and entrepreneurs.

For instance with Basel II, banks could leverage as much as they wanted with OECD sovereigns, over 60 times with what’s rated AAA, 12 times with what is not rated, and 8 times with what’s rated below BB-.

And that of course allows banks to earn much higher risk adjusted returns on equity when lending to “the safe” than when lending to “the risky”.

Why do regulators allow that?

Does that not, by distorting the allocation of bank credit to the real economy, impede banks to perform well what is perhaps their most important social function?

How on earth can something rated ‘highly speculative’ below BB-, be considered more dangerous to the banking system than something rated ‘prime’ AAA?

Do not regulators know that banks already took into consideration credit risk when setting interest rates and size of exposures, before requiring these to double down on ex ante perceived credit risk in their capital?

Do not regulators understand that all risks, even if perfectly perceived, cause the wrong actions if excessively considered?

Regulators know that bank equity is to cover for unexpected losses. Do they not understand that the safer something is perceived the larger its potential to deliver unexpected losses?

Do not regulators and central bankers understand that, while this distortion is in place, whatever fiscal or monetary stimulus they provide will be wasted and not reach where it is most needed?

Do not regulators understand that by favoring “the safe” over “the risky” they will increase inequality?

Do not regulators understand that by doing this, banks will no longer sufficiently finance the riskier future, which is what our young need, but will mostly keep to refinancing the safer past?

World Economic Forum, during #Davos2016, for the good of the world, especially for our young, have someone ask these questions to Stefan Ingves, Mark Carney, Mario Draghi, Jaime Caruana, Janet Yellen, Martin Gruenberg, Christine Lagarde or any similar experts present… and press them for full answers.

WEF/Davos. Clarify the mystery of how global regulatory lunacy invaded the Basel Committee for Banking Supervision.

Sir, Gillian Tett referring to the turmoil in China, low oil prices and the dramatic drop in the Baltic Dry Index writes: “the elites breezing into Davos for the World Economic Forum next week should take note… that globalisation does not always proceed in a straight line” “Globalisation moves in mysterious ways” January 15.

“Mysterious ways” indeed. The elites in Davos would do well asking themselves how on earth the development of bank regulations to be applied globally, the Basel Committee, landed in hands of “experts” who think that what is rated ‘highly speculative’ below BB-, is much more dangerous to the banks and to the banking system than what is rated ‘prime’ AAA?

In Basel II the capital requirement for what was rated AAA to AA was 1.6 percent while for below BB- it was 12 percent.

In Basel II, banks could therefore leverage over 60 times their equity with what was rated AAA to AA and 8 times with what was rated below BB-.

So with Basel II banks could obtain much much higher risk adjusted returns for what is rated AAA to AA than for what is rated below BB-.

And neither has the Financial Stability Board found something curious with that regulatory concept that so distorts the allocation of bank credit to the real economy.

And here we are with a financial crisis that originated in AAA land, and a real economy that is weakening because of lack of access to bank credit for “risky” SMEs and entrepreneurs. How many #Davos201x will it take to ask the right questions?

@PerKurowski ©

Bank regulators distorted and unleveled the access to bank credit playing field

Sir, Shamit Saggar, a former Non-Executive Director of the Financial Service Authority (1998-2004) writes: “Regulators cannot avoid getting involved: their role is to level the playing field” “Regulators must keep banking culture in check” January 14.

Exactly! But then he should explain to us why he kept mum when regulators, by means of credit risk weighted capital requirements for banks, unleveled the whole playing field.

They allowed banks to leverage much more with loans to those perceived or deemed as safe, than with loans to those perceived as risky; which meant banks would earn higher risk adjusted returns on exposures to those perceived or deemed as safe, than to those perceived as risky.

And so “The Safe”, like the sovereigns and the AAArisktocracy, got much easier and cheaper access to bank credit than usual; while the Risky, SMEs and entrepreneurs, had to face much lesser and more expensive bank credit than usual.

Mr. Saggar, like so many others of his regulatory colleagues, should be ashamed of what he allowed to happen on his watch.

@PerKurowski ©

Ordinary holders of bank shares had little idea that their investment was leveraged a speculative 50 to 1.

Sir, Daniel Davies, with respect to the lower returns on equity that result from higher capital requirements, holds that bank executives should tell investors: “You loved this business when it had equity-to-asset ratios of 2 per cent and a 16 per cent RoE. Why do you hate it now that it has 5 per cent equity to assets and a 9 per cent RoE?”, “Banks should not fixate on double-digit returns” January 13.

Let us be clear of that 2 percent equity to asset ratio signifies 50 to 1 equity leverage, and one of 5 percent, 20 to 1.

Does he really think shareholders loved the 16 percent RoE had they been truly aware that the bank management was leveraging his investment a mindboggling speculative 50 to 1… and taking home great bonuses because of that?

Does he really think shareholders would be satisfied with a 9 percent RoE if they really internalize the significance of banks now leveraging their investments 20 to 1, in times when any official assistance operations requires shareholders and creditors to first sustain important losses… in order for the management to keep taking home great bonuses?

Shareholders, like many other, were and are still misled by all those low leverages reported as a result of not using gross assets but using risk weighted assets instead.

Go back some years and you will, even in FT, find that the great majority of articles mention 10 to 1, or even lower leverages, quite often even ignoring to mention the risk weighing of assets, that which so much diminished the asset on which the leverages were calculated.

Would I be satisfied with a 9 percent RoE? Yes, perhaps for a bank leveraged 10 to 1… and with the bonuses to be paid to the managers decided by us, the shareholders. 

@PerKurowski ©

Martin Wolf, where do bad credit bubbles grow, in ‘prime’ AAA land, or in ‘highly speculative’ below BB- terrain?

Sir, Martin Wolf writes “The adjustment ahead for a world economy so addicted to credit bubbles is going to be difficult” “This turmoil is the result of the Fed’s blunder” January 13.

Basel II regulations to which most developed emerging and developing markets adhered, set capital requirements for banks of 1.6 percent for what is AAA rated and 12 percent for what is rated below BB-. That means that banks could leverage their equity 62 times when dwelling in AAA land but only about 8 times when daring into below BB- terrain. That means banks would obtain much larger risk adjusted returns on equity when lending to what is AAA rated (or sovereigns) than when lending to what is rated below BB-.

And Martin Wolf has never understood the credit risk aversion that introduced in the regulation of banks, nor does he understand the fact that risk-taking is the oxygen of all development. Currently, because the regulatory distortions credit risk weighted capital requirements produce in the allocation of bank credit, the whole world is submerging.

And that distortion does not provide the banking system with one iota more of stability. It is just the opposite.

Sir, do yourself a favor, give Martin Wolf a call right now and ask him: “Martin what do you think poses more danger for the stability of the banking system, or creates more dangerous credit bubbles, that which is rated ‘prime’, AAA, or that which is rated ‘highly speculative – near default below BB-’?” 

Sir, when compared with the dangers to the world economy of current bank regulations, the .25 percent rate increase by the Fed, is pure chicken shit.

Are there many problems in the emerging markets? Of course there are! It suffices to go back a couple of years and read the many opinions about the ‘marvels’ of emerging markets… especially in light of the almost inexistent interest rates for what was perceived or deemed safe in the developed world.

@PerKurowski ©

Culture might not be a matter for bank regulators, but common sense should be.

Sir, you write “Banks are ultimately private institutions and not adjuncts of the state. It is the job of the FCA both to ensure that they treat their customers fairly and also to preserve the integrity of the UK’s financial markets. It is not the regulator’s function to determine how they go about the day-to-day management of their businesses. The soundness of the country’s financial system ultimately depends on having a sensible framework of well enforced rules as well as institutions that are capitalised sufficiently to withstand inevitable periodic shocks.” “Culture is a matter for banks not regulators” January 13.

Indeed but what have the regulators done? Nothing less than giving the banks the incentives that allow these to earn much higher risk adjusted returns on equity when lending to those ex ante perceived or deemed as safe, like the AAArisktocracy or Infallible Sovereigns, than when lending to those ex ante perceived as risky, like SMEs and entrepreneurs.

And that they did by means of credit risk weighted capital (equity) requirements, more risk more capital – less risk less capital; which means banks can leverage more with assets perceived as “safe” than with assets perceived as “risky”. 

Basel II prescribed 1.6 percent in capital for what was AAA rated, and 12 percent for what was rated below BB-. The meaning of that is “be very scared of the risks you see, what’s below BB-, and very daring with those you don’t see, the AAAs”

And with that regulators guaranteed that when really bad things happen, like when an AAA rated assets turned out ex post to be very risky, banks would stand there with especially little capital to cover themselves up with.

And with that they regulators also guaranteed the weakening of the real economy, that economy for which risk taking is the oxygen that helps it to move forward so as not to stall and fall.

Frankly, in their current incarnations, we would all be better off if the Basel Committee, the Financial Stability Board, the FCA, and other similar meddling schemers simply did not exist.

Sir, and you should be ashamed of helping to cover up those bad regulations that are taking our economies down.

Current bank regulators do not hope for the best nor do they plan for the worst.

Sir, Lawrence Summers concludes: “Policymakers should hope for the best and plan for the worst” “Heed the fears of the financial markets” January 11

But let me note that current credit risk-weighted capital requirements for banks are based on the opposite principle.

What would be the best? That the risky turn out to be safe. Do they hope for that? Absolutely not, they even prohibit that hope. They require the banks to hold more capital against what is perceived risky than what is perceived safe.

What would be the worst? That the safe turn out to be risky. Do they plan for that? Absolutely not! They allow banks to hold especially little capital when lending to The Safe.

@PerKurowski ©