Do Gillian Tett and other really believe that ever-growing offshore cash piles, is cash stashed away under mattresses?

Sir, Gillian Tett writes: “overseas profit piles have swelled — to more than $2tn”; and from there she jumps to: “in the real world introducing a repatriation deal — even at a mere 10 per cent — would almost certainly be better than the dismal status quo: a world of ever-growing offshore cash piles, transatlantic tax battles and lousy infrastructure does not suit anybody.” “The clampdown on tax inversions is only a start” April 8.

But Vanessa Houlder informs: “Over $1tn of cash has been booked offshore, even if the money is held in US banks or Treasury bonds.” “Tax havens seen as ‘grease on wheels’ of cross-border trade” April 8.

All those “overseas profit piles” have, in some way or another, already been deployed and so, to redeploy these, means having to liquidate their current positions.

What if the “more than $2tn” had all been invested in public debt and you repatriated all of it and the government got a 10 percent cut on it?

Then of course governments would owe ‘more than $200bn’ less, but if they for instance wanted to better any “lousy infrastructure”, then they would have to sell fresh public debt in the market. And, since the stockpile-holders have been diminished, that would most certainly imply having to pay higher interest rates. That is of course, unless governments are not assisted by banks holding it against zero capital requirements, or central banks buying up public debt for the governments own “stockpiles of cash”.

It is amazing the kind of demagoguery that is floating around. It is dangerously divisive. At the end of the day what it really comes down to, is who is going to decide on how any accumulated wealth is to be redeployed, whether the private or some government bureaucrats.

I truly believe that current governments waste, represents much more lost value than what is inappropriately or illegally diverted into these oh-so-horrible “stockpiles of cash”. And so I would like to see the expected repatriation profiteers kept at bay. Perhaps all citizens in some Universal Basic Income/Wealth scheme could share the governments’ cut of any repatriated assets?

And by the way, what are we to do with Putin’s “stockpiles of cash”, those that might be fully invested in the US? Send it back to Russia to Mr Putin?

Do these comments mean that I condone what distorts or what is illegal? Of course not! All tax systems should be improved and all taxes should be paid! There are occasions though in which I find it quite relevant to ask: How much failed nation or tyrannical government is needed for citizens’ capital to be granted immediate asylum?

Jamie Dimon should consider the long-term interest of his and of JPMorgan’s shareholders’ children and grandchildren

Sir, Ben McLannahan reports on Jamie Dimon’s letter to JPMorgan’s shareholders’. “JPMorgan chief Dimon warns on dangers of undermining US banks” April 7.

In his letter Dimon argues that tougher rules can weaken the competitiveness of US banks, for instance against the Chinese banks. That’s true! Especially in the short-term.

And McLannahan reminds us that “In 2014 Dimon argued that tougher rules would mean that customers faced more expensive credit, or would be denied certain financial products altogether.” That is also true!

But Dimon must also be perfectly aware that current bank capital requirement rules, for when lending to those ex ante perceived as “risky”, are much tougher than those for exposures to the “safe”.

And I refuse to think that Dimon does not know that distorting the access to bank credit in favor of the “safe” government and the AAArisktocracy, against that of the “risky” SMEs and entrepreneurs, only guarantees to sooner or later weaken tremendously the real economy of US. 

And I also refuse to think that Dimon does not know that no US bank should expect to be able to stand solid amid the rubbles of a ruined US economy… not even JPMorgan.

Dimon states: “The US financial services industry does not conform to simple narratives. It is a complex ecosystem that depends on diverse business models coexisting because there is no other way to effectively serve America’s vast array of customers and clients.”

And surely Dimon knows perfectly well, that a complex ecosystem is not made better by regulators who, with much hubris and little wisdom, believe they can help it with their distorting concoctions.

And so Jamie Dimon, instead of writing a letter to JPMorgan’s shareholders considering their short-term interest, should write them a letter that considers the long-term interests of theirs and his own children and grandchildren.

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

God make us daring!

@PerKurowski ©

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

@PerKurowski ©

The Basel Committee’s risk weighted capital requirements for banks decreed the ‘new mediocre’, and boosted inequality

Sir you write: “Christine Lagarde, the IMF managing director, has warned that the recovery remains too slow and fragile — and that the world risks being trapped in a “new mediocre” of persistent low growth, with damaging effects on the social and political fabric of many countries.” “The high cost of settling for the ‘new mediocre’” April 6.

If asked: “Is risk-taking essential to the economy?” most experts and all wise men would say “Absolutely!”

And yet regulators de facto ordered banks to stay away from whatever that is ex ante perceived as risky. Because that is what happens when you allow banks to earn higher expected risk-adjusted earnings on what is “safe” than on what is “risky”. Because that is what happens when you allow banks to leverage equity more with what is “safe” than with what is risky.

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

This week William Coen, the Secretary General of the Basel Committee, said in a speech: “We have spent several years developing a framework to make sure that banks' capital and liquidity buffers are strong enough to keep the system safe and sound.” And that describes precisely the problem; they have only cared about the condition of the banks, and not one iota about the fundamental social purpose of banks, which is that of allocating credit efficiently to the real economy.

As is banks will dangerously overpopulate safe havens and leave many promising but “risky” bays unexplored. As is banks no longer finance the riskier future, they just refinance the, for the very short time being, safer past.

And of course, negating the “risky”, like SMEs and entrepreneurs, fair access to the opportunity of bank credit can only boost inequality.

Sir, I cannot understand your, IMF’s, World Bank’s, economists’ and so many others’ silence on this issue. As I see it you should all be ashamed.

One day soon, your sadly unemployed children and grandchildren, will hold you accountable for it.

And don’t tell me I did not warn you. I have sent you way over 2,000 letters on the dangers of arbitrarily imposing distorting risk aversion on our banks, during more than a decade. 

@PerKurowski ©

The fights against climate change and inequality would both benefit much from a Basic Universal Income union

Sir, Martin Wolf, discussing the seemingly accelerating threat of climate change writes: “If carbon pricing were to deliver the desired shifts in investment, it would require credible commitment over the long term. But commitments for the long term can barely be credible.” “Why fossil fuel power plants will be left stranded” April 6.

That really depends on how carbon pricing is structured. The real challenge is to keep at bay the climate change profiteers, be that governments, be that private companies.

In my country Venezuela, were the subsidies for domestic gas (petrol) are monstrously large, but where there is an imbedded resistance to high gas prices, that could be solved if the government paid out all domestic gas revenues directly to the citizens in equal parts… and that at a cost that would not be larger than 2 percent tops.

In the same vein I have also suggested that if all funds derived from carbon pricing, or carbon taxes, were to fund a Universal Basic Income scheme that fights inequality, then all the incentives are perfectly aligned, and it would be politically very difficult to eliminate it.

In fact all the fight against inequality should also proceed with the basic principle of keeping the redistribution profiteers at bay, and Universal Basic Income helps to do that.

An added advantage is that separating the redistribution flows from the taxes needed to fund the governments operations, would bring much added transparency to fiscal matters, and thereby make life more difficult for demagogues.

And of course the resulting flows would help to sustain the demand needed for economic growth.

PS. The Universal Basic Income could also be additionally funded by means of a Pro-Equality Tax

@PerKurowski ©

Would adequate SIFIs’ designations have helped to avert the last crisis? Of course not!

Sir, I refer to Patrick Jenkin’s “MetLife ruling poses threat to drive towards global financial stability” April 5.

Jenkin sounds very much upset: “This is absurd. The FSOC — with its expert mandate and responsibility for “identifying risks and responding to emerging threats to financial stability” — is being torpedoed by an inexpert judge.”

Sir, you know I hold that the regulator, the Basel Committee and friends, was the real responsible for the crisis that errupted in 2007-08. Its risk weighted capital requirements for banks distorted the allocation of bank credit to the real economy, and allowed banks to leverage absurdly much on assets deemed, decreed or concocted as safe… and all this when history clearly shows that “safe” assets is precisely the stuff that big bank crises are made of.

Had the oversized exposures to AAA rated securities and sovereigns to Greece anything to do with what the regulators now tries to catch with their SIFI methodology? No is the simple answer.

In fact working on how to manage SIFI’s, keeps regulators from working on mending their own mistakes. And frankly I see no reason for Jenkins to deposit so much naïve faith in the expertise of FSOC or FSB or any other member of the regulatory logia.

He writes “The time may have come for the G20 to give the FSB proper statutory powers to ensure shortsighted political interests do not put the world on the road to financial ruin once more”

He should know that there is nothing as shortsighted as the risk weighted capital requirements. These have stopped the banks from financing the risky future and have them only refinancing the, for the very short term, safer past.

If anything Sir, I would wish for that “inexpert judge” to also look into whether the unauthorized discrimination against the access to bank credit of the “risky”, which is imbedded in that regulation, should really be allowed in the Home of the Brave.

It is high time the world starts to reflect on whether it really wants to allow an Ultra Important Regulator to introduce, as it wishes and thinks fit, dangerous systemic risks into the banking system.

The absolute minimum we must ask for is for the regulator to first give us its working definition of what is the purpose of our banks, so to see if we agree.

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

@PerKurowski ©

If Britain had applied current bank regulations when it was developing, it might even have found itself below India

Sir, you write: “Even if one puts to one side doubts about India’s economic statistics, private investment remains weak. The government has rightly emphasized improved administration, faster decision-making and greater ease of doing business” and you quote Eswar Prasad of Cornell University ideas with “Markets for land and capital remain distorted. Several public sector banks are in dire shape. They need recapitalization and radical reform”, “Modi fails to exploit India’s great opportunity” April 4.

But again you fail to mention the fact that the Basel Committee’s credit risk weighted capital requirements for banks, which by favoring “the safe” disfavor “the risky”, is as anti-development and pro-inequality as can be.

Do you really think that allowing banks to earn higher expected risk adjusted returns on equity with “the safe” than with “the risky” is the way to go for a country that has not reached sufficient altitude climbing the mountain of development?

And it is not that these bank regulations keep you high up, they also impose a fast descent. With it Britain has expelled its spirited and adventurous risk taking and embraced the risk aversion of the scared.

Hello India, we, Britain, will soon catch up with you, while climbing down.

When the Bible says “But the meek will inherit the land and enjoy peace and prosperity” I am sure it was not to excessive risk-adverseness it was referring.

God make us daring!

@PerKurowski ©

John Dizard has provided us with a very important wakeup call on energy storage batteries

Sir, I think that everyone that wants to fight climate change, but feels that is best done by keeping the climate change profiteers at bay, need to be very grateful for John Dizard’s “Lack of economic rationale is a feature of battery-storage hype” April 4.

I myself am guilty of having preached, to friends and family, the benefits of new energy storage batteries without really checking up on their real costs. I will immediately go silent on this without further checking up.

@PerKurowski ©

Having carbon taxes fund Universal Basic Income schemes would align the fights against inequality and climate change

At least in the 1980s (I do not know of the before and after) high European taxes on gas (petrol) were defended by the need to protect the environment, while at the same time, at least in Germany and Spain, the much dirtier coal was being subsidized. And the resulting tax revenues are of course huge.

Stephen Foley writes about how investors should adapt their exposures to fossil fuels given all declarations of war against climate change. ”Even oil barons are giving up on fossil fuels”, April 4.

But the taxman needs also to adapt. If we consume less gas/petrol tax revenues will go down, so it is not farfetched to think that those hungry for tax revenues to manage, will again exploit the environmental argument to increase taxes… though they must know that puts their tax revenues on a sort of unsustainable path.

I believe though that climate change is best fought on its own merit, which means keeping the climate change profiteers, whether private or governments, at far distance.

In my own country Venezuela, as a tool to get rid of monstrously large gas subsidies, I have been proposing that all the net income the government derives from the domestic sale of gas, should be paid out in equal parts to all citizens, so as to keep the redistribution profiteers at bay.

And if the whole world did the same, using carbon taxes as a fundamental source of income to pay for a Universal Basic Income, that would not only help to increase fiscal transparency, but also beautifully align the fight against inequality with the fight against climate change.

Placing our banks into the hands of a Basel Committee is surely one of the greatest acts of naïve realism ever

Tim Harford quotes George Carlin with “Have you ever noticed when you’re driving, that anybody driving slower than you is an idiot, and anyone going faster than you is a maniac?”, “Delusions of objectivity” April 2

And Harford refers to a new book, The Wisest One in the Room, co-authored by Lee Ross, a psychologist at Stanford University and that describes the problem of “naive realism”… “The seductive sense that we’re seeing the world as it truly is, without bias or error. This is such a powerful illusion that whenever we meet someone whose views conflict with our own, we instinctively believe we’ve met someone who is deluded, rather than realising that perhaps we’re the ones who could learn something”

But let me also quote from Tim Harford’s book “Adapt” of 2011. It states: “So far this book has argued that failure is both necessary and useful. Progress comes from lots of experiments. Many of which fail, and we are to be much more tolerant of failure if we are to learn from it. But the financial crisis showed that a tolerant attitude to failure is a dangerous tactic for the banking system.” In other words Harford holds that, those not allowing for sufficient risk-taking are idiots and those allowing too much risk taking are maniacs”.

And in his book Harford also quotes Charles Perrow, emeritus professor of sociology at Yale explaining that the dangerous combination is a system that is both complex and tightly coupled, and saying that the banking sector “exceeds the complexity of any nuclear plant I ever studied”.

And when commenting on the Piper Alpha (nuclear plant) disaster Harford writes: the “safety system introduced what an engineer would call a ‘new failure-mode’ – was precisely the problem in the financial crisis: not that it had safety systems, but that the safety system it did have made the problems worse”. Harford illustrates that with the example of credit default swaps CDS.

But finally, in “Adapt”, Hartford also argues: “Among the bitter recrimination over the financial crisis of 2008, if there’s a consensus about anything is that the financial system needs to be made safer. Rules must be introduced, one way or another, to prevent banks from collapsing in the future”.

And of course that’s wrong! Because that might precisely represent the worst kind of bank regulation risk!

In May 2003, in some comments delivered as an Executive Director of the World Bank during a workshop for regulators I said: “A regulation that regulates less, but is more active and trigger-happy, and treats a bank failure as something normal, as it should be, could be a much more effective regulation. The avoidance of a crisis, by any means, might strangely lead us to the one and only bank, therefore setting us up for the mother of all moral hazards—just to proceed later to the mother of all bank crises.”

Coming back to Harford’s "Delusion of Objectivity" I would hold that one of the greatest acts of naïve realism of our times, is believing that a small group of technocrats, holed up in a mutual admiration club like the Basel Committee effectively is, can regulate our banks to be safer, without creating even larger risk.

Just for a starter they regulated the banks without defining the purpose of banks, which allowed them to introduce their risk weighted capital requirements, which completely distorted the allocation of bank credit to the real economy.

Clearly in reference to my criticism of Basel regulations, most in FT believe, or had been told to believe, that I am someone quite deluded, rather than realising that perhaps they are the ones who could learn something from me.

I confess I am obsessive on this issue. They should confess they are even more obsessive ignoring this issue. 

@PerKurowski ©

Rules that make all banks behave the same can pose greater systemic risks than all SIFIs put together.

Sir, I refer to Brooke Masters article on “systemically important financial institution whose failure could destabilise the economy” “MetLife’s court win means US regulators should redraft rules” Saturday 2.

Before regulating or redrafting anything, regulators should at least come to understand that their own rules might be the source of the most dangerous systemic risks.

In 2001, in an OpEd I wrote the following onbank regulations:

“The regulatory risk: Before there were many countries and many ways of how to regulate banks. Today, with Basel proudly issuing rules that should apply worldwide, the effects of any mistake could be truly explosive. 

Excessive similarity: Encouraging banks to adopt common rules and standards, is to ignore the differences between economies, so some countries end up with inadequate banking systems not tailored to their needs. Certainly, regulations whose main objective appears to be only to preserve bank capital, conflict directly with other banking functions, such as promoting economic growth, and democratize access to capital. 

Low diversity of criteria: A smaller number of participants, less diversity of opinion and, with it, increased risk of misconceptions prevailing. Whoever doubts that, should read the dimensional analysis that ratings agencies publish. 

Backlash: The development of decision-making processes has benefits but also risks. Thus we see that the speed of information itself, which promotes quick and immediate response, can exacerbate problems. Before, those who took the problem home to study it, and those who simply found out late, provided the market a damper, which often might have saved it from hurried and ill-conceived reactions.”

And already in 1999 in another OpEd I had written: “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”

And then Basel II’s 20 percent risk weight for AAA rated securities, caused the financial crisis 2007-08; while Basel I’s zero riskweight assigned to sovereigns, doomed sovereigns like Greece.

Of course there is a need to think about the systemic risk of SIFIs, but even more important, is looking to minimize the systemic risks of bank regulations… or at least to recognize their existence.

A million of individual small banks can easily be turned into a very dangerous Systemic Overall Important Banking System, by just some rules drafted by some members of that mutual admiration club known as the Basel Committee for Banking Supervision.

@PerKurowski ©

When securitization wedded the capital requirements for banks, the subprime mortgages' inferno overheated.

Sir, I refer to Gillian Tett’s “Unorthodox answers to the inflation enigma” April 1.

Ms Tett writes: “If the Fed, or any central bank, wants an illustration of why ethnographic research matters, they need only look at the last credit bubble, when most economists missed the subprime mortgage boom because they shunned on-the-ground research. Fed officials need to get into consumers’ lives. Or else hire a few anthropologists to work with those office-bound, and baffled, economists.”

Unfortunately central bankers have yet to understand the missed subprime mortgage boom, and so has anthropologists like Gillian Tett.

Anyone who has read Kirsten Grind’s spectacular tale of the Washington Mutual failure “The Lost Bank” 2012, Gillian Tett has praised it, should have been intrigued by a question the book poses but that remains unanswered. Why was there especially such huge demand for basically the lousiest mortgages?

An objective researcher would then have found that combining the dark secret of securitization, with the importance given to the credit rating agencies for determining the capital requirements for banks, created a temptation impossible for any ordinary humans to resist.

What “dark secret of securitization”? That the worse the assets to be securitized are, the more can those involved in the securitization process profit. Selling of a $300.000, 30 years, 11 percent mortgage, packaged in a security for which an investor thought that 6 percent was a great return, would immediately yield $210.000 in profits.

And on credit ratings, if a security got an AAA to AA rating, then the banks, according to Basel II, needed only to hold 1.6 percent in capital against it, and were therefore allowed to leverage a mind-blowing 62.5 times to 1.

The problem with any central bank research though, is that it would lay much blame on all central bankers involved with bank regulations… and, among colleagues, we can’t have that, can we?

Oh how I wish Kirsten Grind would go back to the subprime inferno and research the causes for why it overheated.

@PerKurowski ©

What if all redistribution is paid by a special tax and shared out equally keeping redistribution profiteers away?

Sir, Marin Wolf discusses the utterly important issue of redistribution of income (and wealth) “The welfare state is a piggy bank for life” April 1.

Citing the Institute for Fiscal Studies Wolf writes: “in the course of adult life, only 7 per cent of individuals receive more in benefits than they pay in taxes”. That sounds as the society is very equal or that the redistribution is very inefficient/costly.

In Finland they are currently analyzing the possibility of a Universal Basic Income. That might not redistribute efficiently over lifetime needs but, by keeping redistribution profiteers away, it might still be a much better alternative than current procedures.

Wolf writes: “benefits paid to individuals, such as housing benefits, tax credits paid to those in work and pensions. In the UK, such benefits amount to a huge sum: 33 per cent of current spending (and 12.5 per cent of gross domestic product) in 2014-15.”

How much money does that represent per citizen? What if it was just paid out directly to all from a specific pro-equality income and wealth tax? If done so that would make it easier to separate re-distribution from the general government functions, and that added transparency could at least help keep some political demagogues at bay.

What causes more inequality, market or government imperfections? In Venezuela, that is a question easy to answer. The poorest Venezuelans have not received even 15 percent of what should be their per capita share of the net oil revenues

@PerKurowski ©

The risk weighted capital requirements for banks, put the “Minsky moments” on steroids.

Sir, you write “A period of stability leads to rising investment, financed by borrowing, which drives up asset prices until cash flows generated by those assets can no longer support the debt taken on to buy them. Eventually there is what has been dubbed the “Minsky moment”: a dash for the exits as asset prices plunge. After the bubble bursts, the debt burden remains and can depress activity for a long time. “The challenge posed by oil’s ‘Minsky moment’” March 29.

But the regulators, with Basel II, told banks “If you think that something is safe then you can hold less capital against it”. And, in their Standardized Approach to Credit Risk, the regulators allocated the basic capital requirement of 8 percent according to the following risk weights: zero percent for loans to AAA-rated sovereigns; 20 percent on loans to the AAArisktocracy, 35 percent risk weight on the finance of residential mortgages; and 100 percent risk weight on exposures to unrated citizens.

And that translated into banks could leverage equity unlimited times when lending to AAA rated sovereigns; 62.5 times to 1 when lending to the AAArisktocracy, 35.7 times when financing residential housing 35.7, and only 12.5 times to 1 when lending to the unrated citizens.

And of course that allowed banks to earn different risk adjusted returns on equity not based on what the market offered, but much more based on what the regulators dictated.

And since “Minsky moments” never occur in areas ex ante perceived as risky but always in what is perceived as safe, that is of course equivalent to putting the “Minsky moments” on steroids.

You also end with: “As Minsky argued, booms and busts are endemic to capitalism. Sensible policy strives not to abolish the cycle but to mitigate its effects.”

But the risk weighted capital requirements signifies banks will have especially little capital precisely when the busts occur. And that has nothing to do with “mitigating” its effects, just the opposite.

Sir, I must have written to you and your colleagues well over 2.000 letters trying to explain the dangerous distortions caused by the risk-weighted capital requirements for banks, but apparently it has not yet been understood.

Sir, between us in petit committee, although I understand that it probably has to do with you wanting to sound sophisticated, I do not think you have earned the right of referring to Minsky into your editorials.

PS. This is not a critique directed solely to you Sir. For example, out there, the less many seem to understand what is really going on with our banks, the more they express concerns about “derivatives”, only because that word sounds so delightfully sophisticated.

Sir, would you trust a columnist who refuses to acknowledge what produced Europe’s financial crisis?

Wolfgang Münchau asks: “would you trust with your own security somebody who cannot even contain a medium-sized financial crisis? I personally would not, which is why my own preference is for the Schengen system of passport-free travel to be suspended indefinitely” “A history of errors behind Europe’s many crises” March 28.

Sir, here are some of the Basel II’s risk weights that determined how much of the basic bank capital requirement of 8 percent banks were required to hold against some different exposures:

Loans to sovereigns zero percent; to the AAArisktocracy 20 percent; financing residential housing 35 percent; and loans to ordinary unrated citizens 100 percent

That meant banks could leverage equity unlimited times when lending to sovereigns; 62.5 times to 1 when lending to the AAArisktocracy, 35.7 times when financing residential housing 35.7, and only 12.5 times to 1 when lending to the unrated citizens.

And that allowed banks to earn different risk adjusted returns on equity not based on what the market offered, but much more based on what the regulators dictated.

So forget the Euro, forget bank unions, that distortion of the allocation of bank credit to the real economy had to provoke, more sooner than later, financial crises that will destroy Europe.

And so I ask you Sir, would you trust a FT columnist that steadfastly refuses to acknowledge such facts to opine on anything? I would not!

@PerKurowski ©

Securitization is useful, but not when it is driven primarily by differences in capital requirements for banks

Sir, Alexander Batchvarov writes: “It is claimed that securitisation was one of the main causes of the financial crisis because it was complex, performed poorly and lacked transparency.” “It is time to ditch the ‘toxic’ tag for the sake of Europe’s economy” March 24, 2016

There are deggrees of possible toxicity that are a direct function of how much the securitization process increases the perceived safeness of what is being securitized.

And in this respect what turned out to be really toxic, was not the securitization of relative safe 30 years fixed rate mortgages to the prime sector, but of home equity loans, subprime loans, Option ARM loans, and similar risky affairs.

But even these “risky” underlying loans would not have morphed into truly toxic securities, had it not been for the regulatory benefits awarded to them by means of risk weighted capital requirements for banks.

For instance Basel II assigned a risk weight of only 20 percent for securities rated AAA to AA- , which with a basic capital requirement of 8 percent, meant banks could leverage their equity with these securities a mindblowing 62.5 times to 1 (100/1.6). Those incentives distorted the whole process.

The moment when a securitization, for instance of SME loans, generates a lower capital requirement than non-securitized bank loans to SMEs, that introduces a distortion in the allocation of bank credit that can be very profitable for the banks, but generates little value for the SMEs.

And so if Batchvarov, head of international structured finance at BofA Merrill Lynch Global Research, wants to emphasise proper use of the securitisation technology for the benefit of the broader European economy, he should begin by favoring the elimination of the risk weights differences which cause bank capital requirement differences between what is ex ante perceived as safe and what’s perceived as risky.

And, by the way, that would not increase European financial instability, since there never ever are excessive dangerous bank exposures to something ex ante perceived as risky… that dishonor belongs entirely to what is perceived as safe.

PS. There is something fundamentally dangerous with securitization

@PerKurowski ©

There is risky bank lending and then there is "risky" bank lending

Martin Arnold and Laura Noonan quote Gonzalo Gortázar, chief executive at Spain’s Caixabank with “In a world of low or negative interest rates, that is a possible consequence. You could see banks taking more risk” “Europe bank chiefs fear risky lending from ultra-loose policy” March 22

Of course I cannot be absolutely sure but, when “banks taking more risk” is said, it most probably refers to larger exposures to something that because it is perceived, deemed or sold as safe, carries lower capital requirements.

What is perceived by regulators as risky, like loans to unrated corporations, SMEs or entrepreneurs, and which is risk weighted 100 percent or more, and so require banks to hold more capital, well that’s not the risks banks are taking, unfortunately for the economy.

It would be nice to see reporters digging up a little bit more about what risks is being referred to. In fact, I start any risk assessment by identifying what risk one cannot afford not to take... because that would be too risky.

PS. Another interesting detail is whether it is the ex-ante perceived risk or ex-post resulting risk that is being considered.

@PerKurowski ©

Does anyone see the grey showing on the roots of Lucy Kellaway’s hair or the smear of icing sugar on her leg? Not me!

Sir, you know I am usually a great admirer of Lucy Kellaway’s writings, but, this time, I think she’s got it wrong. “High heels and boxing gloves: a portrait of women at work” March 21

Kellaway writes: “If a company wants to show that it really values women and wants to prioritise action in the gender equality landscape, it will show pictures of them in which they don’t always look cool or gorgeous. They just look like professional women at work.”

Hold it there, my wife is a great lawyer, and she has never ever expressed to me any concerns about any type of discrimination based on gender; if anything she has lately felt, ever so slightly, more burdened by age. But, no matter how she looked at work (always gorgeous of course), she would always, no exceptions, prefer to be depicted as if not at work.

And we men are instinctive survivors. We know perfectly well we should never ever take photos of any woman, including Lucy Kellaway, with “grey showing on the roots of hair and a smear of icing sugar on leg”.

PS. The following is absolutely no opinion, especially not mine; its just a question:

Is there anything as deflationary as women willing to work for less? If women did not work, and stayed home to binge on over 100 episodes shows, then unemployment rate would be lower, salaries higher, and so central banks would get the higher inflation they desire and so allow us higher interest rates, and so we could all have a chance to earn a bit on our savings to cover for our retirements. Matching life styles with the economies is always challenging… so they say.

@PerKurowski ©

Holy moly, some will be paying MIT $75.000 for learning techniques on how to hunt us down.

Sir, Adam Jones writes that some “will pay $75,000 in tuition fees for their Master of Business Analytics degree, with “Applied Probability”, “MIT’s $75,000 finishing school for Big Data” March 21.

And Jake Cohen, senior associate dean for MIT Sloan undergraduate and masters programs says: “The return on investment we expect to be very high [for those who take the course]”

That is more than clear evidence that we, the hunted, the main suppliers of “Big Data”, need to urgently defend ourselves.

Before these hunting licenses are awarded, we should get a copyright over our own personal preferences and lives, so to at least have something to negotiate with.

@PerKurowski ©

With respect to inequality it behooves us all to stop demagogues from opening appetites that cannot be satisfied

Sir, Tim Harford adds valuable elements to Piketty’s r>g inequality discussions, those that have so many redistribution profiteers drooling in anticipation. “Capital ideas in a time of inequality” March 19.

To Harford’s initial discussions on rates of returns we must keep in mind that the ownership of the capital measured, might be constantly changing. And it is very hard to statistically reflect the continuity value after discontinuities like wars, and other potential wipeouts and resets. And the effect of the survivorships bias on returns, though very hard to measure, might be huge over time.

When it comes to this issue of growing inequality, which is serious indeed, I have always been more for analyzing what could be distorting the allocation of wealth, and in how we can open up opportunities for all to participate in its creation.

And since from the evidence it seems we do need a pro-equality tax on wealth, it is also important to make certain that the redistribution is done in a cost effective way. In my country, Venezuela, I always propose that our net oil revenue should be shared out to all citizens, instead of being concentrated in some political besserwissers’ hands. In this respect it is with a lot of enthusiasm I now follow the idea of universal basic income being studied in Finland and lately in Canada.

But, in all this debate, instead of referring to measured balance sheet wealth, should we not better always think in terms of realizable and transferable wealth? For instance, what about all that wealth stored in art hanging on private, or stored away in the cellars of public museums? If we want to transfer part of that value to the poorer in any significant way, how do we proceed? I mean this is very important, because to open up appetites, ignoring these cannot be satisfied, is precisely what dangerous demagogues do.

Friends, if we had managed to keep the profiteers out of the redistribution, would not the current inequalities be lower? Should not redistributing income and wealth max cost 2 percent?

@PerKurowski ©

Martin Wolf, the uncertainty of whether those who govern us really know what they’re doing is always upon us.

Sir, Martin Wolf writes: “Productivity is not everything, but in the long run it is almost everything… But the prospects for productivity are…the most important uncertainty affecting the economic prospects of the British people. Is it reasonable to expect a return to buoyant pre-crisis productivity growth? Will productivity continue to stagnate? Or will it end up somewhere in between?” “The age of uncertainty is upon us” March 18.

Mr. Wolf, for the umpteenth time, obsessively, I do not understand how you and so many other can so obsessively ignore that if you tell banks they can leverage their equity more with what is safe than with what is risky; so that they can earn higher expected risk adjusted returns on equity with what is perceived or deemed to be safe, than with what is risky; that then banks will foremost be refinancing the safer past while ignoring too much the credit needs of the always riskier future. And since then productivity is not been given the chances it deserves, the prospects for its improvement must be really lousy.

“The age of uncertainty is upon us”? Please when did we have an age of certainty?

Current regulators regulate banks without having defined their purpose, and base those capital requirements for banks that should cover for the unexpected, on the expected credit risk. Those facts evidence the major uncertainty we always face, namely whether those who govern us have the faintest idea of what they’re doing.

@PerKurowski ©

FT you’re now inconsistent! You’ve consistently ignored the nannying of banks by the nannies of the Basel Committee

Sir, you hold: “There is a case to intervene when people act in a way that harms those around them, or when it is a case of safeguarding children who cannot take an informed decision and may face bigger risks. If adults take risks with their own health, they should be made aware of the dangers and perhaps nudged into sense, but there is no case for coercion.” “The relentless march of the nanny state” March 18.

Indeed but why then do you keep mum when adult bankers, aware of the ex ante perceived credit risks, are coerced by regulators into considering those risks for a second time, by means of the risk weighted capital requirements for banks?

Can’t you understand that any risk, even if perfectly perceived, leads to the wrong actions, if excessively considered?

If you had two very concerned nannies watching over your children, you might accept them applying the average of their concerns, but never ever the sum of their concerns. Because you know that if they did that, your kids, embracing safety excessively, would grow up seriously disturbed. 

Equally, when now regulators’ risk aversion is added to bankers’ risk aversion, the result is a much disturbed banking system, that embraces excessively what is perceived or has been decreed as safe. Do you get it?

@PerKurowski ©

Should not those who live under the thumb of blatant redistribution profiteers have safe access to safe tax havens?

Sir, David Pilling raises a question that needs to be asked more often, especially when inequality is debated “Why would people pay tax if much of the money is simply stolen or distributed to others, and provision of public goods is so inadequate?” “Where states remain at the mercy of their elites”. March 17.

In my country Venezuela, the really poor have not received more than a maximum of 15% of what would have been their per capita share of the nations net oil revenues. The rest if not just wasted, has gone to redistribution profiteers and associates.

And Pilling quotes Senator Alphonso Gaye from Liberia saying: “You need some cash. Your respect in this country depends on your capacity to respond to people’s demands.” Of his salary… how much do you think goes into his responses? 10 percent?

This is why I am hopeful the universal basic income that currently is being studied, for instance in Finland and Canada, could become a reality.

That would help us to get rid of all those odious redistribution profiteers. And with such a redistribution mechanism many would look much more favorably on a pro-equality tax on wealth.

Question: Where would inequality be today if all social redistributive spending had been done by means of a cost effective Universal Basic Income?

PS. My tax paradise (Nothing as powerful against tax havens as tax heavens)

@PerKurowski ©

Mario Draghi, a risk adverse regulator, now wants banks to increase lending to the risky real economy. Inconsistent!

Sir, I refer to your “Monetary policy is not enough to beat deflation” March 15.

You write that Mario Draghi holds “there is still plenty of scope for central banks to innovate by extending their asset-purchase programs to riskier assets and finding ways to support banks that increase lending to the real economy”.

Mario Draghi is a former chair of the Financial Stability Board and the current chair of the Group of Governors and Heads of Supervision that govern the Basel Committee.

He has therefore fully supported the risk weighted capital requirements for banks.

Those give banks much incentive to stay away from what is perceived as risky and to embrace what is perceived as safe.

Sir, so don’t you think that Draghi now pushing banks to venture more into the realms of risks is being extremely inconsistent? Why not just abandon the bank regulatory distortion of the credit allocation to the real economy?

@PerKurowski ©

Sir, here’s what I would have told young Martin Wolf 40 years ago at the World Bank on India, had I been his boss

Sir, Martin Wolf covers a lot of terrain in his: “India’s growth is a light in a gloomy world” March 16.

He must surely have more knowledge about India than I so I have nothing to argue against his opinions.

BUT! At one point he writes “Markets for land, labour and capital are all highly distorted” and he also informs us “Forty years ago I worked on the Indian economy for the World Bank.”

Which brings me back to my obsession against the distortions in the allocation of credit produced by the risk-weighted capital requirements for banks, which Wolf so firmly has decided to ignore.

Let me be clear, if I had been Wolf’s boss 40 years ago, and if the banks of the world had then also been suffering the Basel Committee’s risk adverseness, I would have sat him down and firmly told him the following.

Listen young man. We represent the world’s premier development bank and so we know that true risk-taking is the oxygen of any development.

Wolf might have asked “True-risk-taking Sir?”

Yes. I do not refer to those risks that derive from building up excessive and dangerous exposures to what is “safe”… which is what the very low risk weights and resulting lower capital requirements for banks for what is perceived as safe currently does.

I refer to taking much, albeit low exposure risks on the risky, like lending to SMEs and entrepreneurs, something that is currently hindered by the higher risk weights and resulting higher capital requirements for banks for what is perceived as “risky”.

So young Martin, if you really want to help India, tell them to ignore the silly aversion against risk imposed by some developed countries’ bank regulators, who on their own decided they should not dare to climb more. Remind those in India that they cannot afford such nonsense. They owe their people the chance of much risky climbing.

And Sir, don’t ask me what steps I would have taken if young Martin had then ignored me J

PS. Here is the document I presented at the High-level Dialogue on Financing for Developing at the United Nations, New York, October 2007, and titled “Are the bank regulations coming from Basle good for development?” It was also reproduced in The Icfai University Journal of Banking Law Vol. VI No.4, India, October 2008

@PerKurowski ©

Has the SEC really shown such merits that Patrick Jenkins has to stand up in their defense against bullies?

Sir, Patrick Jenkins, in “SEC should stand up to asset management bullies on liquidity risk” of March 15, writes that some “even accuse the SEC of attacking the very essence of American free markets”

Those “bullies” are right! Risk weighted capital requirements is something totally incompatible with free markets, whether in America, Europe or anywhere else.

And let us not forget that the main reason the investment banks supervised by the SEC suffered more than the commercial banks supervised by the Fed and FDIC, was that in April 2004, the SEC gave in to the Basel Committees' capital requirements.

That some “blame the SEC’s poor regulation…for the risk that exists in the system”, is not something outlandish.

In November 1999 a began an Op-Ed titled “About the SEC, the human factor, and laughing” with: “A couple of days ago, SEC reported that their pension fund had also been the victim of a fraudulent stock-managing firm, and that they had lost a lot of money”. And I ended it with: “the possible Big Bang that scares me the most is the one that could happen the day…regulators… playing Gods, manage to introduce a systemic error in the financial system, and which will cause its collapse.

I have no idea why Patrick Jenkins goes out defending the SEC with his “415 pages of often technocratic proposals, the regulator suggest some sensible mechanisms to mitigate the fast-growing risks in the fast-growing asset management industry.”

Any regulators who have to write 415 pages to propose some partial solution, is only working for himself and for friendly regulation consultants. I am sure those 415 pages, which I have not read, contain all type of dangerous distortion and gaming possibilities.

@PerKurowski ©

The strongest opposition to a universal basic income (UBI) would come from the redistribution profiteers to be substituted

Sir, John Thornhill discusses an upcoming book of Andy Stern titled “Raising The Floor”. In it the author “argues powerfully for the US government to provide a universal basic income (UBI) of $1,000 a month to every citizen” “A basic income — welfare for the digital age” March 15.

Having seen a real fortune in oil income being wasted and stolen away in my homeland Venezuela, I have for soon two decades been proposing something similar… although clearly there we would be talking about much less money per citizen.

In Venezuela, during the years of XXI Century Socialism I seriously doubt its poor got more than 10% of what would have been their per capita share of the country’s net oil revenues.

And lately I have also proposed a Pro-Equality tax on the wealth of all paid out in equal shares to all.

But, when it comes to opposition to the idea, that will surely come the strongest from the redistribution profiteers… those who have a vested interest in doing the redistribution.

@PerKurowski ©

Why do regulators insist in realizing bankers and insurers wet dreams? It costs the real economy too much!

Solvency II does to the insurance industry what Basel regulations did to banks. It introduces what is known as the “risk-based approach” to capital and regulation.

In essence it means more ex ante perceived risk more capital, less ex ante perceived risk less capital.

That translate into the lesser the ex ante risk is perceived, the more you will be able to leverage your capital.

And the more you are allowed to leverage capital, the higher are the expected risk adjusted returns on equity.

And so, just like it realized the banker's wet dreams (more elegant "nocturnal emissions") Solvency II should now realize those of the insurers… namely that of being allowed to earn the highest risk adjusted returns on equity on what is perceived as the safest.

Evidence of the existing enthusiasm we find when Oliver Ralph quotes Omar Ripon, partner at accountants Moore Stephens with “Risk-based capital is a great thing. The best firms are looking at using it to improve their returns. If you only look at it from the compliance angle, you won’t get the benefits.” “Insurance divides over shared rules” March 14.

Unfortunately allowing bankers and insurers to realize their wet dreams has a very high cost for all the rest of us.

First it obviously distort a lot in the financial markets in terms of how credit, investments and capital is allocated.

When the European Commission explains why Solvency II is needed they hold that Solvency I “does not entail an optimal allocation of capital, i.e. an allocation which is efficient in terms of risk and return for shareholders”

But that is certainly what the risk based capital approach cannot do.

That is because all risks that are considered by the capital requirements are risks that have already been perceived and cleared for in other ways, by means of risk premiums, amounts of exposure and other.

And any risk, even if perfectly perceived, if it is excessively considered, causes the wrong action.

And then of course “hiding risks” or production of Potemkin ratings, which allows for higher leverages, becomes a competitive tool.

“Any risk you hide I can hide better, I can hide better the risks than you can… No, you can't - Yes, I can - No, you can't Yes, I can! Yes, I can!”

And if the distortions in capital allocation to banks and insurance are bad, the distortion it produces among those who access bank credit or insurance investment funds from the insurance companies is much worse. It will mean the “safe” will get too much, much more than what they already get (making them risky) and that the “risky” will get too little, much less than what they already get… and as a consequence our real economy will suffer a lot.

I know too little of the insura © nce industry to estimate their capital requirements but, in the case of banks, these should be required to hold 10 percent in capital against all assets to cover for the unexpected, which, even though it can be expected, includes such events as regulators having no idea of what they are doing.

PS. I challenge you to read the European Commission’s explanations of Solvency II and count the self confessed distortions it will produce.

@PerKurowski

Lucy Kellaway is my large glass of wine that keeps me suscribing to FT and writing letters to its (quite dumb) editor

Though that would clearly be highly unethical journalistic behavior, it is clear that someone somehow must have issued a strong, very strong, recommendation to ignore my letters to the Financial Times.

And obviously that should have me raving mad and cancelling my suscription to FT.

But it is when I read something so great like Lucy Kellaway’s

“The reply consisted of one word: Noted. This was the perfect passive aggressive response. It was just about polite enough for me to have no legitimate grounds for complaint. It shut down the discussion, and left me with only one sensible course of action — to pour myself a large glass of wine and see”

... that all is forgotten. That it is just the kind of my large glass of wine that keeps me suscribing to FT... and keeps me writing letters to You Dear Editor.

With my very best regards

Per Kurowski

PS. I sure hope and pray this will not create any trouble for Lucy Kellaway. Sir, I swear she’s innocent!

@PerKurowski ©

Wolfgang Münchau, what has risk weighted capital requirements have to do with the primary functions of banks?

Sir, Wolfgang Münchau writes: “Monetary policies, like the ECB’s quantitative easing program, filter into the real economy through various channels.” “The European Central Bank has lost the plot on inflation” March 14.

That is correct but again, so stubbornly, Münchau refuses to mention the not so unimportant fact that credit risk weighted capital requirements for banks, especially when regulatory compliant bank capital is scarce, seriously distorts the allocation of bank credit to the real economy.

Münchau also refers to ECB’s “targeted longer-term refinancing operations” in somewhat skeptical terms, arguing that there is no evidence of ample demand for loans. But there again I would ask if the lack of demand for bank loans is not a reflection of SMEs and entreprenuers having seen their loan applications so much rejected? And again those rejections are much the result of that kind of “risky” lending generating the highest capital requirements for banks.

Helicopter droppings? Yes but why not eliminate the regulatory distortions that serve no purpose first?

I was recently made aware of a paper written by Hyman P Minsky in October 1994, titled “Financial Instability and the Decline (?) of Banking: Public policy considerations”

In it Minsky describes the two primary functions of banking as supplying the means of payments; and channeling resources into the capital development of the economy.

And so Münchau, unless you disagree with Minsky, let me ask, for the umpteenth time, what has the pillar of current bank regulations, the risk weighted capital requirements, to do with banks fulfilling efficiently those two primary functions?

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

@PerKurowski ©