What derives from what?

Sir we used to believe derivatives derived from the market but each day that passes, with articles such as "Derivatives law sheds light on the financial ripple effect" Aline van Duyn, August 29, we suspect that it could equally be that it is the market that derives from derivatives.

This reminds me of what I have always felt about the issue of immigration and securing the borders, namely that whenever you build a wall you cannot be absolutely sure you end up on the right side of it.

The minimum minimorum of exiting Iraq!

Sir your “Exiting Iraq”, August 26, concentrates mostly on the logistics of getting out, like not leaving permanent bases and receiving legal immunity for the forces. After so much suffering can we not be more ambitious?

I was never in favour of the invasion of Iraq but, once it occurred, I pleaded for a scheme that would put its oil revenues directly into the pockets of all the Iraqis, and thereby set an example that could help to empower the democracy in all the other countries that are cursed with the centralization of their oil revenues… the mother of all oil curses. Unfortunately, the supposed builders of democracy forgot bringing with them to Iraq such a fundamental building block.

Now, when exiting Iraq, as a minimum minimorum, we should at least aspire that the next Saddam Hussein, whenever he will appear, should not find it easier to be the next Saddam Hussein… much the same like the next Bush, whenever he will appear, should not find it easier to be the next Bush.

Financial traffic jams are also caused by financial Global Positioning System

Sir we are grateful to Christopher Caldwell for drawing our attention to "Traffic" by Tom Vanderbilt, "Caught in the human traffic", August 23. From what we see that book should urgently be made obligatory reading to all bank regulators in Basel, so that they learn what happens when you impose credit rating agencies as the Global Positioning System supposed to direct the financial flows of the world.

That "Predictions about traffic become 'self-destroying'" is exactly what lies behind that systemic risk that brought us the subprime mess. They should have known it!

"Once everyone gets the same reliable real-time information about traffic everyone mobs the same route" questions the whole underpinnings of our current bank regulations, namely that you are able to measure risks without affecting the risks.

When the book quotes German physicist Michael Schreckenberg "telling them the whole truth is not the best way" we begin to understand Angela Merkel's request for a purely European credit rating agency.

We need to look at other possible explanations than trade

Sir Jagdish Bhagwati in “The selfish hegemon must offer a New Deal on trade” August 20, complains that “the labour lobbies believe, without any compelling evidences, that the American wages have been stagnant because of competition from the developing countries”. But, even if he is right, since he offers no other alternative explanation for the widening gap between the returns to capitals and the returns to labour in the economy, he is actually helping to keep the focus on trade as being the culprit.

Bhagwati would serve his worthy cause better by pointing out the effects of other developments that have run in parallel to the growth of global trade. How much of the capital-labour gap could be explained by the following?

1. The discrimination implicit in risk based pricing that has allowed the financial sector to charge some groups with extremely high interest, based on some quite dubious logical reasons. Borrowers that cannot pay the high interests should not have received the loans to begin with, at least not at those high rates, and those who can serve the loans have de-facto evidenced they merited lower rates.

2. The growing tendency to use intellectual property rights of all sort and kinds to create unregulated monopolies that capture rents.

3. The increased regressiveness of taxes that results from the tendency of turning away from taxing income to taxing consumption.

Net out the effect of those three factors and you might not have anything left to blame trade with.

Indeed how will this risk-based priced consumer generation respond?

Sir Aline van Duyn is exploring vital terrain in “Hard-pressed consumers refuse to read from script” August 18 analyzing how this generation of “risk-based priced” consumers will respond.

Just for a starter there must be a world of difference between having you credit worthiness assessed in an eye to eye conversation by a lending officer and today’s having a computer read you number. At least it must be affecting the moral implications in the “to pay or not to pay”.

I suspect we will also see a growing reluctance from the high interest rate payers to remain in that group since if they can service their debt adequately at those rates they might feel they are de-facto meriting lower rates.

Risk based pricing, which is similar to placing persons that after some doubtful genetic test are presumed to be especially exposed to an illness in a separate insurance pool, could be causing much of the growing social inequality that is currently attributed by some to globalization. Risk profiling, for a discriminatory purpose, is prohibited in most spheres of our social relations, except in lending where it is very much cheered, by most.

On unwelcome advertising

Sir John Gapper in "Advertisers will see you read this", August 14, describes very well how the advertisers wish to obtain more and better information on our habits and how this could intrude on our rights to privacy.

That said let us also not forget there are occasions when it is the website or the user who wishes to be identified better so as to avoid the messages or the publicity they do not want to see.

In Venezuela, a radical anti-U.S. website, but that still wish to generate some advertising income, because of its name revolves around "sovereignty", frequently attracts recruitment ads for the U.S. Marines. I supposed this must be of extreme nuisance to the owner of the site.

How do you nudge the Financial Times?

After having tried it and failed miserably I would love to ask Richard Thaler or Cass Sunstein about how to go about to nudge the Financial Times… firmly or gently? Any special tips?

It is impossible to fight graft when its origins are in the centralization of a big oil income

Sir you write in “Nigerian graft”, August 12, that “the most important battle at home looks likely to be lost” and yes, at current oil prices, the battle was lost before it even began. Any country where the oil revenues are centralized in the hands of government and where they come to signify more than for instance 5 percent of GDP and thereby make the government wealthy, independently of its citizens, will be swamped by graft, in whatever shades or colours it comes, whether open, hidden, informal or de-facto, whether in pseudo-democracies or real autocracies, whether in Nigeria, Russia, Saudi Arabia or Venezuela.

What an opportunity was missed in Iraq when someone decided not to implement an oil revenue sharing plan for its citizens! That way Iraq was condemned to a non functioning democracy and to living in graft.

Is FT backing Paris Hilton?

Sir you quote Paris Hilton saying something funny and smart on your first page, August 9, and then you have John Gapper write "The president of hedonism" with the leader of "The LA heiress is no average airhead" just to end up informing that what was quoted, "the script" as it is called, was written by somebody else. What on earth has happened to FT? Let the celebrities fight out among themselves but FT has nothing doing blatantly favouring one over another. This is a perfect opportunity for transparency and so, without fear, please disclose how this article came about.

And what about the AAA sails?

Sir Niall Ferguson, in “How a local squall might become a global tempest” August 8, tries to analyze how “primarily a US affair” and that according to him “has its origins in a US real estate bubble fuelled by easy money and lax lending standards” could extend globally and go nuclear in strength. I am sorry but he completely misses the story.

To talk as Ferguson does about howling winds and a perfect storm in the world of finance and ignore the existence of the new sails that were able not only to capture the smallest breeze but even to change the direction of the winds, is to turn a blind eye on what happened . The outlandishly bad mortgages given in the back-yards of some American cities would not have gone anywhere, and the capitals of the world would not have travelled to these back-yards either, had it not been for the “AAA No-Risk” sails hoisted up by the risk kommissars appointed by the financial regulators, namely the credit rating agencies.

Finally on “decoupling” what on earths is he talking about? The credit ratings risk assessments is what has coupled the whole financial world and these couplings, or shackles, are still in place. Q: Which was the first bank that lost out on the subprimes? A: A German bank. Q: And what have China, Russia and many other countries lost in official investments coupled to the subprimes? A: Anyone’s guess, though I have a feeling I would not like to be in their financial advisor’s shoes right now.

You’re free to go anywhere… but use my guides.

Sir in trying to place the “Credit crunch in a century context” August 8, you mention that the “financials flaws and perversions exposed by the credit crunch are on a par with 1920s” giving as an example “the moral hazard that allowed lax mortgage lending, because the risk would ultimately be sold to a third party via securitization”.

In doing so you keep on ignoring that what made it possible for the lax mortgage lending to make its way into securities for which there was a market, were the prime ratings awarded to these instruments by the credit rating agencies, the supreme risk surveyors appointed by the bank regulators.

You also conclude that “The free flow of international capital is not under threat”, but try to tell that to all those that were led over the subprime mortgage precipice by those traffic signs saying AAA No Risk. With the information on risks already concentrated in the few hands of the official guides and whose “opinions” are imposed on the markets forcefully by the regulators, it is hard to sustain the notion that freedom of flows and free markets still prevail.

A good piece on Venezuela

Having been quite critical of some of Benedict Mander’s previous reports on Venezuela let me just express that I found his “Venezuela’s televised revolution”, August 8, accurate and balanced… though I guess that Mander will be exposed to criticism from any of the extremes that crowd our airwaves, c’est la vie… I write weekly in Venezuela in green but most of my readers there can only read me in yellow or blue.

Given the inevitability of the bust we need to make more of the boom

Sir Willem Buiter in “Welcome to a world of diminished expectations” August 6, takes the role of a neutral and detached observer when he rightly acknowledges the unavoidable boom-bust cycles in the economies around the world and looks into the future for clues. That is good, but how much better would it not be if he had dared to make some recommendations on how to go about to make the most of the boom-bust cycle itself. I mean, when I have a hangover, much of the way I feel about it, has to do with whether the party was worth it or not.

At this moment we live in a world where financial regulators are only concerned with avoiding the bust, but is it not time for them to start thinking more in terms of helping to make the most out of the boom? The worst part of today’s headache with the financial system, is that the party seems not having been that good, except of course for some of the financial intermediaries who enjoyed it enormously.

Competitive financial markets and risk information cartels do not go hand in hand

As global public goods go credit ratings have certainly not proven their worth. Alan Greenspan, the former chairman of the US Federal Reserve, now has the galls to tell us “The world must repel calls to contain competitive markets” August 5, after having been absolutely silent while the credit rating agencies, empowered by the financial regulators as risk information cartels, imposed their opinions on the markets in clearly uncompetitive ways. Why do not regulators, like soldiers, just fade away?

Do not blame the sprinklers, blame the sprinkler inspectors and the smoke detectors

Sir Joseph Stiglitz in Fannies and Freddie’s free lunch July 25 holds that “No insurance industry would provide fire insurance without demanding adequate sprinklers; none would leave it to “self regulation”. But that is what we have done with the financial system.” Wrong. Insurance companies would and should provide fire insurance even if there are no sprinklers, as long as the risk premiums are right. What happened was that the financial regulators outsourced the checking of the sprinklers, and the installation of smoke detectors, to the credit rating agencies and these fouled it all up, reporting no smoke when burning and sprinklers where there were none.

Free lunches just for current homeowners?

Sir Joseph Stiglitz in Fannie’s and Freddie’s free lunch July 25 proposal of “converting the home mortgage deductions into a cashable tax credit” begs the question, and what about those who rent and those who would want to see house prices come down so as to be able to afford one on their own? The Home-Owners Church giving out free lunches only to their own destitute and ignoring all others is starting to look like pure discrimination.

It is a myth that the financial markets were freed

Sir Paul de Grauwe writes “Cherished myths have fallen victim to economic reality” July 23 and mentions as one of the fallen that the “financial markets have to be freed from the shackles of government control”. This is simply wrong. The current crisis can be directly blamed on the fact that the regulators shackled the banks and many investors to some government appointed few outsourced risk overseers, the credit rating agencies, and these later led the banks, the investors and the regulators over the subprime mortgage precipice. To make it worse, these shackles are still being fully enforced.

We all need an insurance against what they are going to think they have discovered in our DNA

Sir in “The fallacy of the ‛choice agenda’”, July 18, Sir Samuel Brittan enters briefly into asking what will happen to health insurance when DNA records come to provide detailed health prognosis. I would answer, just what happens when credit records provide detailed information to lenders, that the borrowers often get bunched together into small groups of misfortunate outcasts that have to take care of each other. For instance, among the subprime we find those who are not able to serve a loan at very high interests, and therefore lose out, and those who by being able to serve their loan de-facto evidence they deserved a lower rate, and therefore also lost, making it truly hard to distinguish a winner.

Since Brittan also correctly states that “insurance is well suited to covering events that are unpredictable at the individual level” let me say that for over a decade I have held that the most important new insurance coverage we all need is that of the risks derived from what they are going to think they have discovered in our DNA.

Could axing an anti-graft watchdog actually reduce graft?

Sir I read the report by Guy Dinmore and Michael Peel titled “Italian premier to axe anti-graft watchdog” July 18 and was of course duly upset. But then I started to think about the figures mentioned and as a yearly budget of 2.5m Euros to fight corruption in Italy seems not to be sufficient it could actually be more honest, and less corrupt, not having a watchdog at all.

It also reminded me of once when at an anti-graft conference I commented that those selling themselves as “anti-corruption experts” sometimes sounded to me as if they could themselves be involved in an extremely subtle form of corruption. I got some strange looks!

What we need to make sure is that any financial crisis results at least from something worthwhile.

Sir John Eatwell and Avinash Persaud, in “Fannie and Freddie, damned by a Faustian bargain” July 18, write the following: “The main cheerleaders for the marketisation of banking were the gnomes of Basel – the centre of international bank regulation. Many regulators thought the “marketization” of banking represented a brave new world, where grizzled, idiosyncratic lending officers were replaced with best-of-breed credit models, policed by third party rating agencies and, where risk was digitised, spread across a large number of investor and traded. But it was a Faustian bargain…. We need to redraw the lines of financial regulation. A critical objective should be to preserve diversity, not create artificial homogeneity in the blind pursuit of common practice.”

Of course as I have been writing and fighting along those lines for over a decade I totally agree with them on this. But when they suggest that regulators need to focus more on the risk capacity of the institutions, primarily their funding structure, there I lose them. The first think we need to focus on is what the real purpose of our financial system should be since currently it seems limited to avoid any type of crisis and that, besides being unrealistic, sounds like a truly pitiful objective.

Since a financial crisis is natural and will happen no matter what, we need to make sure that any financial crisis at least results from something worthwhile.

Politicians and regulators are the same… they only look out for their own interests.

Sir Erik Berglof and Raghuram Rajan in “Progress in emerging markets is being put at risk” July 18, and as a result of the current crisis that gives oxygen to populism, say that “Many of the actions against the financial sector are proposed in the name of the poor, even though the true beneficiaries are the politicians themselves. Absolutely true, but just in the same vein it can be said that most of the current bank regulations are exclusively the result of regulators only wanting to avoid a crisis on their watch, selfishly not caring a jota about the true development needs of the poor and the not so poor.

What would the founding fathers say?

Sir Sam Natapoff recounts part of the US financial history in “Finance and the Fed: the battle is not over” July 17. What I would have found really interesting though is to hear him speculate on what the founding fathers would have said about the following issues:

a. The empowerment of the credit rating agencies with the capacity to influence where the capitals should flow, as they currently do through the minimum capital requirements for the banks that are primarily based on the risk ratings.

b. Favouring the government coffers, because when a bank lends money to the government it does not have to put up any capital, something equivalent to an infinite credit multiplier, but if it instead wants to lend to a private, then the shareholders would have to put up 8 dollars or more for each 100 lent.

c. That the savings of the nation are by means of the current regulatory system strongly biased towards financing sectors that can be construed as low risk, such as mortgage lending (ha!) when compared to other more risky but perhaps more nation developing endeavours such as decent job creation or the reduction of climate change risks.

The managers of the oil extracting nations simply cannot manage more oil revenues.

Sir Martin Wolf in “A year of living dangerously for the world’s economy” July 16, quotes Daniel Gros of the Centre for European Policy studies on that oil producers (more correctly oil extractors) will leave oil in the ground if the rise in real oil prices is expected to be faster than the return on the alternative assets. Nonsense! Any private company would at current prices be selling oil like crazy to make their shareholders happy. The problem is that there are no real shareholders in many of the oil extracting countries and so even if their citizens, their equivalent of the shareholders, would love to see more oil revenues coming into their pockets, their respective governments have enough trouble managing the huge oil revenues as is.

Why should on earth should Venezuela extract more oil… if all what the government can thing of doing with it is giving it away to London?

What a splendid moment for an America Union!

Sir when reading Martin Wolf’s “A year of living dangerously for the world’s economy” July 16, and seeing him speculate that in terms of government indebtedness the US could soon look like Italy, I cannot help but thinking about what a particularly splendid moment it would be for the announcement of an American Union between the US, Canada and Central America.

Analyzing these countries you see how well they complement each other in economic terms and so the worst thing that could happen for the US now would be to build borders and shrink their GDP numerator just when the check arrives with a high debt denominator.

On averages and dark pools

Sir Rupert Macey-Dare´s suggestion to “Upgrade models to blend in pricing information” July 14, which is sort of looking at the difference between how the market prices risk and how the credit rating agencies see is intuitively attractive. That said we have to remember that an exact average does not signify a perfect average and also the fact that if the dark pools where trading occurs in a hidden way and that have been lately so much mentioned really take off then our market price data might not reflect the real market price.

By the way will there be some ownership of the data in the dark pools that will allow for their commercialization at a price? A new line of business? Dark pools of student grades which parent have to pay for to see?

Castigate the regulators

Mr Pietro Calice writes that “Sanctions and enforcement rules are needed to regulate the rating agencies”, FT July 11, but what seems most needed are sanctions and enforcement rules to regulate the regulators. How many financial regulators have been fired having been found sleeping on their job after they outsourced the watch out to the rating agencies? None? Yep!

To me there are clearly none more responsible for the current calamities than the regulators that thought up the crazy idea that it is possible to drive risks out of banking forcing the banks to heed the specific opinions of the credit rating agencies and without creating even larger systemic risk.

These regulators though they perhaps should not be sent to jail, should at least be named, shamed and fired… otherwise all talk of accountability is just a farce. If an impossible construction is contracted out who is really guilty when the construction falls?

I guess it is time for your reporter to change location

Sir I am sorry but Benedict Mander completely misses the angle when in “Red tape congests Venezuela’s roaring car trade”, July 11, he describes the governments “new rules that 30 per cent of cars sold from next April must have dual natural gas and petrol tanks” as something extraordinary. I just need to ask what extraordinary measures he believes the Crown would have to take to reign in car sales if it sold petrol at 4 cents of a dollar per litre and if it subsidized the import of new cars by means of an exchange control system.

When a foreign reporter does not see the absolute grotesque in the state giving away petrol at prices below distribution costs, I guess that reporter has been to long in the country and has become blind to its realities. There is supposedly a study that shows that people after having lived long enough close to a railway station do not even hear the trains, because of natural anatomic process of adjustment.

Just another case of managers running their personal agenda.

Sir Daniel Gros writes that “it is no mystery that oil supply has not reacted to higher prices. Producers are just waiting for even higher prices tomorrow”, “The China bubble fuelling record oil prices” July 10 and this is far from the whole truth.

The problem lies in that in the many countries where the oil belongs to the State, the current oil revenues exceed their respective governments’ capabilities to use them rationally, and their respective leaders’ most immediate personal needs, and so there is not a lot of incentives for them to produce more.

If on the other hand in all these countries, where the population still suffers many unsatisfied needs, the oil revenue was to be shared out directly to the citizens, the true shareholders, you would see more supply. Again it is all another case where the management run their personal agenda.

Gros quotes King Abdullah of Saudi Arabia that if additional oil were to be found in his country he would advise leaving it in the ground because “with the grace of God our children might have a better use of it” and this he can say only because the current children of his land have no say on it.

Give more freedom to the commercial banks

Sir of course I agree with Frank Partnoy in that we need to “Do away with rating-based rules” July 9 (my over 100 letters on the subject to FT should attest to that) but I would not necessarily stop at picking a substitute like the risk assessments made continuously by the market and as Partnoy seems to suggest, but change the whole current system of minimum capital requirements that differentiates among risks and go for flat percentage capital requirements, that could be higher or lower depending on the conditions of the economy.

That way we put the responsibility for taking the financial decision squarely back on the shoulders of the market and the individual bankers by eliminating the almighty excuse impossible to avoid of “I just followed the advice of the credit rating agencies that my bank regulators appointed”.

The traffic signs set up around the world by the credit rating agencies indicating low risks and the minimum capital requirements for the banks hijacked the commercial banks. It is high time to free them since we do indeed need their cooperation in channelling our resources to more productive uses than the building of subprime-mortgages financial pyramids.

As disaster producers, do not underestimate the humans

Sir John Kay tells us to “Forget the meltdown worry about goo and asteroids” July 9 and his arguments goes along the line that the damage humans can cause is modest relative with the damages nature can cause. On the surface it would seem that he has a point but given that humans are no cats and have only one life it does not really matter whether a disaster is capable of killing you once or a million times over.

Also he should not forget the havoc humans create while trying to tame the nature. Just look at the financial sector. Our risk-busters appointed the credit rating agencies to eliminate the risks and what did these do? They concentrated their prime-rating rays too much on a part of the market so that it exploded, bubbled, only later to implode, hopefully in a bunge, but that will foreseeable cause many sufferings, and worldwide, you can’t hide this fact, many onetime deaths.

Whatever, do not make the poor countries trust they can count on the rich ones

Sir Martin Wolf in “Why the obstacles to a deal on climate are mountainous” July 9, repeats frequent arguments of why the costs associated with the reduction of carbon emissions should be borne by high-income countries. Nothing wrong with that except if doing so makes the poor countries actually believe this is going to be so.

Since I am certain that Martin Wolf like me suspects that the possibilities of the high-income countries picking up the tab on this are almost nil, may I suggest that a more productive and honest line of argument would be on the line of the following:

“You poor countries, you better take special notice since in most of the climate change impact studies you seem to be dangerously exposed and since you most probably will not be helped sufficiently by the rest of the world community, you better stop copying the rich countries unsustainable habits, and start cracking on preparing yourself for the worst, on your own. And who knows, there might even be some great hidden benefits in doing so.”

We need a new batch of bank regulators

Sir these days the credit rating agencies are getting pounded on, as they should be, for instance as described by Joanne Chung and Michael Mackenzie in “SEC sees conflicts of interest at rating agencies” July 8, but the really frightening issue is how on earth we landed ourselves some bank regulators that trusted so much the credit rating agencies.

No matter what you believe the credit rating agencies they do not even intend to look into the future, they just extend the past into the future, and so they do not even purport their ratings to be correct, and besides that they are manned by humans and therefore bound to err.

But all that did not stopped the regulators from assigning to the credit ratings agencies the role as supreme risk overseers and by doing so reinforcing the beliefs of all those who wanted to believe that the future is manageable. And, like lemmings, the market followed the officially endorsed credit rating agencies over a precipice, and will do so over and over again. Is it not high time to get us a new batch of bank regulators, some that are more knowledgeable of the very basic facts of life?

And the lesson number one is....

Sir, Martin Wolf in “The lessons to be learnt from today’s financial crisis” July 2, 2008 quotes the Bank of International Settlements annual report stating “loans of increasingly poor quality have been made and then sold to the gullible and greedy”. Although I find it hard to think of a market that does not use greed as one of its main motors it is really the “gullible” part of it all that really blows my mind.

Who on earth is BIS to talk about gullibility. Was it not the Basel Committee on Banking Supervision that BIS hosts that set up a system based on credit risk assessments and that appointed the credit rating agencies as the supreme risk measurers? If we normal citizens and investors are gullible of anything it has been of believing that the Basel bank regulations had taken care of the problem once and for all, and that the credit rating agencies knew what they were doing.

BIS also mentions “the inherent procyclicality of the financial system” to argue for tighter monetary conditions when credit soars…but not a word about how the risk rating and the consequent “massive re-rating of risk” can send cyclicality soaring to the moon.

No, if there is a first lesson to be learnt it is that central bankers and bank regulators are, no matter how knowledgeable and pompous they act, only humans prone to err, and so it behoves us not give them too much powers, which is what makes them truly scary and dangerous.

PS. A letter on this theme to FT back in 2004.

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

The bank directors have the mother of all the good excuses.

Sir Francesco Guerrera and Peter Thal Larsen wrote a full pager on June 26, 2008 titled “Gone by the Board?” on why the directors of big banks failed to spot the credit risk. Though it is not my intention or role to defend bank directors I must in all honesty say that they completely left out the most important argument the directors could use in their defence.

Just think about a knowledgeable and a responsible director’s chances to convince his fellow directors that the securities backed with subprime mortgages and rated prime by the credit rating agencies and appointed to such a task by the bank regulators themselves were not prime as he had heard rumours that the mortgages were not awarded with the same usual care. None? I would say so.

If you want a board to act you have to let it act and not let them believe that the credit rating agencies are doing the job for them.

But the citizens of the oil exporting countries would love to consume…if given a chance.

Sir Martin Wolf says in “How to manage the world economy through two crises” June 25 that the ongoing transfer of wealth from oil-importing countries to oil-exporting countries… from those who spend to those inclined to save… will curb the rise of global demand” and he is right, but it should not have to be that way. The reason for him being right is that the wealth transfers goes into sovereign funds or other government pockets and not to the citizens of the oil-exporting countries who would also gladly step up their consumption.

Today, in Venezuela, I am publishing a fictitious letter from Arnold Schwarzenegger in which he offers to buy on a rolling five years average price 2 million of oil barrels per day to satisfy the needs of his constituency and take the worst volatility out of the market. To stimulate Venezuela entering into such a country he is offering to pay an equal share of the proceeds, to each one of the 26 million citizens of Venezuela, in the currency and in the individual account each one of them would like.

http://opinion.eluniversal.com/2008/06/26/opi_769_art_de-arnold-para-venez_26A1723279.shtml

Indeed moderation needs to be sustained…but it better be the right kind.

Sir Stephen Cechetti wrote “We need to sustain the great moderation”, June 23, 2008 and I initially thought he meant a “from-now-on”. To my big surprise, reading it I then saw that he refers to the period 1985 to 2005 when the $500bn in home mortgages grew to $9,500bn, signifying debts of about 7 months of the current GDP, and of which $7,500bn was used for securities, as the “moderation” that with some minor tweaking, needs to be sustained.

On what planet does he live? As I see it the most important result of that boom was to make the USA even more energy dependent, in the midts of an environmental threath, and luring many babyboomers to anticipate their current consumption.

Can you imagine how much better the US would have been off if those $9,000bn had gone to infrastructure investments that prepared the US for the new realities?

But of course that could never have happened when the bank regulators all they care about is to stop the banks from defaulting… no matter where the rest of the country ends up.

Indeed moderation needs to be sustained…but it better be the right kind.

The real conundrum is… what is the purpose of the banks?

Reading “The conundrum of financial stability” June 20 we get the impression you have been boxed up with those bank regulators for whom everything in life circles around stability, on their watch. You discuss the problem of the central banks having the dual responsibility of macroeconomic and financial stability, but forget that out there, in the real world, stability itself is not enough, we want and we need more.

How the financial systems could help to create decent jobs and avert real threats such as those from arising from climate changes, are issues much more important to discuss than just how banks can avoid to default but, unfortunately, almost by definition, central bankers are not at all interested in those themes, and much less now when having convinced us that they need independence they have been granted their own full stability, given that we cannot fire them.

Angela Merkel, helps us understand, thanks! And now credit rating agency Del Sur!

Sir the world at large needs to show Angela Merkel much gratitude for when she says “I think that in the medium term Europe will need a working ratings agency because the robust currency system of the euro has not yet secured sufficient influence over the rules governing the financial markets” June 11, she is in fact daring to lay bare the fault in the whole fundamentals for the use of the credit rating agencies, namely that these agencies could, objectively, without bias, and presumably without mistakes, measure risk.

Not so, whether through bias or through mistakes they are as humans to err and with their signalling lead us in the wrong directions or even over precipices.

I can already hear a hugo chávez call for a credit rating agency Del Sur!

But foremost we need a new direction for our growth

Sir Martin Wolf writes that “Sustaining growth is the 21st century’s big challenge” June 11 but as the article is set in the perspective of the environmental and energy limitations that the world now faces and that Jeffrey Sachs has written a book on a better title would have been “Re-direction growth so as to make it sustainable is the 21st century’s big challenge”.

Now how do you do that? First of all by measuring growth in terms that makes more sense. That a dollar used to buy the family’s third car in a developed country should count as much as the dollar used to pay for the vaccine for a child in Africa does somehow not seem to give us the right compass bearing we need.

Why can’t you have sensible long term contracts in oil?

Just the sheer possibility of losing a tenure based on no particular fault of their own, could do wonders for the educational system, infusing it with a minimum required dose of uncertainty, and thereby allowing tenured professors to at least to understand the concept of anxiety.

Sir in “Double, or quit?” June 10, you say that “Volatile prices get in the way of sensible medium-term contracts to produce or deliver oil-intensive goods and services” June 10 and you are right but why on earth you cannot extrapolate that into the need for sensible medium-term or even long term contracts for oil itself, to bring down that uncertainty that hinders more investment is indeed very hard to understand.

We need to avoid monopolies or oligopolies in the market of risk-appraisals.

Sir it is indeed comforting to read the president and chief executive of the Federal Reserve Bank of New York Timothy Geithner admit that “Regulation can distort incentives in ways that make the system less safe”; but also disappointing that in his Op-Ed “We can reduce risk in the financial system”, June 9, there is not a word about how the appointment by the regulators of the credit rating agencies as their delegated risk surveyors, reduced the incentives for the rest of the markets to do their own risk appraisals.

We need to avoid monopolies or oligopolies in the market of risk-appraisals.

Sir it is indeed comforting to read the president and chief executive of the Federal Reserve Bank of New York admit that "Regulation can distort incentives in ways that make the system less safe" but also disappointing that in his Op-Ed "We can reduce risk in the financial system" June 9 there is not a word about how the appointment by the regulators of the credit rating agencies as their delegated risk surveyors, reduced the incentives for the rest of the markets to do their own risk appraisals.

We need to establish a worthier purpose for our banks than just avoiding a default

Sir Ken Lewis the Chairman of Bank of America in “Markets alone will not lead to a green future” June 6 says that “the private sector needs a stable and predictable regulatory environment with a bias towards clean energy and the green economy”. By doing so, perhaps unwittingly, he points out the major failure of our current bank regulations, which is that they are biased exclusively towards eliminating the risk of bank defaults, as if that is the only risk with the banks for the society. In fact the risk of the banks not doing their part in the development of the society is much more serious than the risk of having to go through a bank crisis.

In this respect instead of applying minimum bank capital regulations base solely on risks of default, most often as measured by the credit rating agencies, we need to give more purpose to banking, perhaps by starting to think in terms of units of risk of defaults per environmental hazard avoided or per decent job created.

More confidence requires more distrust

Sir Robert Jenkins writes that “Confidence is what we need, not more alchemy” June 6, but let us not forget that it was an excess of confidence, by the regulators in the capacity of the credit rating agencies, that caused much of this turmoil. In this sense we could reach the somewhat peculiar conclusion that confidence building must also include distrust building.

Free the banks from the chaperones and get the party going!

Sir Charles Goodhart´s and Avinash Persaud´s “A party popper’s guide to financial stability” June 5 reads like the desperation of a garage fixer to fix something with whatever epoxy he can lay his hand on.

I have myself often proposed a progressive tax on banks, based on the-bigger-you-are-the-more-it-will-hurt-if-you-fall-on-me principle but, what on earth do they mean by taxing the growth rate of bank assets, which is what raising capital requirements mean? That slow growing banks can just sit back and trade growth allotments, like if bank assets were carbon type contaminants?

No instead of worrying so much about the possible hangovers why do they not worry more about making the party better. The current risk adverseness implied in the minimum capital requirements based on risk and as measured by the credit rating agencies, have the markets playing boring and unproductive minuets, like consumer finance dressed up as “risk free” securitizations.

The world is clamouring for decent jobs, and if the banks are to help us create them, they need to be given more freedom and responsibility. In that sense, set the capital requirements for banks at a fixed percentage of assets and get the chaperones out of their hair, so that we can get more of that risky salsa that when if times comes for a hangover, makes it at least more bearable... since the party was great!

Should not all banking be sustainable?

Sir Lawrence Summers, June 2, gives his “Six principles for a new regulatory order” for the financial system and the next day you publish a full section on “Sustainable Banking” and there is absolutely no connect between them. Should not the ordinary financial sector and its commercial banks also be sustainable?

Ever since the Basel Accord the only thing in the agenda of bank regulators has been to avoid bank defaults and that cannot simply be all the purpose there is to banking. What a big irony that FT and IFC the private sector arm of the World Bank Group can find the need to mention sustainability and even award prizes to banks based on something that does not even appear in Basel I or Basel II or even in the thoughts of bank regulators.

In just the same vein we now read that “World Bank calls for microfinance rules” June 3 saying that “lenders making small loans to poor people in developing countries should be subject to regulation to prevent abusive practices” and we need to ask, does that not apply to lenders making big loans to rich people in developed countries?

The new regulatory order should correct the faults of the old one

Sir Lawrence Summers lists us “Six principles for a new regulatory order” June 2 and I wish to make the following comments. Though I do agree on that the risk of allowing institutions to determine capital levels based on their own risk models neither do I think it is up for the regulators to intrude artificially with their own subjective rulings. As is the differentiated minimum capital requirements based on credit ratings is imposing an arbitrary layer of risk adverseness on top of the market’s own with quite possibly long term dangerous results as society needs risk-taking in order to develop.

With respect to the need of avoiding that the failure of “an individual institution is not itself a source of systemic risk” there would seem to be no other route than placing limits on the size of the institution, perhaps based on a progressive the-bigger-you-are-the-more-it-will-hurt-if-you-default-on-us tax.

Finally there is a fundamental principle that Summers misses, that of avoiding the risk of the market relying too much upon other, such as the credit rating agencies. The least acknowledged lesson learned from the current sub-prime turmoil is that it would not have happened were it not for the credit rating agencies having been too much empowered by the regulators and a new regulatory order that is build without naming the faults of the previous one has little chance to become better.

What kind of reporting is this?

Sir Benedict Mander reports that “Drivers put cars blame on chávez for Caracas congestion” May 30, and nowhere does he mention that the purchases of cars is subsidized by means of the foreign exchange system and that petrol is sold for about 2 cents of a Euro per litre, and which has made a small country like Venezuela import 750.000 new cars to place on already jammed roads, in just two years. What kind of reporting is this?

Is Benedict Mander trying to hide the fact that this supposedly socialist government is taking way over 10% of Venezuela’s GDP from the poor people who have nothing and giving it to those citizens who have a car?

If you have to handle uncomfortable truths, go for the right ones.

Sir Philip Stephens in "Uncomfortable truths for a new world of them and us" May 30 blames the subprime mortgages turmoil on "the explosion in financial innovation made possible by ever more sophisticated information technology. This has… engendered among investment bankers and traders an insouciant indifference to risk". The real truth is much more uncomfortable than that.

The subprime mess has nothing to do with sophistication but with the fact that those who had been empowered by the regulators as supreme risk surveyors, the credit rating agencies, just did not do their job right finding out some very basic faults with the mortgages and that should have been easy to spot.

Stephens, referring to Washington consensus type of preaching to the developing world now tells us that in response to the turmoil the developed world must show the "willingness to see that this is a transformational moment that demands we look at the world entirely afresh".

He is right; and one of the issues on that urgent agenda must be to annul the dangerous paradigms that have taken over financial regulations. The first being that the only purpose of bank regulations is to avoid a bank crisis, when there is so much more to banking than that, and the second, the one that relates to the uncomfortable truth above, that it tremendously unwise to delegate so much regulatory risk surveillance power in some few agents that, as humans, are bound to err and take us over ever more dangerous precipices.

When in Rome, do not try to see every attraction but do not miss what has to be seen either

Sir Robert Zoellick making reference to a meeting among world leaders in Rome prescribes “A 10-point plan for the food crisis” May 30. That plan is somehow confusing in that it mixes immediately needed actions, the first three, that of fully funding the World Food Programme’s emergency needs; the support of vital safety nets and facilitating the access to seeds and fertilizers in poor countries, with other seven points, on some of which there is even an ongoing debate about whether they are right or wrong, like for instance whether to step up ethanol production from sugarcane, which consumes a disproportionate amount of water.

Since this food crisis relates more to economic growth and energy related than to unforeseen weather disasters, and there are many official watchdogs like the International Energy Agency, the Consultative Group on International Agricultural Research, even the World Bank, supposed to keep their eyes open, my suggestion of an 11th point, I believe far more important those point 4-10 suggested by Zoellick, is to figure out why world has been so taken by surprise with this food crisis and what can be done to improve the foresight.

Rating the rating agencies would be just digging us deeper in the hole.

The last thing we need is to create even more illusion that nothing can go wrong piling on top of current realities the concept of an AAA rated credit rating agency.

Sir, “Who rates the ratings agencies?” May 30, starts from the premise that the credit rating agencies need to keep the immense powers that regulators have awarded them and that they therefore need to get better. You are wrong on that! The way to go is to reduce the powers of the credit rating agencies and so that the rest of the market have better incentives to analyze credits, for instance banks could instead of rating readers and rating predictors employ credit analyst again.

If the banks were just needed to report as an information the minimum capital requirements as judged on the basis of the assessments of the credit rating agencies but were actually not forced to apply these capital requirements, and for example go for a fixed percentage of capital to credit instead, then that would make of credit rating agencies what they are supposed to be, information providers, and not what they are, regulation enforcers.

Let us also free the development experts!

Sir William Easterly, himself a development expert, after reading the report of the World Bank Growth Commission, tells us to trust the people, instead of development experts, “Trust the development experts – all 7bn of them” May 29.

Easterly bases his conclusions on Friedrich Hayek’s teachings on the need of freedom for “multitudinous individuals to figure out their own answers” arguing that experts cannot impose this freedom from the top down. He is right but having, as a former Executive Director of the World Bank 2002-2004, witnessed myself how the risk aversion of those who manage the business of development; the vested interest of those who hire the development experts, the governments; and the experts own often non functional peer reviews all conspire against creativity and promotes useless development jargon, we should not forget that the experts are also in need of much more freedom.

Humans and animals are still challengers to oil.

Sir although Daniel Yergin is absolutely right reminding about the disastrous effects of the price collapses [of oil] in 1986 and 1989 in "Oil has reached a turning point", May 28, it is much harder to agree that oil “seems to be losing its almost total domination in ground transport”, because of ethanol... since hybrids still run on oil.

In a world where cyclists and animal pulled carts are going over to cars and trucks, in many places, high oil prices, just makes humans and animals real alternatives again. Of course we could get some petrol out of coal, but, when push comes to shove, that is just another sort of oil, though perhaps slightly dirtier, no matter what the clean coal slogan says.

When it comes to oil FT does not write without fear and favour.

Sir once again, when it comes to oil, I feel that what is most valid about FT’s “Without fear and without favour” are the quotation signs. In your “Pumped up”, May 28, you refer to a study that finds that “UK duty was 20% higher in real terms in 2000” and you therefore happily conclude that “it is not the cause or rising fuel prices” Why did you not compare it to a year when petrol duties really started to increased, like for instance 1980?

You talk about that driving is getting costly, but you do not dare to specify the components of that cost, could that be because the taxman still gets more than the oil man?

Hey, you missed the story!

Sir, "Moody's error gave top ratings to debt products" May 21, is presented as a "human bites a dog" story even though it really is a "dog bytes a human" event. We all know that Moody and all the others are bound to commit errors, it is only human and must be forgivable, just as then try to cover up those errors is also human though not as forgivable.

The real story is how these agencies could have been regarded as infallible by the regulators who empowered them, and thereby forcefully or suggestively induced the market to blindly follow their ratings.

The article states "Credit ratings are hugely important within the financial system because many investors – such as pension funds, insurance companies and banks – use them as a yardstick to restrict the kinds of products they buy, or to decide how much capital they need to hold against them" and this gives the impression that the use or not of the credit ratings is a voluntary issue, which is clearly wrong. The investors mentioned, use the credit ratings because they have been strictly ordered to do so by their respective regulators.

Now if they managed to get you to spin a story about a once in a lifetime crazy mistake event that is never ever to happen again, then let me assure you that someone is shamelessly using you.

Yes, it is awfully hard to have the cake and eat it too!

Let's face it, globalization is awfully hard to discuss when "like most of us do we try to have our cake and eat it too and Martin Wolf's "How to preserve the open economy at a time of stress", May 21, is but another example of it. I agree with it all, full-heartedly, yet I have not the faintest idea of what I really have agreed with. It might be that we need to simplify the whole globalization equation in more manageable pieces.

Martin Wolf mentions for instance "redistributing the spoils of globalization, not sacrificing them" and which sounds a quite sensible thing to do. But that would have to start by identifying the spoils and perhaps wake up to the fact that the spoils are not to be found in a faraway country but in your own neighbourhood, in your own friendly neighbours courtyard.

Trying to speculate about where the non-obvious spoils are to be found, as those arising from higher prices of commodities are easier to identify, I frequently end up making two questions that might indicate possible new direction, exactly the purpose of questioning.

The first is. Is it logical that profits made by competing nakedly cost to cost in an efficient market should be taxed at the same rates that profits derived from an activity to which society has provided special shelter, like intellectual property rights?

The second, much more mundane, is why should a sportsman that earns a fabulous amount because he plays in a franchise with global reach pay income taxes based on where he slugs or kicks it out? Should he not pay it to his homeland or proportionately to where his audiences are?

Many of the consumers have had oil at $130 for decades!

Sir may I congratulate on placing the current price of oil in its true perspective saying "When oil was $10 a barrel, the idea that the stuff was running out seemed demented", "Solving the $130 oil conundrum, May 21.

It is exactly in that "dementia" during the last oil bust-boom (where you place yourself depends on whether you are an extractor or a consumer) that we find the origin of the current boom-bust, and so let us hope that a similar dementia is not present this time. This requires being sincere with the facts.

Among the little acknowledged oil facts is that for instance that the European consumer and many others have already for decades been living with oil in the $130, only that instead of the extractor getting that value it was the taxman. While oil prices were nudging down to the $10 you mention, taxmen were stealthily increasing their take...will they now reduce it?

Oil was at almost 10$... and heading south!

Sir, why are you distorting the truth? In a "Time to convene a summit on oil" May 16 you refer to the inexorable rise in the oil price from below 20$ to 126$ in less than a decade. If that had happened we would probably not seeing the current conditions but the fact is that late 1998 the price of oil got close to 10$ creating havoc for producers and investors alike (and for Venezuela bringing us chávez) and you know that as late as April 1999 even The Economist published an article arguing it was going for 5$ and FT must have echoed the same beliefs.

If an oil summit between the consumers and the oil extractors is to succeed then it has to build on the truth. And the truth should be spelled out without fear and without favour. Don't you think so?

Could we please have our active commercial bankers back?

Sir Evan Salway is right when he urges to "Rethink the 'active versus passive' investment debate" May 15, but much more important is the issue of whether we want active versus passive bankers. I sure do!

Since it is the commercial banker's true societal role to be actively out there in the real world developing his skills in listening and analyzing the many different lending opportunities I feel saddened by seeing the bankers turning into passive credit-rating-agency-criteria followers and automated executioners of trading opportunities identified by computers running models that none of them fully understand.

Banking regulator in Basle...could we please have our active commercial bankers back?

Should central bankers be allowed to own assets?

Sir in reference to your leader "The great asset price controversy" May 15 one could wonder if the first step should not be that of prohibiting central bankers from owning assets as one must wonder how many, if not all of them, were plainly delighted seeing the value of their houses go up and up... like a beautiful balloon full of hot air.

Americans, how sure are you it is not Mr. Jones that you should blame?

The fundamental driver of the unease with globalization is the reduction of the share of decent salaries paid in the gross global production (GGP) and since “decent salaries”, whatever that means, has almost exclusively to do with the developed world, there is a growing grumbling in the western world that this globalization thing might not have been such a bright idea after all.

Clearly, if an American holds that the world has to stop growing, immediately, so that he can go back to his 2 dollar per gallon of gas, he has a point, though he would also have to explain what to do with a paralyzed world.

Devesh Kapur, Pratap Mehta and Arvind Subramanian, “Is Larry Summers the canary in the mine?, May 14, worry that American liberal intellectuals might now team up with Lou Dobbs and produce a pure local US knee jerk reaction, which would be both dangerous and unproductive for the whole world, instead of teaming up with them in finding some valid solutions for all. They are very right about that.

Americans should know that when you build an isolation wall the worst part is how difficult it is to be 100% sure that you got stuck on the right side of it and so, before shutting themselves out, they would de well trying to get at the root of who are really capturing a larger share of the GGP, since besides from those obviously benefiting from the commodity boom, one of the culprit might even be their next door neighbour, Mr. Jones.

But we did what the market told us to do not long ago!

Sir Martin Wolf tells us that “The market sets high oil prices to tell us what to do” May 14, but we should not forget that the same market, less than a decade ago, priced the barrel of oil under 10$, and according to some pundits it was heading for 5$, and that in fact many of our current problems are derived from doing exactly what those low prices told us to do.

Martin Wolf also quotes the International Energy Agency in order to establish a case for extremely tight oil markets but what was this agency saying just a few years ago? Why are they to be more credible now?

What Martin Wolf does not mention are the alternatives to the short term markets in oil and that some long term take up contracts between producing and consuming countries, based on some reasonable in between prices, could create stability and reduce volatility in the oil markets for the benefit of all...less the short term speculators of course.

There is indeed a case for a league of “real” democracies

Sir Robert Kagan writes about “The case for a league of democracies” May 14, and of course there is such a case, as long as we are talking about real democracies. Many citizens around the world pray for the existence of a club where only governments that show their own people their utmost respect could be members, and where not belonging to it, helps to send an unequivocal shaming message.

Now for this to be a true example-setting club, it should not be possible to become a member by sheer political wheeling and dealing, but only by meeting a set of very strict criteria that go much further than just having a popular vote.

For instance Venezuela though presumably having a popular elected government, should not be able to be a member of such club since though it is a very polarized country it yet has a Congress that includes 167 members who are in favour of him who wishes to be called ‘Commander’, and none, zero, zilch, of those many who are not the least in agreement with that. Additionally Venezuela, as an oil cursed country that by centralizing the revenues from the oil in the State has a government that is wealthy and powerful independently of its citizens, should obviously not be admitted to a club of real democratic leaders.

And then on top of it all there is the regulatory tax on risk.

Sir I could not be in more agreement with what Eric De Keuleneer has to say in his letter “Step up competition for banks and rating agencies”, May 12 in relation to taking away the powers the credit rating agencies have been given to distort the markets, as you must know having received at least 100 of my letters on the subject over the last years. That said Mr. De Keuleener does not mention the current tax that the minimum capital requirements for banks impose on risk.

Under the current Basel I Standardized Approach, a low risk corporate loan (rated AAA to AA-) requires a bank to hold only 20% of the basic 8% capital requirement, meaning 1.6 in units of capital, while a much riskier loan (rated below BB-) requires it to hold 150% of the basic 8%, meaning 12 units of capital. If the current cost of capital for the bank is 15%, then the bank's carrying cost for the low risk credit is 0.24% (8%*20%*15%) while the bank's carrying cost for the high risk credit is 1.80% (8%.150%*15%), thereby producing an additional cost of 1.56% that must be added on to the normal spread that the market already requires from the higher risk credit when compared to the lower risk one.

This mind-boggling 1.56 basis points regulatory tax on riskier but frequently more needed credits when compared to low risk but often not so productive loans, dwarves any Tobin tax proposals both in terms of costs and distorting signals, but it is blithely ignored.

What is the purpose of the financial institutions?

Sir Evelyn de Rothschild writes passionately that “Ethical standards must be restored in finance”, May 9 and we all agree. That should begin though by clarifying what is the purpose of the financial sector since without that ethical standards would indeed be hard to define.

In fact given that the current purpose of the financial institutions seems to be extracting as much profits and bonuses as possible from them, some could even argue that there has been quite a lot of ethical behaving lately.

What is the purpose of our banks?

Samuel Brittan in “The financial crises of capitalism” May 9 says that “The beginning of wisdom is to recognize that boom and busts have been a feature of capitalism from the start”. Let us hope our bank regulators read it since instead of regulating so as to maximize the benefit from the boom and minimize the cost of the bust, ever since the Basel Accord in 1988 they have been set exclusively on avoiding the bust and which is clearly unwise.

How long has it been since any bank regulator has asked himself the question of what is the purpose of the banks? It cannot be simply that of avoiding a bank crisis as that is just stupid.

But in all this slicing and dicing there is no cube with the fathers and mothers of the US

Sir Jurek Martin in “Do not let Limbaugh pick the president” May 8, says “We are slicing and dicing the great American Community as it has never been sliced and diced before. Every component part is in play – black, white, men, women, Hispanic, Asian, rich, poor, old, young, Protestant, Catholic, evangelical, Jew and non-believer”.

To this we would then also add the slicing and dicing that the US Census Bureau does when reporting on the characteristics of citizens who voted or not in the elections and which, to Jurek Martin’s components adds: Nativity Status (whether born in the US or naturalized), Marital Status, Educational Attainment, Employment Status, Tenure (whether they own or rent the house), Duration of Residence at the place where they now live, Veteran Status and the Region where they originally come from.But surprisingly, at least to me, no one seems to be interested in the cube represented by fathers and mothers! Since the backbone of a nation is its people and the backbone of its people is God and families one has to wonder whether someone is taking the US backbone for granted.

Please visit!

The bankruptcy of the finance sector regulations

Sir Martin Wolf lists a quite comprehensive “Seven habits that finance regulators must acquire” May 7, though I missed two things.

The first is a definition of what we should have the right to expect from the regulated financial sector since hopefully it must be something more than just for it to avoid defaults. And how can you regulate without an objective?

Second, when Wolf mentions that “Capital requirements must be the same across the entire financial system, against any given class of risk”, this is way too important to leave at that, since it signifies that the fundament basis for all current Basel regulations, namely minimum capital requirements allocated on the basis of risk of default alone, has proven to be a bankrupt concept; with in this case “bankruptcy” being an unusually appropriate term.

By tinkering with risk and forcing upon the markets the “opinions” of the credit rating agencies overall societal risk has only increased and this has to change. Basel, do not go forward to Basel II or III, go back to the drawing board altogether!

Don't forget to sack some regulators too!

Sir William Cohan writes "Regulators must seize the chance to reform Wall Street", May 2, and though I agree with most of what he says I can't help thinking that we must also seize our chance to reform the regulators before they take us to That-Place-That-Must-Not-Be-Named.

Our bank regulators have now for two decades forced upon us a system which sole objective has been to avoid financial turmoil, as if that is all that banking is about, and they have not even delivered on that!

Come on, that the bank regulators should get sacked when they do not perform must be the first pillar of any reform. This is turning out to be the mother of all the non-accountabilities.

We also need to review "normality"

Sir it is understandable to wish for a return to normality as could be read from your "No quick end to the credit squeeze" May 2, but one of the very few good parts with any crisis is the opportunity it brings to reappraise whether we agree with "normality". This is a moment to step back and have a long deep thought of what we really want to get out from our financial sector and from our banking regulations, since just keeping us out of turmoil is clearly neither enough nor deliverable.

Just because they are private doesn’t make the credit rating agents less bureaucrats

Sir John Authers in “The Short View” of May 2 asks the relevant long term question “should the S&P’s ratings be this important”, and answers with a no “As we have learnt from the credit crisis, it is dangerous for so many to put so much weight on one rating agency’s judgment”. He is right. The fact is though that as long as the regulators keep empowering these agencies to decide so much on how much capital the banks have to set aside for each credit based on the ratings, too many will indeed put too much weight on one rating agency’s rating, and there is no way around it.

I just ask what if those credit rating agents had worked for the regulators. All hell would have broken loose. Our confusion arises from not being able to see through the veil that the outsourcing to the private sector signifies, so as to comprehend that the credit rating agents are just simple credit-risk-measuring-bureaucrat-commissars.

Risk is always relative!

Sir, John Gapper titles a bit prematurely "The return of high-risk optimism" May 1, when in fact we are yet only going through "the coming home of low-risk pessimism" phase; and in fact he mostly discusses the losses on "safe securities".

What is finally true is that risk itself is a very relative concept and I have argued for years that while all those low risk instruments could be truly low risk instruments from a financial investment perspective, they could just the same be the most risky investment from a long term societal development point of view. For instance the "safe" financing of cars placed in the perspective of the climate change threats.

The restructured mortgages need to earn the prime status they should not before have been awarded.

Sir the chairman of the US Federal Deposit Insurance Corporation Sheila Bair opined on "How the state can stabilize the housing market", April 30.

She describes the pros of some current options but misses out on what is the most important rule of any restructuring namely that if you are going to pay for the costs of restructuring, this is normally only worthwhile to do, if you get it right once and for all; and that what is left in the pot is deemed as being of much better risk quality than what went in. In other words the resulting mortgages should have to earn the real prime status they should never before have been awarded.

In this respect when Bair states as a clear advantage that "it keeps the risk of re-default on mortgage investors", though it sounds about right, it should be irrelevant if the restructuring has been done correctly and the risk of re-default are negligible.

Force oil companies to adopt EITI principles in order to list and trade

Sir as a cursed citizen from an oil cursed nation (I guess you have never really seen a cursed government from an oil cursed nation) I do applaud your editorial "Fighting graft" since you there clearly state that if persuasion and coercion do not exist, nothing will happen any century soon. 

I for one am begging the developed countries to have their financial and commodities exchanges to ask for evidence of compliance with a set of minimum practices along the lines of the Extractive Industries Transparency Initiative, before any oil company is allowed to list or trade on them. 

That of course would do infinitely more than having to spend our next hundred years trying to convince individual companies and countries of the merits of such initiative.

That of course does not mean that I am in agreement with EITI’s obnoxious 2nd principle that states “We affirm that management of natural resource wealth for the benefit of a country’s citizens is in the domain of sovereign governments to be exercised in the interests of their national development.”

As a citizen I know that the worst part of any oil curse is the excessive concentration in the governments of our oil revenues.

America, and the world, needs equally to make a new case for its financial system.

Sir Lawrence Summers observes in “America needs to make a new case for trade”, April 28, that “while the financial crisis dominates current discussions on the US economy questions regarding America’s future approach to globalization are looming increasingly large” and as if those were in fact two separate issues. They are not! Summers asks for us to better define what the purpose of trade for the sustainable well-being of a country is and the same needs to be done with respect to the financial system.

The biggest failure with the financial sector is not its current turmoil but the fact that having left it completely into the hands of regulators who on their minds had only the limited goal of avoiding defaults and bank crisis, we now face a totally purposeless banking system. Even if we would get out of the current turbulence, it would still be totally rudderless system. I say this assuming that no one could really be satisfied having a financial system that makes bets in a virtual world, guided by traffic signs set up by the credit rating agencies, all just in order to survive. Ask your regulators… survive in order to do what?

In fact had you not had such a wasteful financial system pursuing so much the lending to the public sector, the housing finance or the anticipation of consumption just because this lending could be disguised as less risky lending, you might not even have the current trade imbalances.

Our first turning point has to be in the how we manage the world’s economy.

When I was an Executive Director at the World Bank 2002-2004 I am on the record complaining that there were no significant mention of energy plans in the country assistance strategies presented to us, when in light of the tremendous energy intensive growth occurring in places like China and India, we could very well be facing 100 dollar per barrel of oil in a short time. And I do not yet understand how the International Energy Agency was not capable of mustering sufficient strength to warn the world of the upcoming imbalances with the supply and demand of oil.

For more than a decade I have been also been voicing, sometimes quite noisily, that in fact we do not have a workable regulatory framework for our financial systems, since it should be clear to anyone that our real objectives for it must reach much further than the current limited and almost silly objective that Basel has in mind, that of just avoiding defaults.

Also, from the very first moment I heard about officially empowering the credit rating agencies to do the risk measurements that determined the capital requirements of banks, I have repeatedly stated that this would just lead some participants to let down their guard and end with many investors following, sooner or later, the credit rating agencies over a precipice.

I mention these three aspects, though there are many more, like the “scandalously wasteful biofuels programmes”, in response to Martin Wolf’s “A turning point in managing the world’s economy”, April 23, in order to emphasize that the first turning point we really need to make has to do with the how we manage the world’s economy. Obviously we must break lose from the habit of blindfolding and ossifying our institutions. Perhaps we need to impose term limits on the bureaucrats too, especially since their first rule for survival seems to be…do not ask questions and do not answer what you have not been questioned.

Frightening!

Sir what many of us feared, the Union of those who can not go bankrupt with those who are to big to fail is getting closer. Henry Kaufman’s proposal contained in “Finance’s upper tier needs closer scrutiny” April 21, on a supervisory authority that takes over the role of the credit rating agencies and that starts almost micromanaging the big financial entities makes our hair stand up.

Where are we citizens going to be left in this cosy arrangement among those who could share so many mutually beneficially interests? Why do we not just place a little tax on the size of banks based on the bigger you are the harder you could fall on us concept?

Clarity is needed for credibility

Sir you rightly say that the “Climate Policy must be credible” April 19 and one of the basic requisites for that is clarity in the use of terms.

When on a simple water bottle you might find information such as calories=0 (thank god the implications of something different would indeed be frightening) there is no way to find a clear-cut definition on what is meant by for instance “clean energy”. The closest we get is to some mumblings about energy that causes little or no harm to the environment and which will not get you that far down the lane of credibility either.

But why did the regulators, knowingly, tempt the bankers?

Sir Gillian Tett shows great expertise describing the physical evidences gathered in the ongoing “forensic research” like the regulatory arbitrage that resulted from that the super-senior debt that carried the triple A tag and that only required banks "to post a wafer thin sliver of capital against these assets”, “Super-senior losses just a misplaced bet on carry trade” April 18.

Where Tett falls short though is in the reconstructing of the scene of the crime, since nowhere does she ask herself why the regulators exposed the bankers to these types of temptations, especially when they must have known they would fall for them.

My personal answer is that the regulators were so obsessed with fighting their own demons, “the default risks”, so that they did not care for anything else; and neither did they want or listen to other opinions, since they wanted to show themselves to be independent.

If there is one single lesson that stands out from the current turmoil it is that the regulation of the financial sector cannot be left solely in the hands of the regulators, since single-mindedness is not a good enough reason to award anyone independence.

Sometimes formal limits signify fewer limits

Sir Krishna Guha in “Call for investment bank rules to change” April 18 mentions that Bear Sterns had a debt to equity ratio of about 30 times and that "experts argue that the investment banks should be subject to the same capital requirements as commercial banks - requirements that in effect limit their leverage. Not necessarily so!

If investments banks invested in those super senior debt that carried the triple A-tag and that are described by Gillian Tett in “Super-senior losses just a misplaced bet on carry trade” then according to the minimum capital requirements that apply to the commercial banks these could in fact have an even higher leverage…in some circumstances even more than 60 times.

Let us not forget the rental options

Sir though I might have picked a somewhat more gentle title I agree full heartedly with Martin Wolf’s “Let Britain’s housing bubble burst” April 18. Having said that perhaps it would also have been appropriate to include a remark about the bias that has been spread throughout the whole world and that favours the ownership of houses as compared to the alternatives provided by the rental markets.

In a global mobile work market where a house when owned often signifies a ball chain around the ankle it would seem that renting should be a very good option, if it is able to overcome the stupid hurdle of having almost been socially derided as a second class choice.

FT you’re obsessed!

Here is the world confronting truly frightening scenarios and one is trying to argue that one way forward is not to blindly pursue the avoidance of the risk of defaults, just for the sake of it, but to be able to better embrace the risks of default by placing them in the perspective of what could be achieved in terms of sustainable growth… and you keep on busy with your quite silly and almost sissy chit-chat on the testosterone levels among male traders, Calibrating cojones, April 16.

Let me just remind you so that you can get over this discussion and return to your senses, that for each trade induced by an overdose of testosterone, there should be a counterparty suffering from an under-dose of testosterone.

Sissy banks and sissy markets?

Martin Wolf in “Why financial regulation is both difficult and essential” April 16, says “It is impossible and probably even undesirable to create a crisis free system”.

Wolf falls way short since in fact even trying to create a crisis free financial system poses extreme dangers, being that risk is the oxygen of development.

No matter what, the world does not belong to the risk adverse and the real risk is not banks defaulting, the real risk is banks not helping the society to grow and develop. Not having a hangover (a bank-crisis) might just be the result of not have gone to the party!

What we then must do before rolling up our sleeves to do regulations, is to have a fresh look at what has been ignored for so long namely what are the financial institutions and specially the banks to do for us?

In that sense we need to stop focusing solely on the hangovers and begin measuring the results of the whole cycle, party and hangover, boom and bust! For instance the South Korean growth boom that went into a bank crisis in 1997-1998 seems to have been much more productive cycle for South Korea than what the current boom-bust seems to have been for the United States.

If we insist on using as the main ingredient for the regulation the risk of default, is it not time to start thinking of capital requirements for banks based on units of default risk per decent job created or climate change avoided? That would at least seem much more productive that units of badly gauged default risk per subprime mortgage financed. Honestly who could believe that the world would have come this far without a bank crisis now and again?

And, to top it up, FT ran two pieces yesterday suggesting banning testosterones from our trading floors! Sissy banks and sissy markets?

This is indeed an embarrassing low for FT!

Sir not only did you publish John Coates’ “Traders would do well to track their hormones” April 15, in which, based on the study of the saliva of 17 male traders over eight days, the author suggests we complement the efforts of our bank regulators to drive risk out from banking, with driving out any risk taking stimulators such as testosterones from our trading floors, but you also have Clive Cookson reporting fully on the same nonsense including a photo of testosterone in action.

Unless this is a complete mess up of an April fool joke I sincerely think you owe your readers an apology. Are we to extend this type of risk adverseness litmus tests to the professionals working for the credit rating agencies too? Why do we not start with FT editors? Seeing that you completely lost control!

Why we can not leave bank regulators to regulate on their own!

Sir Nout Wellink’s declaration that “Basel II is sophisticated and sorely needed” April 10, is a splendid example of why we cannot leave the traditional bank regulators regulating banks on their own. The just are digging ourselves deeper in the hole we are in!

Of course there is nothing wrong with sophistication as long as it does not take away from our understanding of what is going on, which it will be the end result, which makes further mockery of market transparency; and as long as it does not create new artificial market advantages, which it will by favouring the big banks and the continuation of our craze of putting ever more eggs into fewer basket; and as long as it does not create new systemic risks, which it will as long as “to err is human” applies, just like it applied in the case of the credit rating agencies.

But, what I most object to is that “there will be greater differentiation in the capital requirements for high risk and low risk exposure”. Who on earth told the bank regulators that the only role of banks was to avoid failing and that for that purpose you had to create an additional regulatory bias against risks, more than the natural bias against risk that already exists in the market? No, we do not need the banks to increasingly finance only securitized consumers and public sectors around the world just because that could be construed as having a lower risk of default. To do so could lead the world to default. If we are going to use default risk as a basis, then we better design the minimum capital requirements in terms of units of risk per decent job created.

Any reform should obviously have to start with the most direct causes of the crisis

Sir it is not the first time and it will most probably not be the last one I have to raise the issue but John Plender in “Radical reform will be flawed by compromise and fudging” April 9 does not even mention the credit rating agencies.

Fact one: The single most important detonator of the current difficulties in the financial sector was the securities that had been collateralized with truly lousy mortgages awarded to the subprime sector in the US.

Fact two: The single most important factor that allowed truly lousy mortgages to morph into prime paper was the high prime ratings awarded the collateralized securities by the credit rating agencies.

Fact three: If we survive this there is nothing to stop us following again as lemmings the credit rating agencies over an ever worse precipice.

And so if there is a need for a reform that would be taking away the power of the credit rating agencies to impose their will on the markets.

But then of course Plender could be arguing that this would have to be included in a sort of minimum reform, not at all radical; and in that he would have a point.

It is still the simplest things that are most likely to really bring you down.

Sir John Kay correctly says that “In times of complexity common sense must prevail” April 9 and among the danger present in going down the road of further sophistication he quotes “Goodhart’s law: as soon as reliance is placed on relationship, the significance of relationship changes”. As I see it old Murphy’s Law might be just as relevant because entering into a formal relationship with the credit rating agencies empowering them to advise the markets so much on where the risks were, was just a disaster in waiting.

In this times of complexity let us not forget that the prime detonator of our current crisis were just some simple mortgages to the subprime sector and that were so lousily awarded that anyone should have been able to see them for what they were, had they only used their own eyes and not some old data sets or fancy models.

But Greenspan does share the blame

Sir Martin Wolf in “Why Greenspan does not bear most of the blame” April 9, correctly says that blame distracts from understanding what happened why it happened and what we should do, but it looks that so does also defending someone from blame.

Alan Greenspan in “A response to my critics”, FT’s economist forum, April 6, says that “The core of the subprime problem lies with the misjudgements of the investment community”; and the core of that misjudgement lies of course with the credit rating agencies; as most of the other financial agents were just doing their normal business which is selling something risky valued at somewhat less risky terms.

In this case what Wolf fails to recognize, sufficiently at least, is that the immediate detonator of the current crisis was not a housing bubble but a bubble in financial securities, such as those collateralized by lousily awarded mortgages to the subprime sector.

The credit rating agencies did not do the job they were supposed to do, to err is human; but the responsible for empowering the credit rating agencies to do the risk measurement for the markets and ignoring the “to err is human” part of it all, were the bank regulators, like Greenspan. And for this Greenspan should at least stand up and take his share of the blame.

It is stunning how Greenspan can keep a straight face

Sir Alan Greenspan declares that “The Fed is blameless on the property bubble” April 7 and puts the blame instead with the investment community, like bank loan officers; and says “Regulators confronting real-time uncertainties have rarely, if ever, been able to achieve the level of future clarity required to act pre-emptively”. He also ends up by saying that “free competitive markets are the unrivalled way to organise economies.

I am stunned. How can he keep a straight face saying such things when he, as a regulator, did in fact outsource the real-time risk vigilance to the credit rating agencies and thereby helped to lead the market into the temptation of believing that the risk measurement by some few qualified eyes sufficed?

Please FT will you try to help me find out who on earth came up with the idea that the only risks that mattered for the financial sector were the risks of default and thereafter empowered the credit rating agencies to do the measuring?

Stop dodging the issue about the credit rating agencies

Sir the real line of division does not go that much between those who want more or less financial regulation per se but between those who argue that you can give so much power to the credit rating agencies to influence the financial flows and those who like me have always held this to be absolute madness; that sooner of later the market could follow these pipers over a precipice… as indeed it did in the case of the securities collateralized with subprime mortgages. Clive Crook in “Regulation needs more than tuning” April 7, is at least clearly admitting that sooner or later he needs to make his mind up on this thorny issue and for this he should be commended, since most have just been dodging it.

By the way just to help sort out a deep misunderstanding; the fact that the credit rating are private do not make them less official.

Regulatory outsourcing creates confusion

Sir George Soros in “The false belief at the heart of the financial turmoil”, April 3 though he sees some trees that the regulator’s do not, he completely misses the forest just the same.

Soros accuses the regulators of beeing misguided by a market fundamentalism arguing that they believe markets are self-correcting without being able to grasp that the markets are indeed self correcting, though in a quite violent way grant you, to what should be considered the mother of all regulatory fundamentalisms, the excessive empowerment of the credit rating agencies.

If the credit rating agents had been working for a government institution all hell would have broken out, long ago, but since they work for private companies, they get confused with being a part of the market. Indeed regulatory outsourcing creates confusion.

Do not throw imprudence out with the bath water…throw out the power of the credit rating agencies!

Sir “Now the prudent will have to bear the cost of profligacy” says Martin Wolf, April 2, and before anyone misinterprets what I am sure Mr Wolf does not mean, let me remind fellow readers that from a different perspective imprudence can also be seen as one of the basic and most valuable driving forces there is in our societies.

Now if we are going to talk about imprudence, big scale, then let us discuss the appointment by the regulators of the credit rating agencies as risk measuring bureaucrats, as if anyone in a society can really know from what hole risks could jump at you.

That bank defaults are risky and bank crisis bad? Yes, but even more so banks not defaulting and thereby setting us up for the mother of all crisis; and so therefore, please, disconnect the markets from having to give special credence to the credit rating agencies, ASAP.

Whose side are you really on FT?

Sir in “Paulson’s gamble”, April 1, you refer to “investor stupidity” without mentioning that the only fault or sin that probably most of these investors committed was to deposit too much trust in the credit risk surveyors appointed by the regulators. Is not the original stupidity the regulators? And the investor’s and yours only let yourselves be fooled by them?

Mr. Clive Crook. Now you please repeat after me too

Sir Clive Crook is absolutely right when titling “Markets need more than a patch-up” March 31, and ending it with “We need an entirely new model” as in between he really wavers around among a world of possibilities.

Now given that Crook gives so much weight to the issue of moral hazard that he orders us to “Repeat after me: you encourage recklessness if you protect people from its consequences” and which I duly did, I would love Crook to return the favour and also repeat after me that “you encourage carelessness if you make it to be seen that risks could indeed be measured and nominate credit rating agencies as duly qualified to do just that.”

Regulators really have tremendous workload cut out for them especially when they have not yet really decided the objective of their regulation correctly, since avoiding defaults and crisis cannot be the only societal role of a financial system.

Eerily peculiar recommendations

Sir Lawrence Summers writes about “Steps that can safeguard America’s economy” March 31, and suggests “that a top priority for financial policy has to be increases in the level of capital held by financial institutions” and “have Congress insist that [the government sponsored enterprises] stop paying dividends and raise capital substantially as they expand their lending”.

Given that we heard so many times during the last years about how well the financial institutions were capitalized; and that the lack of capital had nothing to do with how this crisis came about, since even the over leveraging of financial institutions had more to do with the lack of common sense, these recommendations sound eerily peculiar indeed.

Why not suggest they stop digging in the hole they’re in first?

Give the banks time instead of bailouts!

Sir in your editorial of March 29 “Not yet time for a bail-out of time” you mention that “Governments can also help by facilitating renegotiation of mortgages. The principal aim is to avoid unnecessary and costly foreclosures.” That is nonsense! The principal and perhaps only aim of any renegotiation is to make the credit viable, ideally taking it out from the shadows of the subprime world and bringing it in to the prime world, where all debtor and creditors can enjoy lower interest rate return requirements.

Now also and though I fully agree that it is not time for a bail-out of banks, it is definitely time to give them some more time to react. This whole affair of putting the banks against the walls just because of the change of mind of credit rating agencies is too harmful. At least give them a year to find and make the new capital increases by allowing them to use a 12 months moving average to account for market changes in the value of their investments. And this way tax-payer does not have to step up to the plate as fast either, or even at all.

Too much ‘Group think’ C’est la vie!

Sir Gillian Tett in “Banking oversight and the danger of ‘group think’” March 28 mentions the “difficulty the staff of the Financial Services Authority’s (FSA) face in terms of challenging the dominant financial creed” mostly because they lack the glamour needed to be allowed to question the glamorous.

Something similar happens when a modest MBA like me, with only 30 years street experience, in only a developing country, tries to get through to journalists to alert them of what has and is really happening out there, only to be ignored because it is so much more glamorous when appearing surrounded by PhDs. I guess c’est la vie! Regulatory authorities will not get to see the full truth, and neither will the journalists, not even some columnists.

Now if Gillian Tett sees danger in the above when occurring in FSA she should have a look at what happens in that mutual admiration club composed by The Basel Committee on Banking Supervision, the International Monetary Fund and all their members the Central Bankers…talk about the mother of all ‘group think’ they even have their own checks and balances, like The Financial Stability Forum. The World Bank and that should presumably do some of the questioning, was just told to shut up and harmonize.

A subprime dollar? Not the end of the world; but a change of collateral may be asked for

Sir Martin Feldstein’s “The dollar may be falling at just the right time” March 28, is a timely reminder that it is not necessarily that bad for the dollar doing upon other currencies what other currencies have done to the dollar; and that there is no need to look at it all as the end of the world… even though it might be the end of that money that was backed only by the trust in the government and that has had a run for almost 40 years now, some say amazingly.

To insulate us from realities? Thanks but no thanks!

Sir John Kay writes “Why more regulation will not save us from the next crisis” March 26, and though he is absolutely right I do not make the same inferences that he does. Just for a starter, I believe that if we do not have a next crisis, that could just the same be the symptom of that we are not doing enough… getting out of bed has its risks, but staying in bed leads you nowhere.

Also, when Kay argues that we should “insulate the real economy from the consequences of financial stability” and meaning with it that the governments should “protect small depositors” (how are they identified?) and mentions “to restrict the use of retail deposits as collaterals for speculative activities” he is in fact proposing something like forcing us to invest exclusively in government papers… and as if that carried no risk to us.

We do know about many different efforts going on in trying to create absolutely risk free environments for retail deposits and that is not only arrogant and preposterously silly but also quite dangerous… much like the belief that the credit rating agencies could be imposed as official risk surveyors without themselves tuning into a huge systemic risk.

Wake up Mr. Wolf!

Sir Martin Wolf holds that “The rescue of Bear Stearns marks liberalisation’s limit” March 26; as if we have had some true liberalisation. 

He is wrong. Much the contrary, never before have the financial markets been so regulated as they are now with the credit rating agencies, empowered by the regulators, deciding over how much each bank needs to pack their rucksack with reserves; and most of what has happened since imposing the minimum capital requirements imposed on the banks through Basel I, has been the result of regulatory arbitrage. 

Wolf quotes Ben Bernanke in a speech that “makes one’s hair stand on end” saying that much of the subprime mortgage lending of recent years was “neither responsible nor prudent”. 

Mr Wolf. You know what makes my hair stand on end? That all the market did was to follow the criteria of the credit rating agencies that felt that such mortgages were good enough to make up prime collateral. Wake up Mr. Wolf, before we can start to think about the limits of liberalisation we still have much to think about the limits of regulations.

PS. Credit ratings as a systemic risk