Wednesday, May 20, 2015

When are we going to get regulators concerned with banks allocating credit efficiently to the real economy?

I just wonder… because clearly current bank regulators do not care one iota about that.

If they did they would not have concocted their silly credit-risk-weighted equity requirements for banks which allow banks to earn much higher risk adjusted returns on equity lending to “the safe” that when lending to “the risky.”

And that of course means banks will lend much too much to "the safe" and much too little to "the risky"

Tuesday, May 19, 2015

Compared to The Really Great Distortion by the Basel Committee, The Economist’s Debt/Tax Distortion seems smaller.

The Economist makes some good points about the distortion produced by the tax deductibility of borrowing costs, “The great distortion” May 16.

Indeed but compared with the distortions produced in the allocation of bank credit by the credit-risk-weighted requirements for banks, those distortions seem minor. The distortion The Economist refers to, favors debt over equity, and produces a suboptimal debt/equity mix. The distortion current bank regulations cause affects the access to debt. Those perceived as safe, and who therefore already have better access to bank credit, will have even more so. And those perceived as risky, and who therefore already have difficulties accessing bank credit will have even less so. And that, which kills opportunities, is a real potent inequality driver.

The Economist writes: “Corporate financial decisions are motivated by maximizing the relief on debt instead of the needs of the underlying business.” But in the same vein, minimizing equity is now more important for banks maximizing the risk-adjusted returns on equity, than looking out for worthy borrowers.

In the briefing “Ending the debt addiction”, “the implicit government guarantee that props up big banks” is identified as a distortion. But that implicit guarantee is made much larger, and regressive, by the fact that it can be leveraged much more when lending to the safe than when lending to the risky.

I am glad to see The Economist could favor “to abolish corporate tax entirely- and instead have one layer of tax levied on the income individuals receive from investments in firms. That is indeed something that I have often proposed, like in “My tax paradise

Where I differ strongly with The Economist though, is when it refers to the lower tax revenues government receives because of the deductibility of interest on debts as “a cost in forfeited tax revenues”. Refer to it only as "lower tax revenues", instead of a “cost”, it can sometimes signify a benefit… for all. Besides how much tax is paid yearly because of the higher property values?

Monday, May 18, 2015

The World Bank spoke out way too softly on faulty bank regulations, and finance ministers did not read carefully enough.

World Banks' The Global Development Finance 2003 (GDF-2003), “Striving for Stability in Development Finance” had this to say on Basel II, pages 50-52

“The new method of assessing the minimum-capital requirement [proposed by the Basel Committee for Banking Supervision (BCBS)]… will be explicitly linked to indicators of credit quality… The regulatory capital requirements would be significantly higher in the case of non-investment-grade emerging-market borrowers than under Basel I. At the same time, borrowers with a higher credit rating would benefit from a lower cost of capital under Basel II….

A recent study by the OECD (Weder and Wedow 2002) estimates the cost in spreads for lower-rated emerging borrowers to be possibly 200 basis points.”

What did the World Bank say with that?

It said that regulatory capital requirements would distort more than the previous Basel I did, the allocation of bank credit.

What did finance ministers of developing countries do?

They did not protest that as an outrageous odious discrimination of bank lending to countries like theirs that are naturally perceived as more risky.

What did finance ministers of developed countries do?

They did not understand that their own “risky”, the SMEs and entrepreneurs, would be exposed to exactly that same odious discrimination.

I, at that time an Executive Director of the World Bank, mostly representing developing countries, when commenting GDF-2003 formally stated:

“the document does not analyze at all a very fundamental risk for the whole issue of Development Finance, being that the whole regulatory framework coming out of the BCBS might possibly put a lid on development finance, as a result of being more biased in favor of safety of deposits as compared to the need for growth. Even though, in theory, we could agree that there should be no conflict between safety and growth, in practice there might very well be, most specially when the approach taken is by substituting the market with a few fallible credit rating agencies.”

And a couple of weeks later, also formally at the Board of the World Bank I held: “BCBS dictates norms for the banking industry that might be of extreme importance for the world’s economic development. In BCBS’s drive to impose more supervision and reduce vulnerabilities, there is a clear need for an external observer of stature to assure that there is an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth. Once again, the World Bank seems to be the only suitable existing organization to assume such a role."

Now I hear some talking about that the World Bank is becoming irrelevant. Forget it! It could be more relevant than ever… but for that it has to be able to stand up for the risk-taking our children needs for us to take in order for their children to have a future.

PS. Come to think of it. The World Bank has been mum on this regulatory distortion of the allocation of bank credit to the real economy. Why? Does it not even listen to itself?

Saturday, May 16, 2015

Today I get to be 65, and so I give myself a list of some of my ramblings on bank regulations, in no special order.

The current pillar of bank regulations “more-perceived-risk-more-equity and less perceived risk less equity” is absolutely wrong, but might intuitively seem too correct so as to allow Daniel Kahneman’s System 2 even to begin its deliberation.

Today banks compete to obtain higher returns on equity more by reducing the equity needed that by identifying those who pay the highest risk adjusted margins.

Today the dollar in net risk adjusted margin paid by those perceived “safe” is worth more to the bank than that same dollar paid by “the risky”.

If you have regulators that do not understand that different equity requirements affects the risk-adjusted returns on equity of assets, which dangerously distorts the allocation of bank credit to the real economy…then you’ve got to change your bank regulators… urgently.

If you have regulators that do not understand that the perceived risk of bank assets does not matter since what is important is how the banks manage those perceptions of risk…then you’ve got to change your bank regulators… urgently.

If you have regulators that do not even look at the empirical evidence of what has caused all major bank crisis, never something perceived ex ante as risky, always something erroneously perceived ex ante as safe...then you’ve got to change your bank regulators… urgently.

If you have regulators who cannot manage the differences between ex ante perceived risks and ex post realities, and so can understand that what really poses dangers for the banking system at large are assets perceived as “safe”… then you’ve got to change your bank regulators… urgently.

If you have regulators who regulate banks without clearly defining their purpose… then you’ve got to change your bank regulators… urgently.

If you have regulators who believe they have the right to odiously discriminate against the fair access to bank credit of those perceived as "risky", SMEs, entrepreneurs and start-ups… then you’ve got to change your bank regulators… urgently.

If you have regulators who believe they have the right to specially favor the fair access to bank credit of those perceived as "safe" sovereigns and members of the AAArisktocracy… then you’ve got to change your bank regulators… urgently.

Had regulators thought abut the “what are banks for?”, they would have known that banks are to allocate credit efficiently to the real economy, and they would never have concocted those highly distortionary credit-risk weighted equity requirements for banks.

A different take on the previous, is that the first step of any good risk management, is to clearly identify the risks you cannot afford not to take.

Few things are as risky as an excessive risk aversion.

Why is so much discussed about excessive risk-taking… and so little about excessive risk aversion?

Risk taking is the oxygen of development and we owe it to our kids and grandchildren that banks take risks with reasoned audacity. Nothing as dangerous, as excessive risk avoidance. God make us daring!

Our grandchildren will damn current bank regulators for denying them the risk-taking needed for them to find decent jobs.

Banks do not finance the risky future anymore they just refinance the safer past.
  
Bank regulators recommended banks an investment strategy fitting old retirees with short life expectancies and completely ignored the need of our young ones.

The best macro-prudential regulations is one of micro-prudential regulations that help banks to fail… fast… not the current micro-prudential regulation, which only helps to create too big to fail banks.

Mini-bank-equity requirements are the best growth hormones for the too big to fail banks.

Perfect information makes everyone to stay in bed… why bother, there’s not going to be any real profits? Blissful ignorance and imperfect information is a great driver of the economy.

Don’t ever allow a failed regulator to get away with the “this was a Black Swan, a totally unexpected event, a completely unforeseen consequence” excuse.

If a regulator tells you that the risk-weight of a sovereign is 0% but the risk weight of the citizens of that sovereign is 100%, then the regulators is not a regulator, only a communist.

If the Home of the Brave were really the Land of the Free, would they have allowed the current risk aversion in bank regulations?

With an Equal Credit Opportunity Act (Regulation B) how come regulators are allowed to discriminate against somebody’s access to bank credit only because he is perceived as risky from a credit point of view?

How can a Governor allow that his state chartered banks can lend, for instance to Germany, against much less equity that when lending to a local entrepreneur? 

Hold your bank regulators accountable. If they fail like they did with Basel II, do not promote them, and much less allow them to design Basel III. Neither Hollywood nor Bollywood would never ever do a stupid thing like that, after a mega box-office-flop.

Do not allow regulators to regulate within the confinement of a mutual admiration club. That only guarantees degenerative groupthink.

Without regulators and regulations, how many banks, like those in Europe, would have been allowed to leverage their equity 30 to 50 times to 1? ¡Zero¡ 

When you regulate, remember that every rule carries in it the seeds of being a systemic risk that can explode as a truly dangerous systemic error.

If your Homeland Security cannot visualize that bad distortive bank regulations could be even more dangerous than a full fledge terrorist attack… then you’ve got to refresh your Homeland Security

If you have progressives who do not understand how higher bank equity requirements when lending to those perceived as risky kills opportunities and drives inequality, then you better get yourself some new progressives.

If you have some free-market defenders that do not see how regulators, with their credit risk weighted equity requirements for banks, impose capital controls on where bank credit should go, and accept to talk about a de-regulated market, then you better get yourself some new liberals.

Finance professor’s in university that do not care about such “vulgar” issues as bank regulations and how these can influence the economy should be send to a boot-camp for a refresher. There they could for instance learn that the risk-free rate they are using is currently a subsidized risk free rate.

Anyone talking about de-regulation when we are in fact facing one of the most intrusive and distortive regulations ever… has been brainwashed.

While current regulatory distortions exists the QEs are just a waste, since these only help to increase the value of the existing assets… sometimes by even reducing what there is… like with the buybacks of shares.

“The possible Big Bang that scares me the most is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause the collapse of our banks.”

The whole regulatory framework coming out of the Basel Committee for Banking Supervision might possibly put a lid on development finance, as a result of being more biased in favor of safety of deposits as compared to the need for growth.

“A mixture of thousand solutions, many of them inadequate, may lead to a flexible world that can bend with the storms. A world obsessed with Best Practices may calcify its structure and break with any small wind”


PS. I will be editing and adding on to this points whenever I remember any other of my ramblings.

PS. But at least I am over that 64 years hurdle https://youtu.be/K5ilYCnHYQ0

Wednesday, May 13, 2015

What are we to do with immoral and dumb dumb bank regulators?

Current bank regulators, with the Basel Accord of 1988, and further with their Basel II in 2004, decided to concoct and impose credit-risk weighted requirements for banks…more-risk-more-equity and less risk-less-equity.

That results in that bank can leverage more, and therefore obtain higher risk adjusted returns on their equity, and on the implicit and explicit support of taxpayers, when lending to “the safe” than when lending to “the risky”.

That constitutes a regulatory bias in favor of those who already are favored by bankers because they are perceived as safe, which results in an immoral and odious discrimination against “the risky”, those who are already naturally discriminated against by bankers.

And it is dumb because that distorts the allocation of bank credit to that real economy on which our pensions, our children and grandchildren’s future, and even our banks long-term safety depends upon.

And it is also dumb because never ever have major bank crisis resulted from excessive exposures to what was ex ante perceived as risky, these have all resulted from excessive exposures to what was ex ante perceived as safe but that ex post turned out to be very risky.

So what are we to do with these immoral and dumb dumb bank regulators? The Basel Committee and the Financial Stability Board, they don't even acknowledge that there is a problem.

PS. By the way, what are regulators really doing when they assign a zero risk weight to the government and a 100 percent risk weight to an unrated citizen? Does that not give out a very strong stench of communism?


Monday, May 11, 2015

Dumb bank regulators clearly evidence we need artificial intelligence, at least as a backup

Banks fail because: they cannot perceive the risks correctly, they cannot manage the correctly perceived risks correctly, or suddenly something truly bad an unexpected happens… like the economy falling to pieces.

So if banks should be required to hold equity, in order to build up a buffer before they need help from taxpayers, those equity requirements should be based on: the credit risks not being correctly perceived, the bankers not being able to manage perceived risks, and something truly not expected happening, like an asteroid hitting their borrowers.

But, the Basel Committee for Banking Supervision, based its equity requirements for banks on the ex ante credit risks being correctly perceived… and that is nothing but loony. 

Besides they regulate banks in thousand of pages, without defining what the purpose of banks is… and that is nothing but absolutely irresponsible.

Any artificial intelligence worthy of its name would have made two simple questions.

What is the purpose of banks?

What has caused major bank crisis?

And how different and better the world would then have been. We could surely have had other type of problems, but definitively not the current crisis, caused by excessive lending to what was ex ante perceived as safe; nor the current lousy economy, caused by the lack of lending to those perceived as “risky”, like the SMEs, precisely the tough we need to get going when the going gets tough.

Our grandchildren will damn current bank regulators, for not allowing banks to take the risks their future needs.

Sunday, May 10, 2015

If we are going to give bankers new real clothes, let’s make really sure they fit our children’s needs

I have frequently commented on statements or writings of Anat Admati. I have done so mostly because I find reasons to think she understands better than many the problems with current bank regulations, and so therefore I am especially frustrated when I see her being somewhat imprecise.

Here I refer to Admati’s comments at the Finance and Society INET Conference May 6, 2016 “Making Financial Regulations Work for Society

1. Admati writes: “What we are tricked into tolerating, even subsidizing, is the equivalent of allowing trucks full of dangerous chemicals to drive at 120 mph in residential neighborhoods (and having trouble actually measuring actual speed), which burns lots of fuel, harms the engine and risks explosions.”

That is indeed a good description of the risks of a blow-up of the banking system… but it needs clarifications in order not to create confusion… in order to correct the system.

Banks are currently allowed to drive at 120 mph or faster only if they are thought not to carry anything dangerous, like if they carry a cargo of loans to sovereigns or AAArisktocrats, if they carry a load that is perceived as risky, like loans to SMEs and entrepreneurs, then they must drive at much lower speeds. That is what the credit-risk-weighted equity requirements do.

The problem with that is twofold. First, since the drivers are paid based on how fast they complete the journey (returns on equity) they only carry “safe” cargo, which constitutes an odious discrimination against all those who need the transport of “risky” cargo. And second, that it does not make any traffic-safety-sense, because all major crashes have always occurred precisely when the drivers think they are carrying something safe and therefore speed too much.

2. Then Admati writes: “harm from finance is abstract and spread out. Connecting the harm to individual wrongdoing or recklessness is hard to establish. Courts might work for fraud, but you can't take someone to court for designing bad regulations.”

I believe you can. If somebody had designed regulations that discriminate based on race and gender they could be taken to court… at least so that those regulations were immediately suspended. Here the regulators are layering on artificial discrimination against the fair access to bank credit of those perceived as risky, precisely those who are already naturally discriminated against by bankers. There is an Equal Opportunity Act in the US, Regulation B, the problem is that no one is applying to what regulators concoct.

3. And Admati writes: “Goldman Sachs CEO was wrong when he said banking is ‘god's work.’ Creating and enforcing good financial regulation is god's work.” No way Jose! Neither Goldman Sachs CEO nor regulators can do God’s work. 1999 in a Op-Ed in I wrote: “The possible Big Bang that scares me the most is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause the collapse of our banks”.

4. Admati also gives some ideas of how to proceed: “First, increasing the pay of regulators may reduce revolving door incentives. Second, effective regulators might be industry veterans who are not inclined to go back. Third, we must try to reduce the role of money in politics.”

Yes... but totally insufficient! In terms of fixing current bank regulations there are three things that I find to be much more important. 

The first is to define a purpose for the banks that is agreeable to the society as a whole. In all thousand of pages of regulations, there is not a single word about what banks are supposed to do… and I ask: how on earth can you regulate what you do not know what it is to do?

The second to close up the mutual small admiration club bank regulators have turned themselves into. Sovereigns and AAArisktocrats might have access to regulators at the IMF or Davos… but risky borrowers are never invited.

The third is to fully understand the need of risk-taking. If nothing is done on that, rest assure, our grandchildren will damn the Basel Committee and the Financial Stability Board, for denying them the risk-taking of banks their economies need.

Saturday, May 2, 2015

We might want to consider “Friends and Family” weighted equity requirements for banks.

Currently the equity requirements for banks are credit-risk-weighted… more-credit-risk-more-equity and so less-credit-risk-less-equity.

That is dumb because never ever has a major bank crisis resulted from excessive lending to someone perceived as “risky”, these have always resulted from excessive lending to what was ex ante perceived as “safe” but that ex post turned out to be risky.

The only case when individual banks have gotten into problems extending excessive credits to somebody perceived as risky is when there had been some close connections between bank and borrower.

It could therefore be a case for analyzing Friends & Family weighted equity requirements for banks… though it is hard to think of who could perform an adequate rating of such relations… as we would also need to rate his F&F relation with bank and borrower.

That said, the least we must do, is to get rid of the credit-risk-weighted equity requirements when applied to those who are not F&F. These, for absolutely no reason, odiously impede their fair access to bank credit. That kills opportunities and therefore drives inequality.

Sunday, April 26, 2015

The Basel Committee for Banking Supervision’s tragic mistake of doubling down on perceived credit risks

Bankers manage the expected losses by means of perceiving credit risks. And if they are not good at it, they should fail.

Bank regulators on the other hand, need to impose equity requirements on banks to cover for unexpected losses. That is in order to create a buffer between a bank’s operations and the needs for taxpayers’ assistance.

Unfortunately, don’t ask me why, the Basel Committee for Banking Supervision imposed equity requirements on banks that are also based on perceived credit risks, more-risk-more-equity and less-risk-less equity.

That signified a doubling down on credit risk perceptions. And any risk, even when correctly perceived, can create much havoc, if it is given too little or too much importance.

As a consequence current allocations of bank credit to the real economy are utterly distorted, by favoring those perceived as “safe” and punishing those perceived as “risky”.

And also banks will most certainly have insufficient equity to cover for unexpected losses, simply because, the “safer” a borrower seems ex ante, the greater the possibility for the unexpected to cause truly huge disasters, ex post.

And this mistake that has been around for about 25 years, even after disaster struck, is still as of today, not yet even acknowledged by those responsible for it.

Wednesday, April 22, 2015

The amazing Achilles heels of the Basel Committee’s bank regulations

1. The unexpected losses (UL) are derived from the expected Probabilities of default (PD)

“It was decided… to require banks to hold capital against Unexpected Losses (UL) only. However, in order to preserve a prudent level of overall funds, banks have to demonstrate that they build adequate provisions against Expected Losses” (Page 7)

Under the implementation of the Asymptotic Single Risk Factor (ASRF) model used for Basel II, the sum of UL and EL for an exposure (i.e. its conditional expected loss) is equal to the product of a conditional PD and a “downturn” Loss Given Default (LGD) [a parameter that reflects adverse economic scenarios]. As discussed earlier, the conditional PD is derived by means of a supervisory mapping function that depends on the exposure’s average PD.

What does this mean? 

First, that the risk weights have nothing to do with the risk premiums banks charge. 

Second, the real dangerous unexpected losses in banking are most certainly inverse to the expected probabilities of default. The higher the expected losses the lower can we expect the probable size of the bank exposure to be… meaning, the safer an asset is perceived to be, the higher the possibilities of something really dangerous unexpected happening. In short this all does not make any sense.

Third, that this would not have been so serious if there had been an adjustment for portfolio risk, since most probably what is perceived as safe commands larger exposures...

but then, to top it up:

2. The risk weights are portfolio invariant... Holy Moly!

I cite directly from “An Explanatory Note on the Basel II IRB Risk Weight Functions” July 2005 (page 4) 

“The Basel risk weight functions used for the derivation of supervisory capital charges for Unexpected Losses (UL) are based on a specific model developed by the Basel Committee on Banking Supervision (cf. Gordy, 2003). The model specification was subject to an important restriction in order to fit supervisory needs: 

The model should be portfolio invariant, i.e. the capital required for any given loan should only depend on the risk of that loan and must not depend on the portfolio it is added to. This characteristic has been deemed vital in order to make the new IRB framework applicable to a wider range of countries and institutions. Taking into account the actual portfolio composition when determining capital for each loan - as is done in more advanced credit portfolio models - would have been a too complex task for most banks and supervisors alike. The desire for portfolio invariance, however, makes recognition of institution-specific diversification effects within the framework difficult: diversification effects would depend on how well a new loan fits into an existing portfolio. 

As a result the Revised Framework was calibrated to well diversified banks. Where a was calibrated to well diversified banks it is expected to address this under Pillar 2 of the framework. If a bank failed at this, supervisors would have to take action under the supervisory review process (pillar 2). 

What does this mean? 

That the benefits of diversification are completely ignored... that the risk weights have nothing to do with the size of the exposure… all because to consider diversification, that “would have been a too complex task for most banks and supervisors alike”, and so “the Revised Framework was calibrated to well diversified banks.” 

But, if a bank fail to be well diversified, then the supervisors, those who have just been deemed as not being able to understand what diversification is, shall address the problem under Pillar 2 of the framework, the “Supervisory Review Process.” Basel II (page 158) 

And if all that does not sound like sheer Kafkaesque lunacy, you tell me. 

As a result we then have portfolio invariant credit-risk-based equity requirements, which allow banks to hold less equity against safe assets than against risky assets, even though all major bank crises in history have never ever resulted from excessive exposures to what was perceived as risky, but always from excessive exposures to what ex ante was perceived as safe.

And that led to much lower equity requirements for what ex ante is perceived safe than for what is perceived risky.

And that caused banks to be able to leverage much more their equity, and the support society gives them, with assets ex ante perceived as safe than with assets perceived as risky.

And that caused banks to be able to generate much higher risk adjusted returns on equity with assets ex ante perceived as safe than with assets perceived as risky.

And that meant that banks would lend too much and at too easy terms to those perceived as safe, like to "infallible sovereigns" and the AAArisktocracy, and too little in relative too harsh terms, to those perceived as risky, like to SMEs and entrepreneurs.

With bank regulators like these… who need enemies?

And please read the Explanatory Note and consider what a regular subordinated regulator would dare to opine about it :-)

PS. Risk of cyber-attack weighted equity requirements for banks make much more sense than the credit-risk weighted

Tuesday, April 21, 2015

Requesting from the Members of the Royal Statistical Society a much needed Statistical Literacy Initiative

Anjana Ahuja yesterday pointed out in the Financial Times that you have launched the #ParliamentCounts campaign, offering all MPs a free training course in statistics. What a marvelous and commendable Statistical Literacy Initiative.

In reference to it may I also get your attention to briefly expose a very serious error in current bank regulations? The error is not only making our banks more dangerous, but is also seriously distorting the allocation of bank credit to the real economy. And, you the Royal Statistical Society, can definitely help to do something about it.

I refer to the pillar of current bank regulations, namely to what is known as the capital requirements for banks; or more precisely described the portfolio invariant credit-risk-weighted equity requirements for banks.

Its essence is to force banks to hold more equity against assets perceived as risky than against assets perceived as safe. Although it intuitively sounds correct, the following simple analysis of the only three possible outcomes, should suffice to illustrate the huge mistake. 

Outcome 1: The perceived credit risk is correct. Is this dangerous for banks? It should not be.

Outcome 2: The real credit risk turns out to be less that the perceived credit risk. Is this dangerous for banks? Absolutely NOT!

Outcome 3: The ex post credit risk turns out to be higher than the ex ante perceived credit risk. Is this dangerous for banks? YES!

And of course, the smaller the ex ante perceived credit risk has been perceived, the larger is its ex post potential danger.

Therefore regulators should have based their credit risk weighted equity requirements for banks, on the consequences of the real credit risks turning out to be higher than the perceived credit risks.

Unfortunately, the regulators based their portfolio invariant credit risk weighted equity requirements for banks solely based on Outcome 1, namely on the perceived risks being correct.

And now, facing clear evidence of how wrong their regulations are from a bank safety point of view, and of how much these credit-risk differentiated equity requirements distorts the allocation of bank credit, the regulators still fail to even acknowledge the existence of this mistake.

Dear members of the Royal Statistical Society, would you please help me to shame the regulators into waking up, before even more damaged is done? 

I am absolutely sure that if you send the Basel Committee, and the Financial Stability Board, and the IMF, a brief memo suggesting that instead of looking at the risk of the assets of banks, one needs to look at the risks of banks not being able to manage the risks of the assets of the banks, you would have significant more impact than what my little voice has been able to achieve during the last decade.

Please do this for the sake of our children and grandchildren and who are the ones who will most suffer the impact of this horrible regulatory mistake.

Yours truly,

Per Kurowski

PS. You will have to excuse me but, not being able to control my obsession with making this horrible mistake known to the world, I am making this letter public on my blog and on some social media.

@PerKurowski
A former Executive of the World Bank (2002-2004)

Sunday, April 19, 2015

Bank regulators de facto create another type of illicit financial flows

When regulators allow banks to hold less equity against what is perceived as safe than against what is perceived as risky then they increase substantially the flow of bank credit to the infallible sovereign and the AAArisktocracy, and decrease substantially the flow of bank credit to SMEs and entrepreneurs.

That is an odious regulation that favors those already favored; and an odious regulatory discrimination against those already naturally discriminated against, precisely by virtue of being perceived as risky.

That impedes banks to allocate credit efficiently to the real economy and, by killing the opportunities of the risky to have fair access to bank credit, increases inequalities. 

And so those regulations could be accused of de facto stimulating the creation of another type of illicit financial flows.

PS. And all for nothing, since never ever has a major bank crisis ever resulted from excessive exposures to something perceived as risky, they have all, no exceptions, resulted from excessive exposures to something erronously perceived as safe. 

Saturday, April 18, 2015

The importance of being ignored… by for instance the Basel Committee, the IMF and the Financial Times

The pillar of current bank regulations is risk weighted capital requirements for banks; or more exactly portfolio invariant credit risk-weighted equity requirements for banks. It signifies banks are allowed to hold much less equity against assets perceived as safe, than against assets perceived as risky.

Though intuitively it might sound extremely correct, it is extremely flawed, primarily for three reasons:

First, it just doesn’t make any sense from the perspective of making the banking system safe, since all major bank crises have resulted from excessive exposure to something perceived as safe but that ex post turned out not to be; and none from excessive exposures to something ex ante perceived as risky.

Second, allowing banks to leverage their equity, and the support the society lends them, differently, depending on perceived credit risk already cleared for by other means, introduces a tremendous distortion in the allocation of bank credit to the real economy.

Third, by discriminating the access to bank credit against those who by being perceived as risky are already naturally discriminated against, it kills equal opportunities and thereby fosters inequality.

I have voiced my furious objections to that regulation, for way over a decade, to no avail.

The indifference with which my arguments have been met, by the Basel Committee, the Financial Stability Board, the IMF, the Fed, the Bank of England and all other institutions related to bank regulations; plus that of medias such as the Financial Times, has undoubtedly been a source of frustration. And worst has it been when I am told that my questioning is obsessive, something which I have never negated, but when I have always felt that the way they have ignored this issue shows even more obsessiveness.

But, little by little, I have started to appreciate the fact that being ignored, has added a much more important aspect to my criticism. Had regulators accepted and corrected for their mistakes immediately, that would have undoubtedly been good. But at the same time that would also perhaps have shed less light on the importance issue of how little contestability and accountability there exists in institutions ruled by a self-appointed technocrats.

And so, when the world wakes up to the horrendous implications of this regulatory risk aversion, it might hopefully also be able to wake up and correct for the horrible regulatory procedures... and for the sort of bias in favor of regulators that many in the media show.

Then perhaps the SMEs and entrepreneurs could get a real hearing about their difficulties to access bank credit in Basel, in Davos or in Washington during the Spring or Annual Meetings of the IMF and the World Bank. 

Wednesday, April 15, 2015

The World Bank should act as an Ombudsman for our children and grandchildren

The Basel Committee for Banking Supervision (BCBS) is in charge of developing bank regulations that are applied by more and more countries around the world. That has increased the coherence and reduced somewhat the regulatory competition between countries. Unfortunately, it has also introduced a serious systemic mistake. 

The pillar of the BCBS’s current bank regulations, is the risk weighted capital requirements for banks; something which for more preciseness, should be termed the Portfolio Invariant Credit-Risk-Weighted Bank Equity Requirements. In essence it indicates: more-credit-risk-more-equity / less-credit-risk-less-equity. 

Though intuitively it sounds very reasonable, it contains two fundamental flaws.

First, the risk-weights used are based on the default possibilities of the assets of a bank, and not on a real analysis of what has caused the major bank crises in the past. In this respect it should be noted that the bank assets more likely to cause a major crisis, are not those perceived as risky, but those that are erroneously perceived as safe.

Second, much worse, allowing banks to leverage their equity, and the explicit and implicit support these receive from taxpayers, differently, depending on credit risks already cleared for with interest rates and size of exposures, seriously distorts the allocation of bank credit to the real economy. In essence it causes the bank system to lend too much and at too low rates to what is perceived as safe, like for instance to sovereigns and what I have termed as the AAArisktocracy; and too little, at relatively too high interest rates, to what is perceived as risky, like for instance to SMEs and entrepreneurs.

The origin of this mistake can primarily be traced to that regulators never really defined the purpose of our banks, beyond that of each one having to be safe. With that the regulators completely ignored that banks represent one of the most important agents through which the society distributes its savings, and the risk-taking that the economy needs in order to move forward, so as not to stall and fall.

Any regulatory interference and distortion of how bank credit is allocated, is very dangerous, and so, if it is to be considered and allowed, one needs to make certain that, at the very least, it is in pursuit of some extremely worthy purpose.

In this respect it could be illustrative, instead of credit-risk-weights, to think about the potential-of-job-generation weights, or environmental-sustainability-weights. That would allow the banks to earn their highest risk-adjusted returns on equity, financing what could most matter to us.

The World Bank, as the world’s premier development bank, must know that risk-taking is the oxygen of any development. It therefore has an enormously important role in supervising bank regulations from the point of view of how banks: promote development, allow for fair and inclusive access to finance, advance poverty reduction, generate jobs and help to bring on environmental sustainability.

The challenges loom large. Current credit risk based equity requirements, by making it harder than need be for those perceived as “risky” to access bank credit, kills opportunities and thereby promotes inequality. And, with its bias against credit-risk, it guarantees that banks will not finance sufficiently the “riskier” future, but mostly keep to refinancing a “safer” past.

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

The credit-risk-aversion present in current regulations could seem adequate for someone retired with a remaining short life expectancy. It is highly inadequate though, in fact dangerous, when set in the context of the needs of future generations. And in this respect I urge the World Bank to cast itself much more in the role of being the Ombudsman for our children and grandchildren.

And let us, somewhat older, never forget that much of what we can enjoy today, is the direct result of the willingness of the generations that preceded us to save and to take risks. We have the same duty… God make us daring!

@PerKurowski

PS. Here a statement closely related to this issue that I delivered as an Executive Director of the World Bank March 10, 2003

Monday, April 6, 2015

Follow my adventures battling the Basel Committee for Banking Supervision (and the Financial Stability Board)

Banks when deciding to give credit to safer or to the longer riskier, used to clear their risk adjusted rates freely, with no regulatory interference. That was before the outright insolent Basel Committee came along wanting to manipulate, and concocted that banks could leverage their equity 60 times or more to 1 on assets considering as safe, while not more than 12 to one on assets perceived as risky. And so of course, it couldn’t be any other way, banks lend too much at too low rates to what is ex ante perceived as safe, and too little at too high relative interest rates to what is perceived as risky.

And this is now destroying our economies.

Recently the Basel Committee released a consultative document titled “Revisions to the Standardised Approach for credit risk”. 

And below are my comments to that document. You might want to follow me and see what the Basel Committee answers, if it answers. I have been trying to extract a reaction from them for over a decade now, but no such luck.

March 27, 2015: Comments on the Basel Committees’ consultative document “Revisions to the Standardised Approach for credit risk”.

Sir, I object the whole document “Revisions to the Standardised Approach for credit risk”, on account that it does not yet acknowledge, much less correct, the most fundamental mistakes with the whole approach of setting bank equity requirements based on credit-risk weights.

The mistakes I refer to and that I would briefly like to point out are:

1. When referring to the “probability-of-default estimates” of borrowers and assets… it ignores that bank already manage and clear for these perceived credit risks, and so that these probabilities have little or nothing to do with the probabilities of a bank having problems. 

Again, the regulator has no business looking at the basically the same credit risks bankers are seeing and clearing for through interest rates, size of exposure and other terms. The regulator should look at the risk of banks not perceiving the credit risks correctly or not managing these correctly. If you do so you can empirically establish that all major bank crises are derived from excessive exposures to what has been erroneously perceived as safe, and not from what has been correctly perceived as risky. And, in this respect, the realities would point 180 degrees in the opposite direction… higher equity for what is perceived as safe. 

2. The regulator has not considered that allowing banks to leverage their equity, and the support they receive from taxpayers, differently depending on the perceived risk of the borrower/asset, introduces a violent distortion of the allocation of bank credit to the real economy. This because it allows banks to obtain different risk-adjusted returns on equity that what would have been the case without this regulatory distortion.

In the medium and long term, in an environment where bank credit is misallocated, there will be no safe banks. In a game of roulette, every bet has exactly the same expected value, and that is why the game works and survives. Changing the payout rates in roulette, by using something like your risk-weights, would crash a casino in seconds… and with “casino”, I refer to our economies.

3. The regulator has de facto exceeded whatever authority it could have been given, by for instance setting the risk weight for central governments at zero while imposing a risk weight of 100 percent on the loans to an unrated SME or entrepreneur. That can only be explained in the context of a statist ideology. That has transformed the “risk-free rate” into a subsidized risk-free rate. 

In fact, it is morally reprehensible for regulators to discriminate the access to bank credit in favor of “the safe” and against “the risky”… that creates a regulatory-subsidy to the safe and a regulatory-tax on the risky. By limiting the opportunities of “the risky” to have fair access to bank credit, the regulator is de facto increasing the inequalities in the world.

4. To top it up, the risk-weighted equity requirements are portfolio invariant, something that is absolute lunacy, since it ignores both the benefits of diversification and the dangers of excessive concentration.

5. As I warned in a letter in the Financial Times in January 2003, the excessive importance given to some few human fallible credit rating agencies introduced a serious source of systemic risk. What we read in this proposal only increases the complexity, and therefore increases the possibility of gaming the regulations, and increases the distortions, all without really diminishing any systemic risks. 

6. Borrowers are always interested in presenting themselves to the banks as being a low credit risk, in order to obtain lower risk premiums. And bankers used always to be interested in questioning the creditworthiness of the borrowers, in order to obtain higher risk premiums. That struggle helped to allocate bank credit efficiently to the real economy.

But, credit-risk-weighted equity requirements for banks and changed the relations. Now more important for the risk adjusted return on bank equity than the negotiation of risk premiums with borrowers, is dressing up the credit operation in such a way so as to allow the highest possible leverage of bank equity. And so, instead of using the tensions between borrowers and lenders, regulators managed to align both of these parties against them. Not too bright!

7. The distortions are causing serious economic risks. Just an example of it, is that the liquidity provided by current QEs cannot reach “the risky”, those we perhaps most need bank credit to reach. It is saddening to now see your proposal, in the case of senior corporate exposures, to set the risk-weights in function of size… as if the larger you are the safer you are… ignoring that the larger and the safer they seem the more you will be hurt if something goes wrong. Why on earth should The Large have even better access to bank credit relative to The Small than what they would usually anyhow have? 

8. It is stated: “The credit risk standardised approach treatment for sovereigns, central banks and public sector entities are not within the scope of these proposals. The Committee will consider these exposures as part of a broader and holistic review of sovereign-related risks.” “Holistic” Ha! Don’t you understand that what is someone’s light risk-weight, becomes immediately someone else’s very heavy risk weight?

9. The document does not indicate any concerns with how to go from here to there. Basel III introduced the not risk weighted leverage ratio, which will act as an equity floor, and you are also currently consulting on “Capital floors: the design of a framework based on standardised approaches”. But, raising the equity/capital floor, while maintaining the roof of the credit-risk-weighted equity requirements, will only increase the distortions, and could cause irreparable damages to the economies. For a more figurative explanation I refer you to the movie “The drowning pool”.

I have some other objections, but, for the time being, these will do.

Regulators, please, before you keep on regulating, go back and define the purpose of banks. It has to be more than to just be safe mattresses. It has to at least include not distorting the allocation of bank credit. 

With these credit risk adverse regulations, banks are financing less and less the risky future; and only refinancing more and more the safer past. That has to stop, for the good of our children and grandchildren. “A ship in harbor is safe, but that is not what ships are for.” John Augustus Shedd, 1850-1926

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

We have already seen too many low-risk-weights AAA bombs detonate with disastrous consequences. So when are you bank regulators going to stop trying being the self appointed risk managers for the world? You’re doing a lousy job at it, and not being held accountable for it.

Per Kurowski

PS. What do I like in the document? Though subject to all my other concerns, like not agreeing with the risk weighing, I do like the CET1 ratio used when setting risk-weights for banks. That ratio indicates that the better capitalized a bank is, the less will other banks be required to hold equity when lending to it, so the better borrowing conditions it can obtained, thereby leveraging the usual market response. That looks like a relative unobtrusive way to nudge banks into being better capitalized.

@PerKurowski
A former Executive of the World Bank (2002-2004)

Did they get my comments? Well here is the reply I received:

Comments on Basel Committee documents open for consultation
Thank you, your comments have been successfully submitted
Name of institution/individual:
Per Kurowski
E-mail address:
perkurowski@gmail.com
Document:
Revisions to the standardised approach for credit risk - consultative document
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Public
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Comments on the consultative document Revisions to the Standardised Approach for credit risk.docx