Wednesday, September 2, 2015

The Basel Committee’s credit risk weighted capital requirements for banks… explained by Mark Twain

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

The so anxious Basel Committee for Banking Supervision thought banks lend out their umbrella much too little when the sun was out, and much too much when it looked like it was going to rain.

And so even though banks already cleared for credit risk perceptions, by means of risk premiums and size of exposures, the bank nannies decided that the capital banks should be required to have, should also consider those same credit risk perceptions; more risk more capital – less risk less capital.

And that means banks can now leverage much more their equity, and the societal support they receive, for instance by means of deposit guarantees, when lending out the umbrella on sunny days than when lending it out on rainy days.

And so banks are lending out less than ever the umbrella when it looks like to rain… and as a consequence the real economy is getting wet and getting a cold.

And all for nothing since never ever have major bank crises resulted from too much lending of the umbrella on days perceived as rainy, but always from too much lending when a sunny day was announced, but the weatherman got it all wrong.

I ask, where would we be if our forefathers’ banks had been subject to credit-risk weighted capital requirements?


Sunday, August 30, 2015

Stop the risk aversion and pro-government bias of bank regulations. Deceitfully it plunders our young's future.

A friend told me I had to read Mark R. Levin´s “Plunder and Deceit”, and when I saw it was subtitled “Big governments exploitation of young people and the future” I immediately ordered a copy. 

And in its first chapter I read about the intergenerational continuum of the past, the living and the unborn… and I knew the author and I, at least in this respect, shared very similar concerns.

And just looking through the index, I knew I had to add a chapter to this book titled: “God make us daring!”

Why? Because the most important driving force on the intergenerational continuum is the willingness of those of us here now, to take the risks needed today in order for the tomorrows of our descendants to be brighter and brighter.

But, unfortunately, tragically, our most important societal financiers of risk-taking, the banks, have been instructed not to attend to the credit needs of The Risky, but to keep financing solely The Safe. How come? 

Regulators imposed capital requirements on banks that are much higher for what is perceived a risky, from a credit risk point of view, than for what is perceived as safe. That allows banks to leverage their equity and the support these receive from the society much more when lending to The Safe than when lending to The Risky. And that of course allows banks to earn much higher risk adjusted returns on equity when lending to The Safe, than when lending to The Risky.

And so regulators have impeded the fair access to bank credit of those perceived as risky, like SMEs and entrepreneurs, and therefore banks are no longer helping out financing the future of our young people, they are only refinancing the past.

And, to top it up, with that so amazingly unnoticed historical event of the Basel Accord of 1988, regulators decided the risk-weight for sovereigns was zero percent, while the risk-weight of citizen 100 percent. And with that these statist/communists de facto made our banks to operate under the assumption that government bureaucrats use bank credit more efficiently than the private sector.

And the credit-risk-aversion and pro-government bias introduced in our bank regulations, has our western civilization going down and down

In April 2013 the Washington Post published the following letter I wrote:

“It suffices to remember the saying about “a banker being that chap who lends you the umbrella when the sun shines but wants it back as soon as it looks like it is going to rain” to know that those assets perceived as safe are already much favored over those perceived as risky. The risk weights applied by the Basel regulations and based on exactly those same perceived risks only increase the gap between “The Infallible” and “The Risky.” 

And that is why I very much salute the bill by Sens. Sherrod Brown (D-Ohio) and David Vitter (R-La.) that looks to “require more capital and better capital but also limit the ‘risk-weighting’ of assets.” More capital is a perfectly legitimate requirement, but the imposition of risk weights is fundamentally incompatible with “a land of the brave.” The United States did not become what it is by avoiding risks.”

Unfortunately, in the Home of the Brave, the interests of bankers making their dreams of very high returns with very little risks come true, seems to trump the needs of its younger. 

America: Why do you saddle your young and brightest with huge education loans, if you’re not willing to allow banks financing those who might generate the jobs your young need in order to service that debt?

US Congressmen and Governors: How come you allow your banks to hold less capital when financing sovereigns and members of the AAArisktocracy, than when financing your own small unrated local businesses?

US bank regulators: Have you never heard of the Equal Credit Opportunity Act (Regulation B)?
A verse of a Swedish Psalm 288 reads: 

God, from your house, our refuge, you call us 

out to a world where many risks await us. 
As one with your world, you want us to live. 


PS. And all this risk adverse and pro-sovereign regulations for nothing! Major bank crisis do not result from excessive exposures to what was perceived as risky, these always result, no exceptions, from excessive exposures to what was erroneously perceived as very safe. Just look at the AAA rated securities backed with mortgages to the subprime sector... and Greece.

Saturday, August 29, 2015

Why does IMF never mention that credit-risk-weighted capital requirements for banks, is a potent inequality driver?

I refer to an IMF Staff-Discussion-Note titled “Causes and Consequences of Income Inequality: A Global Perspective”. It includes among other “Factors Driving Higher Income Inequality” the following:

“Financial globalization. Financial globalization can facilitate efficient international allocation of capital and promote international risk sharing. At the same time, increased financial flows, particularly foreign direct investment (FDI) and portfolio flows have been shown to increase income inequality in both advanced and emerging market economies… Financial deregulation and globalization have also been cited as factors underlying the increase in financial wealth, relative skill intensity, and wages in the finance industry, one of the fastest growing sectors in advanced.

Financial deepening. Financial deepening can provide households and firms with greater access to resources to meet their financial needs, such as saving for retirement, investing in education, capitalizing on business opportunities, and confronting shocks. Financial deepening accompanied by more inclusive financial systems can thus lower income inequality, while improving the allocation of resources… Theory, however, suggests that … inequality can increase as those with higher incomes and assets have a disproportionately larger share of access to finance, serving to further increase the skill premium, and potentially the return to capital.”

And again I must ask: Why does IMF insist on keeping mum on that huge financial inequality driver that is the risk-weighted capital requirements for banks?

Society lends bank much support, not only directly, by entrusting it with its deposits, but also indirectly, by offering deposit guarantees that if called upon will be paid by taxpayers.

And the Basel Committee thought it could make banks safer by making the capital requirements for banks to be dependent on perceptions of credit risk… while entirely ignoring that those perceptions of risk were already cleared for, by means of risk premiums and size of exposure.

And so, for instance with Basel II, regulators decided that banks were allowed to leverage the societal support over 60 times to 1 when lending to the AAArisktocracy, namely those rated AAA to AA, but only about 12 times to 1, when lending to unrated SMEs and entrepreneurs. That, which allows banks to earn much higher risk-adjusted returns on equity when lending to “The Safe”, blocks the opportunities of “the risky” to obtain fair access to bank credit. It therefore constitutes a huge driver of inequality.

And since the document refers to “Financial deregulation” I must also ask, for the umpteenth time…what financial deregulation? That where a small number of regulators redirect the allocation of bank credit all over the world… de facto imposing global capital controls? You’ve got to be kidding!

No! The Basel Committee is just a nest of irresponsible populist technocrats, who frankly have no idea of what they are doing. For instance they derive those capital requirements, that they themselves declare should be there to cover for unexpected losses, from the perceptions of expected losses. How loony is not that? Clearly the safer something is perceived, the bigger its potential to deliver truly disastrous unexpected losses.

I have often complained about these regulations on the IMF blog… you can Google it on “blog-imfdirect.imf.org Kurowski”. But I have never received an answer from IMF, seemingly the automatic solidarity among technocrats is very strong.

Tuesday, August 25, 2015

One of Basel Committee’s many monstrous regulatory mistakes made easy. The expected and the unexpected mix up.

As regulators have explicitly stated, banks should be required to have capital (equity) as a cushion against unexpected losses. 

In Basel II, the risk weight applied to assets of private corporations rated AAA to AA, was 20%. This weight, applied to a base capital of 8%, signified banks had to hold 1.6% in capital against these “safe” assets. And the correspondent risk-weight for assets rated BB- and below, was 150%, which meant banks had to hold 12% in capital against these “risky” assets.

Let me ask anyone of you… what carries a larger potential of dangerously high-unexpected losses, what is rated AAA to AA, or what is rated below BB- and for which therefore the expected losses are huge? 

Do you get the drift?

Also, the moment a risk is generated for a bank is not when an asset is down-rated, but when that asset is put on the bank’s balance sheet. But currently it is when a credit gets down-rated that regulators, much too late, jack up the capital requirements; something which makes it even more difficult for banks to manage the problem assets.

PS. This is one of the many observations regulators have steadfastly refuse to comment on. If anyone of you is able to extract something of an answer from these not accountable to anyone regulators, I would be grateful to know about it.

Friday, August 21, 2015

World Bank, before Public Credit Guarantee Schemes (CGSs) help removing the obstacles to bank lending to SMEs


As a justification the document states something we can all surely agree on: “Financial inclusion, particularly for small and medium enterprises (SMEs), is widely recognized as one of the key drivers of economic growth and job creation in all economies. SME credit markets are notoriously characterized by market failures and imperfections including information asymmetries, inadequacy or lack of recognized collateral, high transaction costs of small-scale lending and perception of high risk.”

We also read: “In order to address these market failures and imperfections, many governments intervene in SME credit markets in various forms. A common form of intervention is represented by credit guarantee schemes (CGSs). A CGS provides third-party credit risk mitigation to lenders with the objective of increasing access to credit for SMEs. This is through the absorption of a portion of the lender’s losses on the loans made to SMEs in case of default, in return for a fee. The popularity of CGSs is partly due to the fact that they typically combine a subsidy element with market-based arrangements for credit allocation, therefore involving less room for distortions in credit markets than more direct forms of intervention such as state-owned banks.”

And I would want to draw your attention specifically to: “they typically combine a subsidy element with market-based arrangements for credit allocation, therefore involving less room for distortions in credit markets.”

That because the World Bank Group and the FIRST Initiative, are aware of the existence of risk-weighted capital requirements for banks which allow banks to leverage much less their equity when lending to “The Risky”, like SMEs than when lending to “The Safe” like sovereigns and the AAArisktocracy.

And they must also be aware that these regulations impede “market-based credit allocation, and cause huge distortions in credit markets”. We know that because already in the World Banks' The Global Development Finance 2003 (GDF-2003), “Striving for Stability in Development Finance” it 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….”

And so, though welcoming very much this initiative of the World Bank and the FIRST Initiative, I pray that it is not in substitution of getting rid of the portfolio invariant credit-risk weighted capital requirements for banks, which blocks SMEs from having fair access to bank credit. If it is, then let me assure you the “Public Credit Guarantee Schemes (CGSs) for SMEs” discussed amounts to a petty consolation prize for the SMEs, and could even increase the existing regulatory distortions.

We read the consultation invites “stakeholders -- governments, credit guarantee schemes (CGSs) and lenders” should not SMEs, or those who speak up for the borrowers’ rights of not being discriminated against by regulators, be specifically invited?

The Basel Committee is a pitiful bunch of bank regulators incapable of expressing even the smallest “We’re sorry Greece”

There is no doubt whatsoever that had regulators not allowed to leverage their equity over 60 times to 1 when lending to Greece, Greece not matter what accounting shenanigans it could come up with, would not have been able to borrow as much as it did. 

And now, as a consequence, we read about Greece having to hand over 16 of its airports to those who  in order for the creditors to be paid, have paid for the right of charging a toll on much of the future tourism to Greece.

And yet not even the slightest hint of the Basel Committee telling Greece, and its creditors, they're sorry. What a sad bunch of technocrats.

Wednesday, August 19, 2015

How to blow up the banking system

Q. What is the most dangerous for banks?

A. That they build up excessive dangerous exposures to something that turns out much riskier than they expected

Q. When do banks usually build up such exposures?

A. Obviously when they perceive something as very safe and they expect to make very good returns on it.

Q. And what else can make those excessive bank exposures especially dangerous, for instance for the taxpayers?

A. That the banks, if something goes wrong, stand there almost naked with very little equity to cover the losses.

Q. So hypothetically, mind you, what would you think of credit-risk weighted capital requirements for banks that are especially low for what is perceived as safe?

A. Well, since that would allow banks to earn the highest risk adjusted returns on what is perceived as safe, it would therefore, sooner or later, cause banks to build up dangerously excessive exposures to what is perceived as safe against very little capital, and so it sure sounds like the perfect way to blow up the banking system..... Sir, excuse me, why do you ask all this?

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

Note: My January 2009 AAA-Bomb blog

Saturday, August 8, 2015

Pension funds, widows and orphans have been told to keep out of what’s perceived safe, that’s now the banks’ domain

Bank regulators, with their credit-risk-weighted capital requirements, allow banks to leverage their equity and the support received by deposit guarantees and similar, immensely, as long as they stick to lending to “The Safe”... in their mind the infallible sovereigns, the AAArisktocracy and housing.

Consequentially the more regulators favor and therefore subsidize bank lending to “The Safe”, the lower will be the interest rates paid by “The Safe”... sometimes even down to zero interests, and, of course, in relative terms the higher the rates “The Risky” need to pay. 

Ergo… non-banks who have to evaluate the increased spreads between The Safe and The Risky, without counting with the regulatory bank-subsidies, are more tempted by, or are in more need of the higher rates paid by The Risky.

Pension funds, widows and orphans who were the one investing in “The Safe”, have now been told to get out of there… “That’s for the banks!”

"The Risky", like the SMEs and the entrepreneurs they used to have access to the banks… now they are left out in the cold… desperately looking for some crowd-funding.

Wednesday, August 5, 2015

Why has not a proper independent autopsy of the financial crisis 2007-08 been done? The answer: What would be found!

When we see with how much care and dedication investigators perform the autopsy of the causes of an accident whenever a plane crashes, one can truly be surprised about how little autopsy has been performed on the 2007-08 financial crash.

But of course those performing the autopsy of a plane crash are not the designers of the plane, nor those responsible for its maintenance, nor air-traffic controllers nor, of course, those who were flying it… and so there are no conflicts of interests present in the investigation (I presume).

In the case of the Financial Crisis 2007-08 crisis any outside completely independent investigator would have determined its principal cause to be:

The very low capital requirements for banks when holding assets perceived as “safe”, and which created unmanageable perverse incentives for banks to lend or invest excessively in what was ex ante perceived as safe.

Evidences?: Just look at the debris: AAA rated securities, credit default swaps issued by AAA rated AIG, loans to sovereigns like Greece, loans to real estate like in Spain. Nowhere is something ex ante perceived as "risky" found to have caused any problem. What more can you need for a prosecutor to rest his case?

But since those investigating the Financial Crash 2007-08 were, by commission or omission, directly responsible for those risk weighted capital requirements, they all found it in their best interest to shut up.

Until now their strategy has worked splendidly for them... even deregulation is denounced a thousand times more as the source of the problem than their misregulation... and some of them have even been promoted, like to BIS and ECB... and other have found job working on Basel III.

  

Monday, August 3, 2015

What were (are) regulators in the Basel Committee smoking when they set their capital requirements for banks?

The capital requirements for banks are primarily, almost exclusively, to cover for Unexpected Losses (UL), since the Expected Losses (EL) are covered by means of risk premiums, size of exposures and other terms.

And this the bank regulators know as we read in “An Explanatory Note on the Basel II IRB Risk Weight Functions”.

It states: “Banks are expected in general to cover their EL on an ongoing basis, e.g. by provisions and write-offs, because it represents another cost component of the lending business. The UL, on the contrary, relates to potentially large losses that occur rather seldom. According to this concept, capital would only be needed for absorbing UL… [and so] it was decided to follow the UL concept and to require banks to hold capital against UL only.”

But then the strangest thing happened! The regulators, when calculating those UL decided to do this all with formulas that used the EL, and so, inexplicably, they came up with capital requirements that indicate the potential of higher UL for higher EL.

And that just cannot be. It is clear that the safer an asset is perceived, the larger its potential to deliver UL. It is also clear that many of UL in a bank can derive from causes completely unrelated to the intrinsic riskiness of assets… like for instance a cyber-attack.

And, as a result of the confusion, the current capital requirements for banks are much higher for assets perceived as “risky” than for assets perceived as “safe”, with the following consequences:

Banks are able to create huge exposures, against very little capital, to what is ex ante perceived as safe but that ex post could turn out risky, and that is precisely the stuff major bank crises are made of.

The allocation of bank credit is much distorted since using Mark Twain’s analogy bankers will now lend out the umbrella even more than usual when the sun is out and want it back faster than ever as soon as it looks like it is going to rain.

Just look at how much those in the sun, like AAA rated securities, real estate and governments (like Greece) have been able to borrow, when compared to the much tightened borrowing conditions for SMEs and entrepreneurs.

And so nowadays, thanks to our regulators, banks are not financing the riskier future but are mainly busy refinancing the safer past… Friends, where are the jobs for our grandchildren come from?

Wednesday, July 29, 2015

Sir Jon Cunliffe. Tiberius would have regulated banks much better than the Basel Committee.

I hereby reference a speech titled “Macroprudential policy: from Tiberius to Crockett and beyond” given on July 28 by Sir Jon Cunliffe, Deputy Governor Financial Stability, Member of the Monetary Policy Committee, Member of the Financial Policy Committee and Member of the Prudential Regulation Authority Board 

Sir Cunliffe writes: “the underlying prudential standards – the reserves of capital and liquid assets that individual banks and other firms need to hold to enable them to withstand bad times – should be set not simply in relation to the risks in the individual firm, but also to reflect the importance of the firm to the financial system and the cost to the economy as a whole if the system fails”

Indeed but it was precisely there, when defining the risks of an individual firm, that regulators completely lost it:

Instead of considering the risks of unexpected losses, and the risk that banks would not be able to clear for the perceived risks, the regulators based “the reserves of capital and liquid assets that individual banks and other firms need to hold to enable them to withstand bad times” on the expected losses derived from the perceived credit risks… the only risks that were already being cleared for by banks by means of size of exposure and risk premiums…

And, as the regulator should have known, any risk even when perfectly perceived is wrongly managed if excessively considered. And that completely distorted the allocation of bank credit to the real economy.

If you’re a kid and your parents assign two nannies to care for you, you can still live a fairly ordinary childhood if the average of your two nannies’ risk aversion is applied. But, if their two risk aversions are added up, you stand no chance, then you better forget about having a childhood.

Sir Cunliffe writes: “The financial system does not simply respond to the economic cycle, growing as the economy grows and vice versa. It also feeds on its own exuberance in good times and on its fear in bad times which can in turn drive the real economy to extremes, as we have witnessed in recent years. The underlying causes of this phenomenon are interactions, feedback loops and amplifiers that exist within the financial system that can act as turbo chargers in both directions”

Precisely and perceived credit risks, credit ratings are main feedback loops and amplifiers that exist within the financial system. In January 2003 in a letter published in FT I wrote: “Everyone knows that, sooner or later, the ratings issued by the credit agencies are just a new breed of systemic error to be propagated at modern speeds. Friends, please consider that the world is tough enough as it is.”

Sir Cunliffe writes: “recognition that what distinguishes ‘macroprudential’ from ‘microprudential’ and from ‘macroeconomic’ is its objective of financial system stability rather than the instruments it deploys.” 

Let me spell it out more directly: 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.

Sir Cunliffe so correctly writes: “The financial system plays a crucial role in a modern economy directing resources to where they can be most productive and can generate the greatest return. When the dynamics of the system itself distort incentives and judgments of risk and return, there can be a huge misallocation of resources in the economy. And when the bubble bursts and the economy has to adjust, a damaged financial system cannot guide the necessary reallocation of resources – indeed, as we have witnessed, it can slow it down.”

How unfortunate then that Sir Cunliffe, and his regulatory colleagues, cannot get themselves to understand that the pillar of their regulations, the portfolio invariant credit risk weighted capital requirements, is in fact the greatest source of distortion in the allocation of bank credit of them all. It guarantees the dangerous overpopulation of safe havens, as well as the equally dangerous lack of exploration of the riskier but perhaps much more productive bays.

Sir Cunliffe begins his speech by saying “Historians still argue about the exact causes of the financial crash of AD 33 that rocked the Roman Empire.” 

I guarantee him that historians will soon know perfectly well what caused the financial crash of 2008, and why it is taking so much time for the world to get out of it. And they will not be kind on the current batch of regulators. Without being clear about the crash of AD 33, they will have no doubt about that Tiberius would have known better than the Basel Committee.

Tiberius would have picked bank regulators who would have tried to understand why banks fail... not why bank clients fail. 

Tiberius would have picked bank regulators who would have known that the biggest risk for the banking system is that of not allocating bank credit efficiently to the real economy... as no bank can  remain safe while standing in the midst of the rubbles of a destroyed economy.

Thursday, July 23, 2015

Do we really want to bet our economies on government bureaucrats using bank credit better than SMEs and entrepreneurs?

Those who protest government austerity the loudest are frequently those who most want to force banks to increase their capital. Let us analyze the implications of that position:

If governments are not going to be austere and spend more, and consequentially run deficits, it is only natural governments will need to take on more debt.

If banks are forced to hold more capital then, while the banks find more capital and adjust their business models to those new realities, there is going to be quite a lot of austerity when it comes to the supply of bank credit to the economy.

Since current capital requirements for banks are lower when lending to the government than when lending to the private sector, that will generate a bank credit squeeze on the private sector, affecting most especially those against which loans banks needs to hold more equity, like the SMEs and the entrepreneurs.

The only way to bridge the contradiction between government austerity being something bad for the economy, and bank credit austerity something good for the economy, is of course by believing that government bureaucrats can use bank credit more efficiently than SMEs and entrepreneurs. And that friends, is a truly doubtful proposition on which to bet the future of our economies.

Citizens, it behooves us to unite much more than what government bureaucrats/technocrats unite.

In the case of banks, the Modigliani-Miller Theorem is absolutely inapplicable

James Kwak of the Baseline Scenario, in a post titled: “More Misinformation about Banking Regulation” while discussing the effects of increased capital requirements writes:

“The Modigliani-Miller Theorem…says that a firm’s capital structure — the amount of equity it has relative to debt — doesn’t matter: in the case of the hypothetical bank, if you increase equity and reduce debt, after the reduced debt payments, there is just enough cash left over to compensate the larger number of shareholders at the lower rate that they are now willing to accept.

Now, the assumptions of Modigliani-Miller don’t hold in the real world, but the main reason they don’t hold is the tax subsidy for debt…

Since the cost of capital doesn’t change with capital requirements (except, again, because of the tax subsidy for debt), the amount of bank lending doesn’t change either.” 

Oops… that is in itself some misinformation! 

For banks, besides tax considerations, the Modigliani-Miller Theorem is absolutely inapplicable; since it does not consider the value of the support society (taxpayers) explicitly or implicitly give the holders of bank debt. If a bank has 100% equity then all risk falls on the shareholder and the societal support is 0. If a bank has 5% equity and 95% debt then society contributes a lot to the party.

Frankly, like in Europe, where some banks were leveraged about 50 to 1, and rates on bank deposits are still low, who on earth can one even dream to bring the Modigliani-Miller Theorem into the analysis?

And the fluctuating societal support, is one of the main reasons behind the argument I have been making for over a decade, about how credit-risk adjusted capital requirements for banks distort the allocation of credit. Regulators are telling the banks: If you lend to what is perceived as safe, like to the AAArisktocracy, then you are allowed to hold less capital, meaning leveraging more, meaning you will receive more societal (taxpayer) backing, than if you lend to a risky SME. 

And so of course, if you increase capital requirements which reduces the leverage, banks will get less taxpayer support… ergo lend less and at higher interest costs. Would that be bad for the economy? Of course it would keep billions out of the economy (it already happens) especially while business models are adjusted and bank capital increased. But that austerity J (less societal support spending) though it would hurt would not necessarily be bad… what is really bad for the economy are the different capital requirements for different assets… since that stops bank credit from being allocated efficiently.

Take away all deposit guarantees and all bailout assistance, and then the Modigliani-Miller Theorem, subject to tax considerations would be more applicable to banks.

Monday, July 20, 2015

Mark Carney: Would the Magna Carta include risk-weights like these: King John 0%, AAArisktocracy 20% and Englishmen 100%?

The Basel Accord of 1988 (signed one year before the Berlin wall fall) bank regulators assigned a 0% risk weight for loans to the sovereign and 100% to the private sector. Some years later, 2004, with Basel II, they reduced the risk-weight for loans to those in the private sector rated AAA to AA to 20%, and leaving the unrated with their 100%.

That introduced a considerable regulatory subsidy on the bank borrowings of the infallible sovereign (government bureaucrats) and of those of the private sector deemed almost infallible. And taxing the fair access to bank credit, of those deemed as risky, like SMEs and entrepreneurs, pays those subsidies.

Reading Mark Carney’s interesting: “From Lincoln to Lothbury - Magna Carta and the Bank of England” I felt like asking him what he would think the Magna Carta would have to say about these risk-weights.

Saturday, July 18, 2015

Fed: The biggest stress resulting from banks might be their misallocation of bank credit to the real economy.


Banks are not there just to make profits for their shareholders, or to be safe places where to stash away money… they are there to perform the social function of allocating as efficiently as possible bank credits to the real economy. That’s the only logical reason why taxpayers could be willing to lend them support.

In this respect any stress-test that does not include looking at assets banks have on their balance sheet from more than credit risk perspective, is an utterly incomplete test.

For instance taxpayers should be able to do know how much unsecured bank credit has gone to SMEs and entrepreneurs, and how that lending has evolved over the last 3 decades.

Friday, July 10, 2015

Prioritizing the financing of residential property over the financing of job creation is not the smartest thing to do

Based on Basel II’s standard capital requirements for banks, these are required to hold 2.8 percent in capital when lending secured by mortgages on residential property and 8 percent when lending to SMEs and entrepreneurs. 

That means that the adjusted for risk net margin paid by a residential borrower can be leveraged 35 times by the bank (100/2.8), while the same margin can only be leveraged 12.5 times (100/8) if paid by SMEs and entrepreneurs.

And that means banks can obtain much higher risk-adjusted returns on equity when lending secured by mortgages on residential property than when lending to SMEs and entrepreneurs. 

And that means that banks will find it much more interesting to finance residential property than to finance those who can help to create the jobs to help residential mortgages and utilities to be serviced.  

That definitely sound skewed the wrong way. If I was the regulator I would much rather prefer banks financing more the creation of jobs, so that people could better afford to buy their homes with less financing… but that’s just little me.

“But building homes creates jobs?” Indeed, but once everyone has a home, and a mortgage to service, which diminishes their available income, where are our grandchildren to work?

Thursday, July 9, 2015

The Financial Stability Board makes efforts to identify “Risk Free Benchmarks”...and I don't know whether to laugh or cry

The Financial Stability Board issued a report on trying to identify “Risk Free Benchmarks

That, in ordinary circumstances, is a very difficult thing to do, since so many other factors than just pure risk considerations, are involved in creating interest rates… for instance tax considerations. 

But, when bank regulators, with Basel I and II, introduced credit-risk weighted capital requirements for banks, by distorting the allocation of bank credit so completely, they made it impossible to determine anything close to real risk free-rates.

The easiest way I have found to explain this issue is by making the following question: What would the rates on for instance US Treasury Bonds and Germany’s Bunds be, if banks were required to hold the same percentage of capital against these that they are required to hold against a loan to an American or a German SME?

PS. The subsidized risk free rate

Greece urgently needs lower capital requirements for banks when lending to SMEs than when lending to its government

Between June 2004 and November 2009 thanks to Basel II, banks were allowed to lend to the Government of Greece against only 1.6 percent in capital while requiring banks to hold 8 percent in capital when lending to the private sector.

That meant that banks could leverage their equity 62.5 times lending to the Government but only 12.5 times when lending to the private sector.

That meant, of course, that banks ended up lending much too much to the government and much too little to the private sector, like to Greek SMEs and entrepreneurs.

And here we are with Greece stuck in the doldrums and not finding its way out.

If I were its doctor, I would immediately recommend that banks should be allowed to hold less capital when lending to the private sector than when lending to the government. Since the private sector is the heart of the economy it is very urgent it gets out of it flat-line, by banks pumping the oxygen it needs.

Just before the fall of the Berlin wall, communists/statists gave the free market and capitalistic world the finger.

In 1988, just before the fall of the Berlin wall in 1989, some communists/statists hacked into the free market capitalist world’s bank regulations. By means of Basel I, and for the purpose of determining the capital requirements for banks, they arranged so that the risk weight for lending to OECD sovereigns was zero percent, the risk weight for lending secured with houses 50%, while the risk weight for lending to the private sector was set at 100 percent.

Since the basic capital requirement was set at 8 percent that meant that banks could leverage 62.5 times to 1 (100/1.6) when lending to sovereigns, 25 to 1 (100/4) when financing the purchase of houses and 12.5 times to 1 (100/8) when lending to the private sector. 

That doomed bank to lend too much to the governments and too much to the housing sector, and basically to abandon the traditional role of banks, namely to provide credit for the private sector, like to SMEs and entrepreneurs.

And that in turn doomed the free market and capitalistic economies of the western world.

And so who’s laughing now?

Please, for the good of our grandchildren, it might already be too late for our children, help me tear down that Basel Committee wall… urgently … Greece is just the tip of the iceberg!

Tuesday, July 7, 2015

Do we need capital requirements for banks based on willingness-and ability-to-lie-and-cheat-ratings?

With Basel II of June 2004, the Basel Committee imposed capital requirements for banks based on credit ratings... stupidly ignoring that bankers were already clearing for such ratings by means of risk-premiums and size of exposures… and naively thinking those credit ratings would always capture real risks.

After having seen the mess that has been caused by for instance much too good credit ratings for the AAA rated securities backed with mortgages to the subprime sector, and the loans to the government of Greece, one could suspect that smarter regulators would have based their capital requirements for banks based on willingness-and ability-to-lie-and-cheat-ratings.

Some decades ago somebody asked me… how come this honest Scandinavian country come up as  more honest than this other honest Scandinavian country on the worldwide corruption index? My instinctive reaction was… the first must have paid more.

Frankly, our current bank regulators have been taken for a ride… an extremely costly ride for us since regulators now dangerously distort the allocation of bank credit.