My letter to the Basel Committee on Banking Supervision and the Financial Stability Board
Basel Committee on Banking Supervision
Financial Stability Board
Dear Regulators
Since you still seem to be completely unaware of it, let me put forward a kindly reminder:
There has never ever been a major bank crisis caused by excessive lending or investments to what was perceived as risky, and these have all resulted from either unlawful behavior or excessive lending or investment into what was perceived as not risky, but later turned out to be.
Against that fact your capital requirements, based on the perceived risk, as perceived by your official risk-perceivers, the credit rating agencies, that establishes higher capital requirements for what is perceived as risky and lower for what is perceived as not risky, seems to be sort of a dumb idea. If anything, on a purely empirical basis, higher capital requirements for what is perceived as not risky would make more sense.
And, while I am at it, let me also remind you that the banks already use the information provided by the credit rating agencies when deciding what amounts and at what margins to lend to a client, and so to force them to also consider these for their capital base, gives the credit ratings a double weight, and, as we all know, even the best information, if it is excessively considered, is wrong.
By the way, your capital requirements, amount to an outright discrimination of those who we most need our banks to attend, the small businesses and entrepreneurs. Shame on you!
Best regards,
Per Kurowski
A former Executive Director at the World Bank (2002-2004)
http://subprimeregulations.blogspot.com/
Financial Stability Board
Dear Regulators
Since you still seem to be completely unaware of it, let me put forward a kindly reminder:
There has never ever been a major bank crisis caused by excessive lending or investments to what was perceived as risky, and these have all resulted from either unlawful behavior or excessive lending or investment into what was perceived as not risky, but later turned out to be.
Against that fact your capital requirements, based on the perceived risk, as perceived by your official risk-perceivers, the credit rating agencies, that establishes higher capital requirements for what is perceived as risky and lower for what is perceived as not risky, seems to be sort of a dumb idea. If anything, on a purely empirical basis, higher capital requirements for what is perceived as not risky would make more sense.
And, while I am at it, let me also remind you that the banks already use the information provided by the credit rating agencies when deciding what amounts and at what margins to lend to a client, and so to force them to also consider these for their capital base, gives the credit ratings a double weight, and, as we all know, even the best information, if it is excessively considered, is wrong.
By the way, your capital requirements, amount to an outright discrimination of those who we most need our banks to attend, the small businesses and entrepreneurs. Shame on you!
Best regards,
Per Kurowski
A former Executive Director at the World Bank (2002-2004)
http://subprimeregulations.blogspot.com/
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