Thursday, February 27, 2014

Regulators, what have the ex ante perceived as “risky” ever done to you, or to the banks?

Why do you require banks to hold more capital against loans to medium and small businesses, entrepreneurs and start-ups, only because these are perceived as “risky”, than the capital banks need to hold against loans to the “infallible sovereigns”, the housing sector or the AAAristocracy? 

Beats me! The former, those perceived as “risky” when originally incorporated in a bank balance, have never ever set of a major bank crisis, those crises have always resulted, no exceptions, because of excessive bank exposures to those erroneously perceived as "absolutely safe" .

And regulators, your risk aversion psychosis causes then banks to earn less return on equity when lending to the “risky” than when lending to the “safe”, and so banks stop lending to medium and small businesses, entrepreneurs and start-ups.

Is that really prudent from the perspective of keeping the real economy strong and sturdy so as to not pose a threat to the stability of the banking system? 

Is it because the “risky” are dirty, smelly and ugly when compared to the “absolutely safe”? Is that also the reason why you never invite them to Basel, or to other venues, so as to hear their opinions about these odiously discriminating risk-weighted bank capital requirements of yours? 

You've got to stop this nonsense… Now! If medium and small businesses, entrepreneurs and start-ups do not have access to bank credit in fair terms, our young will, no doubt about it, become a lost generation.

Wednesday, February 26, 2014

Mr. Stefan Ingves… I do seriously disagree with your “risk-based capital adequacy ratios”, and I dare you to debate it.

Mr. Stefan Ingves the Chairman of the Basel Committee on Banking Supervision delivered a speech titled “Banking on Leverage" during a High-Level Meeting on Banking Supervision, held Auckland, New Zealand, 25-27 February 2014.

In it Ingves stated: “Risk-based capital adequacy ratios have been the cornerstone of the Basel framework since it was introduced 25 years ago. Capital adequacy ratios measure the extent to which a bank has sufficient capital relative to the risk of its business activities. They are based on a simple principle: that a bank that takes higher risks should have higher capital to compensate. Of course, there are plenty of challenges in measuring risk -- something I will come back to shortly -- but I have yet to meet anyone who seriously disagrees with that simple principle.”

Well I am one who seriously disagrees with that principle… and I dare him to meet me and debate the issue.

A bank, when taking risks, high or low, should compensate for any probable expected losses, by means of interest rates (risk premiums), the size of the exposure, and other terms, like the duration of the loans and guarantees.

And, if the banker does his job well, and adjusts adequately to the risk, then capital has absolutely no role to play in that. And, if the banker does not know how to do his job well, and does not adjust adequately to the risks, then he should fail, the sooner the better for all, so that the bank accumulates as little combustible mistakes as possible.

But a bank regulator, like the Basel Committee, cannot and should not, entirely trust that all risks are being duly perceived by the bankers because, as we all know, there are such things as hidden risks and unexpected losses.

But any hidden risks and unexpected losses cannot be approximated by means of the perceived risks and the expected losses… in fact it is what is perceived as absolutely safe, what is expected to produce the smallest losses, and which therefore can lead to very high bank exposures, which always produce the most dangerous unexpected losses which pose a threat, not only to an individual bank, but to the whole banking system.

And so bank regulators should not require banks to have higher capital to compensate for higher perceived risk, as they do now, but require banks to have a reasonable level of capital in defense of what is not perceived… and since they can not presume to know about the hidden risks of unexpected losses, then they have no other alternative than to set one single capital requirements for all assets, independent of their perceived risks.

To have an idea of how much current risk based capital requirements miss the target, if anything, one could even make an empirical case for setting the capital requirements slightly higher for what is perceived as "absolutely safe" than for what is seen as "risky".   

And that would also eliminate a great source of distortion. The current capital requirements, more perceived risk more capital, less perceived risk less capital, translates into allowing banks to earn much higher risk-adjusted returns on equity on assets deemed as safe, than on assets deemed as risky… and that makes it impossible for banks to perform their function of allocating efficiently bank credit to the real economy.

Basel Committee, Financial Stability Board, know that Your risk-based capital ratios are stopping the banks to finance the risks our future needs to be financed, and only have banks refinancing the safer past. Our young, who now because of your regulations might end up being a lost generation, will hold You all accountable.

As I see it… anyone who allowed banks to leverage 62.5 to 1 on assets, only because these had an AAA rating… or allowed banks to lend to the “infallible sovereigns” against no capital at all, like the Basel Committee allowed for in Basel II, is just not fit to be a regulator. Capisce Mr. Ingves?

PS. Stefan Ingves also states that “The world's largest listed non-financial companies fund their assets around 50:50 with debt and equity. In banking, a more common ratio is 95:5” Let it be clear that 95:5 is 19 to 1 debt to equity… never ever, in the history of banking before the Basel Committee’s risk based capital ratios, have banks remotely been allowed to leverage this much, knowingly.

Saturday, February 22, 2014

Regulators, please, your only problems with banks begin when their risk models stop to function.

Now we read that “Under rules being implemented by the Federal Reserve and the Office of the Comptroller of the Currency, the biggest U.S. banks will use their own models for judging their riskiness.”

Are they nuts? 

Bank regulators should have no problems whatsoever when banks own internal models which determine the “expected losses” function well.

The regulators only serious problems begin when these models do no function well... and “unexpected losses” result.

And so, frankly, it seems utterly absurd to allow for regulations which are based on trusting the bank models to function well.

And in this case, trusting primarily those banks which because of their systemic significance most can hurt if their risk models do not work... is like doubling up on the mistake.

If anything, trust the small banks which, if and when they fail, do not hurt us as much.

Friday, February 7, 2014

“The Risky” those discriminated against by banks, and by regulators, need to have a voice at the Fed

I read that the State banking associations and several other groups sent a letter to President Obama on Tuesday urging the president to nominate a community banker to serve on the Federal Reserve Board of Governors. 

In doing so they write: We offer our request and recommendation in view of our shared desire for economic growth that reaches to all parts of our nation, and in the recognition that community banks are fundamental to achieving that growth.” 

And I entirely support such motion.

But, that said, if we are talking about the need of having a voice at the Fed, then no one needs it more at this injunction, than the medium and small businesses, the entrepreneurs and the start ups.

For a starter this is what they would say:

“We are punished by bankers with smaller loans, higher interest rates and harsher terms because we are perceived as risky from a creditor point of view. And that we understand... that’s life. 

But why must you regulators have to make it even harder for us to get loans at competitive rates by requiring the banks to hold more capital when lending to us than when lending to those of the AAAristocracy? 

We fully understand you must require banks to hold capital, and this primarily to be able to confront unexpected losses. But why would you think that we, we who represent higher expected losses, also represent the risk of higher unexpected losses? Is it not the other way round? Has history not proven sufficiently that the AAAristocracy is the most dangerous source of that kind of unexpected losses that can really shake the system?”

Sunday, February 2, 2014

Will anyone in UK help me file the following complaint against bank regulators through the Financial Conduct Authority?

(As a foreigner not living in the UK, if I filed it, the complaint would probably be ignored)

Below is the link for filing it:

The complaint!

Even though bank capital is primarily needed in order to cover for unexpected losses, regulators have set the capital requirements based on the perceptions about expected losses.

And since the perceptions of expected losses are already cleared for by banks by means of interest rates, size of exposure and other terms, this means that perceptions of expected losses get to be considered twice.

And of course that favors those already favored by being perceived as safe, and punishes those already punished by being perceived as risky.

And of course that makes it impossible for banks to allocate credit efficiently to the real economy, with all the negative consequences that entails... among other to the job prospects of the unemployed youth.

And, to top it up, since the capital requirements are portfolio invariant, which means that these do not consider the dangers caused by excessive exposures to what is perceived as absolutely safe but could turn out to be risky, these do not foment the stability of the banking sector. 

On the contrary, these capital requirements guarantee that in the worst case scenarios, which is when banks encounter that something “absolutely safe” has become “risky”, banks will have too little capital to respond with.

These regulations are therefore destructive and should be changed.