Saturday, March 29, 2014

If the Basel Committee had had anything to do with it we, the Western World, would not be cycling.

If the largest of the apprehensions of our mother and of our grandmother about cycling had determined our bicycling, we would still be cycling.

But, if the apprehensions of our mother and our grandmother about cycling had been added up, we would not been cycling.

And that is another way to explain how, when our bankers apprehensions about lending to “the risky”, those reflected in higher interest rates, smaller loans and tighter conditions, got added up to our bank regulator’s apprehensions about risks, those reflected in the capital requirements... it all resulted in our banks not lending to “the risky”, like to the medium and small businesses, entrepreneurs and start-ups.

We need to stress test our bank regulators too! How? Analyze what assets banks do now not have on their balance sheets... thanks to the regulators' interfering and arrogantly playing risk managers for the world

God save us from these regulators.... God please make us daring!

Tuesday, March 25, 2014

CFPB concern yourselves more with why Payday borrowers need to borrow, than with the conditions and the rates they borrow at

Yes, the Payday borrowers borrow too expensively, but… the other side of that coin is that medium and small businesses, entrepreneurs and startups, those who most could give the Payday borrowers an opportunity of not having to borrow, borrow less, and at higher risk-adjusted rates, than the “infallible sovereigns” and the AAAristocracy… thanks to the colleagues of CFPB… the regulators 

I just wish that CFPB would dare to look into the odious discrimination and odious distortion in the allocation of bank credit to the real economy that the risk-based capital requirements for banks cause.

Thursday, March 20, 2014

The world needs regular jobs, not just jobs for bank regulators.

With their distortions of the allocation of bank credit to the real economy, which their Basel II risk-based capital requirements cause, has turned the regulators into the worst enemy of the creation of the jobs our young ones need, in order not to become a lost generation.

But it is just getting worse. Every clause I read of Basel III or Dodd Frank Act, or all thereto referenced regulations, ticks off in my mind a calculation of how many more jobs will this mean for regulators and aspiring regulators, and how many more opportunities of regular jobs will be lost because of it. 

And the ratio that keeps popping up in my mind is about 10.000 regular jobs lost for each job created for a regulator or for a bank regulation consultant.

Wednesday, March 19, 2014

The tyranny of [bank regulatory] experts. The forgotten rights of “the risky” to access bank credit.

Bank regulatory experts in the Basel Committee, and the Financial Stability Board, with their risk based capital requirements, by allowing banks to earn much higher risk adjusted returns on equity when lending to “The Infallible”, are blocking the access of “The Risky” to bank credit.

With that these tyrants are killing our economies… Who authorized them to such odious and senseless discrimination? Did we not become what we are because of risk taking? 

World Bank, IMF what’s wrong with you? You must know this is not right.

Note: Inspired by William Easterly’s “The Tyranny of experts

Saturday, March 15, 2014

European Union, ask the Basel Committee about regulatory distortions in the allocation of bank credit to the real economy

Regulation (EU) No 575/2013 dictated by The European Parliament concerning Prudential Requirements for Credit Institutions and Investment Firms establishes:

“44. Small and medium-sized enterprises (SMEs) are one of the pillars of the Union economy given their fundamental role in creating economic growth and providing employment. The recovery and future growth of the Union economy depends largely on the availability of capital and funding to SMEs established in the Union to carry out the necessary investments to adopt new technologies and equipment to increase their competitiveness. The limited amount of alternative sources of funding has made SMEs established in the Union even more sensitive to the impact of the banking crisis. It is therefore important to fill the existing funding gap for SMEs and ensure an appropriate flow of bank credit to SMEs in the current context. Capital charges for exposures to SMEs should be reduced through the application of a supporting factor equal to 0,7619 to allow credit institutions to increase lending to SMEs. To achieve this objective, credit institutions should effectively use the capital relief produced through the application of the supporting factor for the exclusive purpose of providing an adequate flow of credit to SMEs established in the Union.”

Favoring bank lending to the SMEs this way, implies that the European Parliament admits that the risk weighted capital requirements for banks distort the allocation of bank credit to the real economy. The question then is why has not the European Union, the European Parliament, formally asked the Basel Committee on Banking Supervision, about the implications of such distortions. Is that issue not of utmost importance? Have they, when regulating, not given any considerations to the purpose of banks?

And by the way where did the European Parliament get 0,7619 from? And by the way that still equates to an effective risk weight that is 3 times higher than that applicable to any AAA rated company which might be taking a bank loan only to repurchase its own shares.

And if this is the way to go would the European Union consider to design a similar “supporting factor” for any bank lending which promotes the sustainability of planet earth?

Wednesday, March 12, 2014

Basel III, risk based capital requirements, leverage ratio, distortions, and “The Drowning Pool”

I have for years seriously criticized the distortions in the allocation of bank credit to the real economy that the risk based capital requirements of Basel II produce. And now I am often being answered that these distortions have been in much removed because of the introduction in Basel III of the 3 percent leverage ratio, that which is applied on all assets without any risk weighing.

Unfortunately the truth is that could make the distortions even worse, and equally unfortunate, the why of it, is not so easy to explain… and so here I give it another go.

Have you seen “The Drowning Pool”, where Paul Newman and Gail Strickland are locked in a hydrotherapy room, with the water rising to the ceiling? Well think of the capital requirements as the hydrotherapy room, and the leverage ratio as the water level. 

In Basel II, there was a lot of room for banks maneuvering around the risk-weights but, in Basel III, by means of the water level having risen, there is now less room-oxygen for the banks to breathe… and so the more the distortion.

And so Basel III by making the search for breathing space harder will therefore make banks even more loath to give credit to “the risky” those which regulators decided consume more oxygen-capital. Get it?


And of course that is not helped by the fact that, with the introduction of liquidity requirements which is also based on ex ante perceptions of risks, new sources of distortion are being introduced.

Monday, March 10, 2014

We must stop bank regulators from increasing the risks of our banking system… they´ve done enough damage as is.

The real risks for a bank regulator, and ours as well, has nothing to do with one or even a couple of banks going busts; it has all to do with the whole banking system melting down, or not doing well what it is supposed to do, namely to allocate bank credit efficiently in the real economy.

And that translates into that the risk of a bank regulator has little to do with the type of assets a bank holds, and a lot to do with the capacity of bankers to pick the assets the banks should hold.

But current bank regulators, with their risk based capital requirements, allow banks to hold extremely large amounts of assets against extremely little capital only because bankers, and sometimes regulators themselves, say they perceive these as being “absolutely safe”. And that allows banks to earn much higher risk adjusted returns on equity when lending to for instance the “infallible sovereigns”, the housing sector and the AAAristocracy, than when lending to the “risky” medium and small businesses, entrepreneurs and start-ups.

And that means, effectively, that regulators are assisting banks to create that kind of excessive exposures to what is perceived as “absolutely safe” which has been the source of all bank system crisis when these, surprisingly, turn out to be risky. And all this is worsened by the fact that when now one of these safe exposures blows up, banks stand there holding extremely little capital in defense.

And that also means, effectively, that our banking sector is not allocating sufficient bank credit to those in the real economy who are in most need of it.

And so to sum it up: current regulators are betting more than ever our whole banking system on the bankers being able to pick the right assets… while at the same time distorting the picking of those assets. Sheer lunacy! We need to get rid of them urgently.