Basel Committee, dare subject your risk weighted capital requirements for banks to a referendum… or at least dare answer my objections.
You hold: More ex ante perceived credit risk more capital, less ex ante perceived credit risk less capital.
I hold: It is not the ex ante perceptions of risk that matter, it is only the ex-post realities that do. And in this respect, what is perceived as risky is in fact usually safer than what is perceived as safe.
I hold: Bank capital should be there against unexpected losses not against expected credit risk losses.
I hold you never analyzed what causes bank crises you just analyzed what problems bank borrowers could face, and that far from being the same.
I hold: To allow banks to leverage differently their equity and the support society and taxpayers give these differently, based on ex ante perceived credit risks; which allows banks to earn higher risk adjusted returns on equity on what is perceived as safe than on what is perceived as risky, distorts dramatically the allocation of bank credit to the real economy.
I hold like John A Shedd: “A ship in harbor is safe, but that is not what ships are for.”
I hold like Voltaire: “May God defend me from my friends [AAA rated]: I can defend myself from my enemies [BB- rated]”
I hold that because of the dumb risk aversion in your regulations, banks no longer finance the riskier future our children needs to be financed, they only refinance the, for the short-time being, safer past.
I hold that when you set the risk weights of sovereigns at zero percent, but that of the citizens at 100 percent, you introduced statism through the back door. In fact Sovereign = 0% and We The People = 100% sounds sort of like a regulatory Ponzi scheme.
To sum up, Basel Committee, I hold you have clearly evidenced you have no idea of what you are doing.
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