Saturday, December 3, 2016

Must one go on a hunger strike to have the Basel Committee or FSB answer some very basic questions?

Before regulating banks did you ever define their purpose? I know we all want them to be safe but, as John Augustus Shedd said: “A ship in harbor is safe, but that is not what ships are for.” 

By allowing for different capital requirements based on ex ante perceived risks of assets, banks will be able to leverage their equity (and the support given by authorities) differently, which will cause quite different expected risk adjusted returns for different assets, than would have been the case in the absence of this regulation. Were you never concerned about how this would distort the allocation of bank credit to the real economy? 

Since ex ante perceived risk were already considered by bankers when deciding on the amounts of exposures and interest rates, when you decided that the perceived risk was also going to determine capital requirements, you doubled up on perceived risk. Don’t you know that any risk, even if perfectly perceived, causes the wrong actions if excessively considered? 

In the case of larger and more “sophisticated” banks, you allowed these to use their own internal risk models to determine capital requirements. (Something like allowing Volkswagen to calculate their own emissions) Was it not naïve of you to believe banks would not naturally aim for lower capital requirements, in order to increase their expected risk adjusted returns on equity?

What’s perceived as safe can be leveraged into being utterly dangerous, only because of that perception; while what’s perceived as risky is automatically less dangerous, precisely because of that perception. Or as Voltaire said: “May God defend me from my friends, I can defend myself from my enemies”. In this respect can you explain the logic behind your standardized Basel II risk weights of 20% for what is AAA to AA rated, and 150% for what is rated below BB-? 

In the same vein what empirical research did you carry out to determine that what is perceived ex ante as risky has caused major bank crises? I ask because as far as I know these have always been caused by unexpected event, like natural disasters or devaluations, by fraudulent criminal behavior, or by excessive exposures to what ex ante was considered as safe but that ex post turned out to be very risky. 

In other words since bank capital is there for the unexpected is it not dumb to require it based on the expected?

A risk weight of 0% for the sovereign, and 100% for We the People clearly implies you regulators all believe government bureaucrats make better use of bank credit than the private sector. Are you really such statists? Did you never consider that such dramatic rearrangement of economic power needed approval by for instance a Congress or a Parliament… or even a referendum? 

Finally do you really believe that with such risk adverse regulations, layered on top of banker’s own risk aversion, our economies would have developed as they did? Don't you see that banks are no longer financing the riskier future but only refinancing the "safer" present and past? Don't you see this decrees inequality?

PS. FT’s / Financial Times Establishment, notwithstanding my soon 2.500 letters to it on “subprime bank regulations” has also steadfastly refused to help me get answers to these questions.

PS. And here is one evidence of that I have posed my objections during formal consultations by the Basel Committee

PS. And I dreamt I got this letter with their answers!

PS. And I am 100% for the 10% on all assets capital requirement for small banks in the Financial Choice Act. I just hope it was applied to all banks, foremost the biggest, as these need it the most, as we need these to be better capitalized the most.