Questions on bank regulations which experts are not answering... or even discussing

If all bank crisis in history have resulted from excessive exposures to what was perceived as “absolutely safe”, or at least very safe, and none ever, from excessive exposures to what was perceived as "risky"… what is the rationale behind the pillar of current Basel regulations, namely capital requirements for banks which are much lower for what is perceived as "absolutely safe", or at least very safe, than those for what is perceived as “risky”? Does not all empirical evidence suggest instead that the capital requirements should be slightly higher for what is perceived as "absolutely safe" than for what is perceived as "risky"? 

Since perceived risk is already cleared for by banks on the asset side of the balance sheet, by means of interest rates, amount of exposure and other terms, why did the Basel Committee for banking supervision decided banks needed to clear for the same perceived risk, in the liabilities and equity side of their balance sheet, by means of risk-weighted capital requirements? Does this not doom banks to overdose on perceived risk?

Current capital requirements, allow banks to earn a much higher risk-adjusted return on equity when lending to what is “absolutely safe”, “The “Infallible”, and so banks avoid lending to “The Risky”. But since “The Risky” includes for example small businesses and entrepreneurs, and whose access to credit is absolutely indispensable for the real economy to move forward, who is then supposed to finance what is “risky”? Bureaucrats or citizens? Is not taking smart risks on behalf of the society exactly what bankers are supposed to do?

Bank regulations that so much favor “The Infallible”, those already favored by bankers and markets, and so much discriminates against “The Risky”, those already sufficiently disfavored by bankers and markets, can only lead to increase the gap between the haves, the rich, the history, the old, the developed, and the have-nots, the poor, the future, the young, the undeveloped. Is that what you want?

Please, if you are able to extract an answer from the experts that is reasonable, send me a copy of it to

perkurowski@gmail.com

PS. If bank regulators must meddle, why do they not meddle in a more useful way?

Dear Ministers, you who are concerned with the real economy, during World Bank and IMF Spring Meetings 2013, ask your bank regulators for an explanation of the rationale behind capital requirements based on perceived risk.

Even though perceived risks were already cleared for by banks, in their numerator, on the asset side of the balance sheet, by means of interest rates, amount of exposure and other terms, their regulators, the Basel Committee, decided to clear for the same perceived risk, in the banks denominator, the liabilities and equity side of their balance sheet, by means of risk-weighted capital requirements.

And that doomed the banks to overdose on perceived risks, causing the current crisis, characterized by excessive bank exposures to what was supposedly “absolutely safe” while holding very little capital; and hindering the real economy from getting out of the crisis and generating the jobs we need, by discriminating against the bank borrowings of the “risky” economic agents, like medium and small businesses.

And now, soon six years after the crisis detonated, this issue of the distortion produced by the regulator's hand is not even discussed.

Here follows a more detailed explanation:

Current capital requirements for banks are much lower for what is perceived as “absolutely safe” than for what is perceived as “risky”.

And, as a result, banks are allowed to leverage their equity immensely more when lending to “The Infallible” than when lending to “The Risky”.

Just as an example, the banks in Cyprus and Germany, when financing small businesses in Cyprus or Germany could leverage 12.5 to 1 but, when buying bonds of Greece, 62.5 to 1… 50 times more!

And, as a result, banks make immensely higher expected risk-adjusted returns on equity when lending to “The Infallible” than when lending to “The Risky”. 

And, as a result “The Risky” need pay banks much higher risk premiums in order to make up for this regulatory competitive disadvantage. 

And as a result banks head with little capital towards dangerously excessive exposures to what always have caused bank crises, namely to “The Infallible” 

And as a result of this distortion by the regulator's hand, the most important actors on the margins of the real economy, namely “risky” small businesses and entrepreneurs do not have access to bank credit in competitive terms. 

And as a result millions of young people all around the world will never be able to have a job.

And as a result, the all important “risk-free rate” for which the borrowing rates of “infallible sovereigns” normally serves as proxies, does not indicate the “real-risk-free-rate” but a “subsidized risk-free-rate” instead.

And as a result of this odious discrimination the gap between the haves, the old, the history, “The infallible” and the have-nots, the young, the future, “The Risky”, only widens.

In summary our banks, more than de-regulated were misregulated.

And so ministers, please ask the regulators to explain to you the rationale behind the risk-weighted capital requirements.

And please, do not accept as an answer from your bank regulating anti-risk zealots, the “more-risk more-capital, less-risk less-capital, does that not sound logical?” mumbo jumbo, and much less, of course, “so that the banks can earn more return on their equity.

And please do not allow yourself to be distracted by an unpredictable “Black Swan” argument, this crisis was entirely manmade.

And if you are asking yourself “can experts really get it so wrong?” let me quote you George Orwell´s “one has to belong to the intelligentsia to believe things like that: no ordinary man could be such a fool”; or Patrick Moynihan´s "there are some mistakes it takes a Ph.D. to make”; or Axel Oxenstierna´s “An nescis, mi fili, quantilla prudentia mundus regatur?”

Ministers, as an ordinary citizen, I can only remind you of the fact that never would Hollywood, nor Bollywood, allow the same scriptwriters and directors who produced such an extraordinary flop like Basel II, to go ahead with Basel III… something which is now digging us even deeper into the hole, by introducing liquidity requirements for banks that are also much based on ex-ante perceived risks.

But also Ministers, again as an ordinary citizen, I need to ask you. Did you really authorize this little mutual admiration club called the Basel Committee for Banking Supervision to, with so little accountability, impose on the world de facto capital controls which has bank credit flowing massively to “The Infallible” and away from those who ex ante have been deemed to be “The Risky”?

And Ministers from countries rated BB+ or worse, be aware that you too are paying higher interest rates on your sovereign debt than what you would have to pay in the absence of this odious regulatory discrimination.

Am I saying there should be no capital requirements for banks? Absolutely not! And I do believe the basic 8 percent established in Basel II, would be sufficient and reasonable, if applied to all assets, and not diluted by risk-weights into so many close-to-nothing.

And if you absolutely cannot restrain regulators from interfering, and they must use weights to calculate capital requirements, why do you not ask them to, instead of basing these on silly credit ratings, think more in terms of basing these on job creation potential ratings, or environmentally friendly ratings?

I do acknowledge that Andy Haldane, the Executive Director for Financial Stability at the Bank of England, and Thomas Hoenig a director of the FDIC, have begun making some important comments questioning the wisdom of Basel’s current regulatory paradigm. Nevertheless, since the mistakes are so huge that even mentioning these could seem impolite towards those they could regard as colleagues, and so I dare say Ministers they could be in dire need of more of your direct and urgent support.

Let me also take this opportunity to ask the World Bank and the IMF:

Why does you research department not run a regression between all what had low capital requirements for banks because it was perceived as “absolutely safe”, and all bank exposures which caused the current crises?

Do you know of any major bank crisis that has resulted from excessive bank exposures to what was perceived as risky and not to what was erroneously perceived to be safe?

If banks are given such extraordinary incentives to finance what is “absolutely safe” and to stay away from what is “risky”, who do you suggest should finance “The Risky”, government bureaucrats, widows and orphans?

World Bank, do you really not understand why in churches of some developed countries psalms praying “God make us daring!” are sung? Do you really think development is a risk-free affair?

What will it take to end poverty? #ittakes a lot of risk-taking, of all sort, often even dumb; and of staying away from stupidly excessive regulatory prudence... in other words the world, especially its poor, is in dire need of more reasoned audacity.

IMF, the current capital requirements generate regulatory subsidies to the “infallible sovereign”, and which are mostly paid by “The Risky” when accessing bank credit. If that had been calculated and made known, then perhaps the current crisis would never have happened. I therefore ask your “Revitalizing the Fiscal Transparency Agenda” to include an effort to identify and value these type of quite obscure regulatory favors and disfavors.

Mme Lagarde, in a Civil Society Town Hall Meeting at the IMF, September 2011 I asked whether you did not think it was important for the regulators to define the purpose of the banks before regulating, and you agreed. What has happened with that? We now ask of central banks to include job creation as one of their objectives, but why do we not ask that of our banks? 

And who am I?

Per Kurowski, someone who in 1999 in an Op-Ed wrote “The possible Big Bang that scares me the most is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause its collapse” 

Someone who had the honor of serving as an Executive Director in the World Bank for two brief years, 2002-2004, who then loudly protested the introduction in Basel II of the systemic risk of credit ratings, and who, in October 2004, in a written statement at the Board warned: “I believe that much of the world’s financial markets are currently being dangerously overstretched, through an exaggerated reliance on intrinsically weak financial models, based on very short series of statistical evidence and very doubtful volatility assumptions”. 

In other words, I am someone who suffers from the misfortune of having been unbecomingly right.

And if by any chance any bank regulator comes up with a rational explanation for their concoctions, please send it to me, and, if they prove to be correct, I would, as they say, have to eat my hat and much humble pie.

Am I too aggressive here? I guess so. But it is hard not to be, after so many years of polite criticism has not even brought out the issue of how these capital requirements distort into the discussions. How many times have you heard that argument discussed?

And for crying out loud, these regulators are endangering the world of my grandchildren, and no loving grandfather should take that lightly.

perkurowski@gmail.com