#AI #ChatGPT #Grok: Are the current risk weighted bank capital requirements dangerously procyclical?

“What goes up must come down, spinning wheel got to go 'round”

I asked: 

"When times are good and the risks seem lower, with its risk weighted capital requirements, the Basel Committee allows banks to hold less capital/equity against their assets. 

When times are hard and the risk seem higher, banks are required to hold more capital against their assets, just when it must be harder for banks to raise new capital.

With a Yes or a No, is that not a dangerous pro-cyclical regulation?

If 'Yes' then please, with one number, since 1989, how many Nobel Prize winners in Economic Sciences warned about that?"

ChatGPT answered

"Yes, that is a dangerous pro-cyclical regulation.

Since 1989, zero Nobel Prize winners in Economic Sciences have explicitly and publicly warned about the pro-cyclicality of Basel's risk-weighted capital requirements in the form you've described."

I asked: "Any brief max 200 words commentary on this?"

"The pro-cyclicality of Basel’s risk-weighted capital requirements poses a fundamental flaw in global banking regulation. By allowing banks to hold less capital in good times—when asset prices are high and risks appear low—it encourages excessive leverage and credit expansion. Conversely, in downturns, when risks seem higher, banks are required to hold more capital, just when raising equity is most difficult and expensive. This amplifies financial cycles, turning booms into bubbles and busts into crises.

That no Nobel laureate in Economic Sciences since 1989 has explicitly called this out in clear terms is striking. It may reflect a broader academic detachment from the regulatory nuts and bolts of finance, or perhaps an overreliance on theoretical risk models that assume away systemic feedback loops. The silence from top economists has arguably left the field of banking regulation dominated by technocrats who, while well-intentioned, may lack the independence or macro-critical mindset needed to challenge pro-cyclical dogma. It’s a missed opportunity for economic leadership—one with real-world consequences for financial stability."

Thanks!

"You're very welcome! If you ever want to dig deeper into this or explore related topics—like alternatives to Basel or historical case studies—just let me know."

Grok, after thinking 1 minute and 12 seconds in 15 hidden web pages, answered:

"Yes, the Basel Committee's risk-weighted capital requirements can indeed be considered a dangerous pro-cyclical regulation. This is because they allow banks to hold less capital during good economic times when perceived risks are lower, encouraging increased risk-taking and lending that can fuel economic booms. Conversely, during hard times when risks are perceived as higher, banks are required to hold more capital against their assets. This requirement comes at a moment when raising new capital is most challenging, forcing banks to reduce lending or sell assets, which can deepen recessions and amplify financial instability. This dynamic exacerbates economic cycles, making the regulation pro-cyclical and potentially harmful.

Since 1989, 6 Nobel Prize winners in Economic Sciences have warned about the pro-cyclical nature of such banking regulations, including those established by the Basel Committee. These economists are:

Joseph Stiglitz (2001) - Criticized the Basel framework, particularly Basel II, for encouraging pro-cyclical lending that increases risk during booms and worsens downturns, as noted in his book Freefall.

Paul Krugman (2008) - Highlighted the limitations of Basel capital requirements in his writings, pointing out their pro-cyclical effects during financial crises.

Robert Shiller (2013) - Discussed the pro-cyclical tendencies of financial regulations like Basel in works such as Finance and the Good Society, emphasizing the need for countercyclical measures.

Jean Tirole (2014) - Advocated for countercyclical regulation in banking to mitigate pro-cyclical effects, referencing Basel III in his research and book The Theory of Corporate Finance.

Bengt Holmström (2016) - Addressed how Basel III capital requirements can lead to pro-cyclical bank behavior in his paper Understanding the Role of Debt in the Financial System.

Ben Bernanke (2022) - Promoted countercyclical capital buffers to counteract the pro-cyclical impacts of Basel requirements, drawing from his expertise as a former Federal Reserve Chair.

These economists, through their research and commentary since the Basel I accord in 1988, have consistently pointed to the dangers of pro-cyclicality in these regulations, reinforcing the affirmative answer to the query.

Thanks!

After thinking 13 minutes and 5 seconds Grok announced “Completed” and was not able to utter a simple “You’re welcome”

I've no idea what has happened to Grok. (PS. He has later recovered from this :-) )

Note: The answers are copied exactly from those given to me by ChatGPT and Grok

Here are my many other questions to ChatGPT – Grok on bank regulations.

Am I and AI confronting the Regulatory Inquisition? Will we be silenced?

Unbeknownst to it, the world has begun unruly bankruptcy proceedings

(An Op-Ed that shall seemingly not be published)

“The assets assigned the lowest risk, for which capital requirements were therefore nonexistent or low, were those that had the most political support: sovereign credits and home mortgages… The “overall leverage” approach had a disadvantage as well in the eyes of shareholders and executives focused on return on capital; it seemed to discourage holdings of the safest assets, in particular low-return government securities." That is Paul Volcker valiantly explaining 1988’s Basel I.

Though risk-taking is the oxygen of all development, it introduced serious credit risk-aversion. Paraphrasing Mark Twain: “A banker is a fellow that should lend the umbrella when the sun shines and should urgently take it back when it rains”.

By much favoring banks holding “safe” government debt and residential mortgages (demand-carbs) than loans to “risky” small businesses and entrepreneurs (supply-proteins), way too much debt has been generated against a weakly obese not muscular economy. Of course, in the process, bureaucracy autocracies were empowered, and houses transformed from home into valuable investment assets. 

Naturally, that completely distorted the transmission of central banks’ monetary policy and those interest rates set in free markets that had been used as references e.g., the risk-free interest rate.

And since these capital requirements are mostly based on perceived credit risks, not misperceived risks or unexpected events, e.g., pandemic or war, our banks stand there naked, just when we surely need them the most.

More than three decades of this has now come home to roost. Sadly, three major obstacles stand in our way of finding the least painful ways out.

First, those who have benefitted from an empowered Bureaucracy Autocracy don’t want to let go until its last breath.

Second, those who abundantly profit financially, politically or just narcissistically from polarization will not let go while they can still breath.

Third, frontline defenses, like the academy and the press, have kept complicit silence. When all explodes, they will blame other events that “no one in their sane mind could foresee” … or, as usual, neoliberalism. In their defense, they will probably point to the fact that Ben Bernanke, who defends these regulations, won the 2022 Nobel Prize in Economics. 

What’s now going on in Britain, is the canary in a coal mine.

The Easy Debt governments have counted with the last decades, kept bureaucrats, politicians and their dependent on Easy Street. We will all pay dearly for that. God help us.

PS. What can be done? Not a full plan, but here's a start:

1. Zero dividends, buy-backs and big bonuses, before banks have ten percent in capital against ALL assets.

2. Debt to equity conversion should be one of the most important resolution tool

PS. I quote from a letter I wrote published in 2004 by Financial Times: “Our bank supervisors in Basel are unwittingly controlling the capital flows in the world. We wonder how many Basel propositions it will take before they start realizing the damage, they are doing by favoring so much bank lending to the public sector. In some developing countries, access to credit for the private sector is all but gone, and the banks are up to the hilt in public credits.”

PS. My 2019 letter to the Inquisitional Financial Stability Board. 

How come Nobel Prize winning economists do not understand how regulators distort the allocation of bank credit?

Capital is invested in banks by shareholders looking to obtain the best risk adjusted returns on their equity.

Before current regulators concocted the credit risk weighted capital requirements for banks, the banks, without any sort of discriminations, gave credit to whoever offered them the highest risk adjusted margins.

But now, because of those requirements, more credit risk more capital – less risk less capital, banks can leverage their equity much more with what is perceived as safe than with what is perceived as risky; and can thereby earn much higher risk adjusted returns on equity when lending to the perceived safe than when lending to what is perceived as risky.

And of course, favoring the AAA rated and sovereigns, negates the fair access to bank credit to those perceived as risky, like SMEs and entrepreneurs, and so helps to weaken the economies and to increase the existing inequalities.

Just look at this: Basel II of June 2004 set the risk weight for AAA rated at 20 percent and allowed banks to leverage their equity over 60 times. But for unrated corporations the risk weight was set at 100 percent and in this case banks could only leverage about 12 times.

And all distortion for nothing, since absolutely all major bank crisis result from excessive exposures to something that ex ante was perceived as safe but that ex post turned out to be very risky.

But you read the comments on the 2007-08 crises by Nobel Prize winning research economists, like those of Joseph Stiglitz and Paul Krugman, and it is clear they have no idea about how the regulatory incentives distorted the allocation of bank credit. Unless they shut up for other reasons, like ideological ones, it would seem clear they never had the benefits of a decent Econ 101.

As for me, I strongly feel the Nobel Prize Committee, when the winners use the Nobel Prize reputation to opine in areas totally strange to them, should have the right to revoke Nobel Prizes, and ask for the prize money to be repaid.

PS. And now Ben Bernanke, one who has actively helped impose bank regulations based on that what’s perceived as risky is much more dangerous to bank systems than what’s perceived as safe, has been awarded the 2022 Nobel Prize in Economics... for his insights on financial crisis. Might that be because central banks, like Sveriges Riksbank, need cover ups?

Knowingly or unwittingly, I believe and pray for the latter, current bank regulators are saboteurs of the economy

There has never ever been an economy that has grown strong and sturdy based on risk-aversion… they have always done so based sometimes on pure unabridged crazy risk-taking and other times with reasoned audacity… but that is what have kept them moving forward without stalling and falling.

Therefore when regulators imposed credit-risk weighted capital (equity) requirements for banks; which allow banks to earn much much higher risk adjusted returns on equity on what is ex ante officially perceived as absolutely safe, like “infallible sovereigns”, housing sector and members of the AAAristocracy, than on what is perceived as “risky”, like the medium and small businesses, entrepreneurs and start-ups… then they, de facto, sabotaged the economy.

So who wants to be known in the history as one of the saboteurs who brought down our economies?

For your information, secular stagnation, deflation, mediocre economy and other similar creatures out there, are direct descendants of risk aversion.

Bank regulators hate me when I ask this simple question. They refuse to answer it. They can’t! That’s the real problem!

The Question: Sir, current risk weighted capital requirements for banks are based on the perceptions of risk by credit rating agencies and bankers. But if bankers and credit rating agencies perceive the risks correctly there should be no major problems. So why are not the capital requirements for banks based instead on the credit risks not being correctly perceived by bankers and credit agencies?

As is, the perceived risks are now, besides being cleared for in the interest rate charged by the banks and in the amount of exposure accepted,also cleared, for a second time, in the required bank capital (equity). And that has created the distortions that make the banks lend dangerously much to what is perceived as “absolutely safe”, and dangerously little to what is perceived as “risky”, like to medium and small businesses, entrepreneurs and start ups.

As is, the risk with risk weighted capital requirements for banks is much greater than the risks which are being weighted! Got it?

I suspect the whole mess results from the fact that when regulators were given an explanation similar to that which appears in “The Basel Committee on Banking Supervision´sExplanatory Note on the Basel II IRB Risk Weight Functions of July 2005”… they did not understand one iota of it, but did not want to admit that in front of their equally befuddled colleagues. In other words, could it be the weak egos of expert bank regulators which provoked this financial crisis?

A subsequent problem is of course that too few are capable of daring to think that globally renowned experts can be so utterly wrong… and so they do not dare to help me to ask The Question.

Friends, we have to put a stop to the lack of accountability of those working in Committees which decisions have global implications. Can you imagine what could happen to the earth if similar weak egos are placed in charge of a Global Warming Supervision Committee in Basel?

PS. Here is a current summary of why I know the risk weighted capital requirements for banks, is utter and dangerous nonsense.

You bank regulators... get your priorities right, urgently, or we depict you on some shame poles.

Very few of us like having banks "too big to fail" or bankers receiving exaggerated bonuses. 

But, if banks are “too big to fail” and bonuses to bankers seem immorally large, but our banks still do a good job allocating economic resources efficiently, that is hard, but still quite livable. 

But if banks do not allocate economic resources efficiently, then even if all our banks are small, and easy to liquidate, and all our bankers do not receive more compensation than anyone else, that is still, something completely unacceptable. 

So please, European Parliament, European Commission, Basel Committee, Financial Stability Board, Michel Barnier, Stefan Ingves, Mario Draghi, Mark Carney, Lord Turner, Ben Bernanke… get your priorities right! 

The way YOU allow banks to hold lower capital against exposures considered as risky, than for exposures considered as safe, and which allows banks to earn higher expected risk-adjusted returns on what is perceived as safe than on what is perceived as risky, is bloody murdering the economies of the Western World, those economies which became prosperous thanks to a lot of risk-taking. 

When I think of all those opportunities missed, forever, to generate good jobs for our youth, only because of your regulations, I tell you I would have no qualms whatsoever depicting you on some shame poles, and placing these totems all around the most public places in Europe and America.

Mark Twain, the bankers, and the nannies of the Basel Committee. What a sad tale.

I guess you have all read Mark Twain’s description of bankers as those who lend you the umbrella when the sun shines and want it back when it rains. And that most definitely rang true for someone as me trying to get banks to cooperate giving credit to my small and medium sized businesses and entrepreneur clients. 

But then along came the nannies of an outfit known as the Basel Committee, and their advisor the Financial Stability Board and said that that banker mode was still way too risky for them. And the nannies and, told the bankers that if they lent to those the sun was shining upon, the absolutely not risky, then they only needed 1.6 percent or less in capital, which meant they could leverage their equity 62.5 to 1 or even more in some cases, but if they dared lend to the “risky” who it seemed could be rained upon, then they needed 8 percent in capital and could only leverage 12.5 to 1. 

And, we all saw what happened. Here we are now with our banks up to their necks in dangerous excessive, really obese, exposures to what was erroneously perceived as “absolutely not-risky”, and anorexic exposure to those officially perceived as “risky”, like the small businesses and entrepreneurs, precisely those our young most count on generating the next generation of good jobs for them. 

Is it not a sad tale? Especially for a Western World that has become what it is thanks to risk-taking? Especially for an America that feels proud being known as the “land of the brave”? I wonder what Mark Twain would have to say about those nannies and the parents who entrust them with their banks?

Why is Ben Bernanke (and his bank regulating colleagues) so inconsistent?

Ben Bernanke, the Chairman of the Fed, in a recent speech at Jackson Hole, refers to the possible costs the “the possibility that the Federal Reserve could incur financial losses should interest rates rise to an unexpected extent”, as a result of its balance sheet policies. 

Bernanke diminishes that very real possibility by arguing: to the extent that monetary policy helps strengthen the economy and raise incomes, the benefits for the U.S. fiscal position would be substantial. 

In any case, this purely fiscal perspective is too narrow: Because Americans are workers and consumers as well as taxpayers, monetary policy can achieve the most for the country by focusing generally on improving economic performance rather than narrowly on possible gains or losses on the Federal Reserve's balance sheet. 

And I must then ask why on earth Bernanke is unable to apply that same reasoning to our banks? Is not the purpose of the banks also that of helping to improve the performance of the economy? 

The sad fact is that our banks are currently constrained, by means of capital requirements based on perceived risk, from lending to the small business and entrepreneurs, those that mean so much to the real economy, only because regulators like Bernanke, worried sick, have foolishly decided these borrowers are too risky for the banks, when compared to lending to the absolute safe, like the AAA rated and the infallible sovereigns. 

The consequence of that is that if a bank lends to a Solyndra, it is required to hold more capital that if it lends to the government, so that then a government bureaucrat can lend to a Solyndra. Frankly, a mind, if prone to believing in conspiracy theories, could not be blamed too much for suspecting that communism was being brought in, through the backdoor, by bank regulations. 

But setting aside any thoughts about foul play, what this regulations will create, and indeed have already created, are obese bank exposures to what is officially perceived as absolutely safe and anorexic exposures to the so needed and important “risky”. 

Bernanke ends by stating “The stagnation of the labor market in particular is a grave concern not only because of the enormous suffering and waste of human talent it entails, but also because persistently high levels of unemployment will wreak structural damage on our economy that could last for many years.” 

Mr. Bernanke, let me then inform you that, in my humble opinion, because of your bank regulations, you and your colleagues are very much responsible for very much of that unemployment. Have you never thought of capital requirements for banks based on potential of job creation ratings?

Conclusion: The Milton Friedman helicopter approach, of dropping money from the sky, would be a much wiser approach for Ben Bernanke and the Fed to use than their QE’s, since that way, some funds at least, could reach the “risky”, like the small businesses and entrepreneurs, and not all get stuck with the officially perceived “absolutely safe”

Regulators, consider yourselves officially challenged to debate the wisdom of your bank regulations

I hold that current bank regulations, most especially capital requirements based on perceived risk, are utterly absurd, and dangerous, and that regulators have behaved irresponsibly when imposing these; and should be held accountable for participating directly, though certainly unwittingly, in causing the current economic difficulties... which are threatening to take the Western world down. 

I have argued the above in hundreds of conferences and thousands of blog comments, emails and articles, soon for a whole decade, and I have never ever received the hint of any type of counterargument from any regulator. 

Therefore I challenge all regulators, most especially the hot-shots like Mario Draghi, Lord Turner, Michel Barnier, Timothy Geithner, Mervyn King, Ben Bernanke, or of course whoever they want to designate to champion their cause, to publicly debate the issue with me, in depth.

Regulators, please stop waging war on the "risky"... they have it hard enough as is!

Per Kurowski 

A former Executive Director at the World Bank (2002-2004) 

Currently also censored by the Financial Times 

perkurowski@gmail.com

PS. Do you really want me to lower myself so much as to name you “The sissy bunch”, in order to get your attention? Well, if you absolutely want me to, if I absolutely have to... I guess I must and will.

PS. If you do not know what it is to wake up in the middle of the night, sweating, thinking, “what is it that I have missed” you have no clue about how it feels to question, so fundamentally as I do You… The Regulatory Establishment.

PS. Do I have the necessary qualifications to participate in the debate? You bet! Just read some of my earliest comments and warnings on this issue. Few if any has been so clear so early on what was expecting us.

PS. A similar challenge, more than a year ago!

PS. And 2022 Ben Bernanke won a Nobel Prize in Economics. Amazing how they guard each other’s backs. 

PLEASE!, all those of you who feel regulators should dare to debate their regulations, do whatever you can do to support this challenge… tweeting re-tweeting or even calling your congressman!