The World Bank spoke out way too softly on faulty bank regulations, and finance ministers did not read carefully enough.

World Banks' The Global Development Finance 2003 (GDF-2003), “Striving for Stability in Development Finance” had this to say on Basel II, pages 50-52

“The new method of assessing the minimum-capital requirement [proposed by the Basel Committee for Banking Supervision (BCBS)]… will be explicitly linked to indicators of credit quality… The regulatory capital requirements would be significantly higher in the case of non-investment-grade emerging-market borrowers than under Basel I. At the same time, borrowers with a higher credit rating would benefit from a lower cost of capital under Basel II….

A recent study by the OECD (Weder and Wedow 2002) estimates the cost in spreads for lower-rated emerging borrowers to be possibly 200 basis points.”

What did the World Bank say with that?

It said that regulatory capital requirements would distort more than the previous Basel I did, the allocation of bank credit.

What did finance ministers of developing countries do?

They did not protest that as an outrageous odious discrimination of bank lending to countries like theirs that are naturally perceived as more risky.

What did finance ministers of developed countries do?

They did not understand that their own “risky”, the SMEs and entrepreneurs, would be exposed to exactly that same odious discrimination.

I, at that time an Executive Director of the World Bank, mostly representing developing countries, when commenting GDF-2003 formally stated:

“the document does not analyze at all a very fundamental risk for the whole issue of Development Finance, being that the whole regulatory framework coming out of the BCBS might possibly put a lid on development finance, as a result of being more biased in favor of safety of deposits as compared to the need for growth. Even though, in theory, we could agree that there should be no conflict between safety and growth, in practice there might very well be, most specially when the approach taken is by substituting the market with a few fallible credit rating agencies.”

And a couple of weeks later, also formally at the Board of the World Bank I held: “BCBS dictates norms for the banking industry that might be of extreme importance for the world’s economic development. In BCBS’s drive to impose more supervision and reduce vulnerabilities, there is a clear need for an external observer of stature to assure that there is an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth. Once again, the World Bank seems to be the only suitable existing organization to assume such a role."

Now I hear some talking about that the World Bank is becoming irrelevant. Forget it! It could be more relevant than ever… but for that it has to be able to stand up for the risk-taking our children needs for us to take in order for their children to have a future.

PS. Come to think of it. The World Bank has been mum on this regulatory distortion of the allocation of bank credit to the real economy. Why? Does it not even listen to itself?

Financial regulations, if wrong, could destroy the economy of a nation, and is therefore an issue of utmost importance for national security.

Suppose military regulations which implicitly stated that those who avoided taking direct risks when fighting the enemy, for instance by using drones, had much better possibilities to advance in the ranks than those who dared to risk hand to hand combat. Would this not impact negatively, at least in the long term, the strength of the Home of the Brave?

And should bank regulators not have to consider the dangers of introducing distortions in credit allocation, which might weaken the economy and thereby weaken the defense of the nation?

In 1988, the G10, a group which includes United States, decided to introduce risk-weighted capital requirements for banks; where “risk” means credit risk, and “capital” means bank equity. As a consequence, those bank assets with a low risk-weight require banks to hold less equity than those assets with a high risk-weight.

The initial big risk-weight differentiation, in 1992 with Basel I, was that loans to the central governments of the OECD nations had a cero risk-weight, while loans to the private sector carried a 100 percent risk-weight. In 2004, with Basel II, many more risk buckets were added and in the private sector the risk-weights were set from 20 to 150 percent.

And it all sounds like prudent bank regulations… more-risk-more-equity - less-risk-less-equity. But, unfortunately, bank regulators, I pray unwittingly, did not notice that by doing that, they were introducing an extremely dangerous distortion of how bank credit was allocated to the real economy.

It signified that the equity of a bank, to which we have to add the value of the support a society and taxpayers lend the banks, could be leveraged many times more for assets with a low risk weight, than with assets with a high risk-weight. 

And that meant banks could earn much higher risk adjusted returns on equity on assets that carry a low risk-weight than on assets with a high risk-weight.

Just for a starter it meant that regulators effectively instructed banks to allocate more credit to the central government than to the private sector… implying thereby of course that a government bureaucrat has more capacity to allocate financial resources efficiently to the real economy than a private agent, like a SME or an entrepreneur

And anyone who thinks this regulatory risk aversion will not affect the strength of the USA’s economy, has no idea about how the USA got to be strong

And to top it up, it is all for nothing, since all major bank crises have always resulted from too big exposures to something that was perceived as “safe” that turned out risky, and never ever from excessive bank exposures to something perceived as risky.

Really; are the risk weighted bank capital requirements with decreed weights: 0% Federal Government, 100% We the People, in accordance to the US Constitution?

 

@PerKurowski

A message sometime ago to Homeland Security

A letter on the issue of defense in the Washington Post

World, beware of statist and communists dressed up as bank regulators

In July 1988 the Basel Accord (Basel I) approved that banks had to hold 8 percent in capital (equity) when lending to the private sector but that banks were allowed to lend to OECD’s central governments against no capital (equity) at all.

The introduction of such an amazing pro-government bias, I would even call it outright communism, distorted all common sense out of the allocation of bank credit to the real economy. 

And with Basel II, in June 2004, the Basel Committee made it even worse by allying themselves with the private AAArisktocracy, which of course left even more out in the cold, those we most need to have fair access to bank credit, our SMEs and entrepreneurs. 

And now with Basel III, the Basel Committee, with the blessing of the Financial Stability Board, and counting with the collegial silence of the IMF, is increasing regulatory complexity tenfold, and digging us even deeper into the hole.

PS. And, amazingly, Basel I happened while the attention was diverted discussing the supposed pro-private sector bias of the "Neo-Liberal" Washington Consensus.

PS. And even more amazingly... in its many hundred of pages... the Dodd-Frank Act does not even mention the Basel Accord of which US is a signatory or the Basel Committee

PS. Paul Mason just wrote "PostCapitalism". Since pure capitalism clearly ended with the Basel Accord, he must be referring to PostStateCapitalism.

Bank regulators originated and institutionalized a “market imperfection”, causing less equality in opportunities

The OECD has just released: OECD Social, Employment and Migration Working Papers No. 163, titled “Trends in income inequality and its impact on economic growth”, authored by Federico Cingano. On page 9 it states the following:

“In presence of financial market imperfections, implying that the ability to invest of different individuals depends on their income or wealth level. If this is the case, poor individuals may not be able to afford worthwhile investments… In turn, under-investment by the poor implies that aggregate output would be lower than in the case of perfect financial markets (5). We will refer to this view, first formalized by Galor and Zeira (1993, 1998), as the “human capital accumulation” theory. (6)

(5) With perfect financial markets, all individuals would invest in the same (optimal) amount of capital, equalizing the marginal returns of investment to the interest rate. This occurs as complete markets allow poor individuals, whose initial wealth would not allow reaching the optimal amount of investment, to borrow from the rich (infra-marginal gains from trade). If, on the contrary, financial markets are not available, and the returns to individual investment projects are decreasing, under-investment by the poor implies that aggregate output would be lower, a loss which would in general increase in the degree of wealth heterogeneity (see e.g. Benabou, 1996; Aghion et al, 1999).

(6) Aghion and Bolton (1997) and Piketty (1997) explicitly modeled the supply side of the credit market, explaining imperfections based on moral-hazard (e.g. problems of input verifiability) or enforcement problems stemming from contract incompleteness (e.g. due to output verifiability). Moral-hazard would occur, for example, with limited liability (i.e. when a borrower's repayment to his lenders cannot be greater than his wealth); if the probability of success of the project depends on a (costly) effort exerted by the borrower, her incentives to exert efforts would be lower the larger the fraction of externally financed investment. Thus the interest rate on the loan will be an increasing function of its size (i.e. higher for the poorer).”

And that provides me with a new opportunity to try to draw the attention to how bank regulators, during the last couple of decades, have originated and institutionalized a truly odious and discriminatory capital market imperfection.

The Basel Committee for Banking Supervision imposed credit-risk-weighted capital (equity) requirements for banks which are much much lower for assets perceived as “absolutely safe” than for assets perceived as “risky”.

And, of course, what is perceived as “absolutely safe”, correlates much more with wealth than what is perceived as risky.

And, of course, what is perceived as “absolutely safe”, correlates much more with what already exists (history) than with the riskier future.

And that allows banks to make much much higher risk adjusted returns on equity when lending to those perceived as safe (like the "infallible sovereigns", the AAAristocracy and the housing sector) than what they can obtain when financing "the risky".

And, as a consequence, small businesses and entrepreneurs, those creators of jobs that will allow mortgages and utilities to be serviced, have no longer fair access to bank credit.

And, as a consequence banks, no longer finance the future, they mostly refinance the past.

And in short, that is how our economies are stalling, while inequality is growing.

“A ship in harbor is safe, but that is not what ships are for.” John Augustus Shedd, 1850-1926