Yes, Basel III has to be thrown out the window, in its entirety

Andrew Haldane, Bank of England's executive director for financial stability said in a speech during the 2012 Jackson Hole meetings, "less may be more" when it comes to financial regulation, and called for a "de-layering" of the Basel III accord to focus more on simpler gauges of bank stability. 

And he is absolutely right! By accepting to engage banks through complex regulations, the regulators have acted less as regulators and more as risk-managers… which does not make any sense, since a regulator’s prime responsibility is to prepare itself for when risk-management fails.

But there are of course many more reasons to throw Basel III, and the Basel Committee regulators too, out the window.

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 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”

My message to American conservatives- republicans and liberal-democrats, as a foreigner that needs America to do well

If you believe the best days are in front of you, you do not discriminate against risky risk-takers. 

If you believe the best days are behind you, of course you discriminate against anything that seems risky. 

If you now believe that American exceptionalism is to be found where it is safe, where there is no risk, you will lose whatever exceptionalism you've got.

Courage to self-correct begins by throwing out those inducing cowardness.

Ask your bank regulators to explain themselves… ask them why they discriminate against small businesses and entrepreneurs when it comes to access to bank credit?

Support my call for the bank regulators to debate this issue: 

http://subprimeregulations.blogspot.com/2012/08/regulators-consider-yourselves.html

What are the thickheaded bank regulators smoking?

It is truly mindboggling to hear so much about job creation, without a single word uttered against how bank regulators discriminate against our prime job creators, the small businesses and entrepreneurs… only on account of these being perceived as “risky”.

What are they smoking... might they be talking about jobs on Mars?

Our current bank regulators seem incapable of understanding that when they allow the banks the goody of being able to leverage their capital more if lending to the “not-risky” than when lending to the “risky”, they are effectively discriminating against the “risky” small businesses and entrepreneurs, precisely those we most need to get into action in order to create the next generation of jobs. 

Honestly, how thickheaded can we allow them to be?

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!

Universities, standardized tests, tuition fees, banks, credit ratings, capital requirements

What if someone suggested that the tuition fees of universities should bear direct relation with the results of standardized tests? The better the results, the much lower the fees, the lower the results the much higher the fees. Sounds reasonable eh? 

That is, until sometime questions if those standardized tests really measure the diversity of capabilities we want to be present at our universities, because just the fact that already so much of the current selection process is based on these standardized tests that might be bad enough. 

In terms of bank regulations, the credit ratings, the risk perceptions, are the equivalent to those standardized tests. If those ratings are not good, borrowers will already need to pay higher interest rates, will get smaller loans and on stricter terms and so, to also have these risk perceptions count for setting the capital requirements might risk excluding some risky borrowers who could truly benefit the economy. 

And that is one of the many reasons I am so opposed to those utterly silly capital requirements for banks based on perceived risk and which by the way, in terms of the university, do not even guarantee that between those with excellent results in the standardized tests, there are not some really rotten apples, who will spoil it all.

I am truly concerned about the future of the Western world

Regulators, on their own initiative, instructed banks, by means of capital requirements based on perceived risk, to stay away, more than usual, from what was perceived as “risky” like the small business and the entrepreneurs, and embrace, more than usual, what was perceived as “not-risky”, like the triple A-rated or the “infallible” sovereigns. The fact, that this does not raise any eyebrows, bodes badly for a Western world, which became what it is thanks to risk-taking. 

If we do not rid ourselves of these dumb overly nanny regulators, the Western world is doomed to perish in some dangerously overpopulated absolutely safe-haven.

Mr. Bank Regulator. Please explain yourself!

In banking (as with most in life) with respect to perceived risks, there are only four possibilities: 

Risky/risky: What was perceived as risky turns out to be risky. Because of the higher interest rates usually charged to those perceived as risky, which serves as a shield, the harsher terms, and the lower bank exposures that follow, this quadrangle has never ever been the source of any major bank disaster. 

Risky/not-risky: What was perceived as risky turn out not to be risky. This can only be of course, a source of good news. 

Not-risky/not-risky: What was perceived as not-risky turn out not to be not-risky. In other words, all as expected. 

Not-risky/risky: What was perceived as not risky, turned out to be risky. This is of course the only source of all major bank crises, namely when major bank exposures gone sour. 

But, the current “pillar” of bank regulations, is capital requirement for banks which allow for much less bank capital when lending in the danger area of the perceived “not-risky”… and that does not seem too smart. 

Not only will the increased possibilities of leveraging bank equity attract too much bank interest in lending to the “not-risky”, but also, when things go sour, the banks will stand there naked, with little or no capital. And it also creates a regulatory disincentive for banks to lend to the safe area of the perceived as risky… and which by the way includes the small businesses and entrepreneurs we so much need to have access to bank credit. 

Indeed that regulation sounds very dumb, which leads me having to consider you, as a bank regulator, to be very dumb. I have for almost a decade now tried to get an explanation from you, but you have consistently refused to do so. You have not even acknowledged the arguments. And so, here is a new opportunity for you to explain yourself. 

Let me assure you that I would love for you to be able to convince me that, with your regulations, you are not castrating our banks, that important channel by which a risk adverse society takes the risks it needs for it to take, without making these safer, but in fact even endangering these. 

What’s my problem? I tell you! If you would run a regression between all the obese bank exposures that have lately gone bad, and the extremely low capital requirements allowed banks for holding these assets, one should conclude that your dumb regulations fundamentally caused this crisis. And, for that, you need to be held accountable, most especially when you seem quite unwittingly to be digging our economies even deeper in the hole. 

Sincerely 

Per Kurowski 

Two whys on bank regulations

How can I, as an ordinary citizen, obtain a decent return on my savings when investing in safe securities, having to compete with banks who can leverage their equity more that 60 to 1 when they do so?

How can I, as an ordinary small businesses or entrepreneur, get a decent interest rate on my bank loans, when banks can leverage their equity so much more when lending to those officially perceived as not-risky? 

It is so unfair! Who are these bank regulators? Who invested them with so much power?

You will not get the jobs you need while bank regulators discriminate against the safe perceived as risky.

Current capital requirements for banks are lower when these lend to those officially perceived as not-risky and that amounts to an outright discrimination of those officially perceived as “risky”, the small businesses and entrepreneurs. As a consequence, these safe-risky, have to pay much higher interest rates and get smaller loans on tougher terms than they would have had without this regulatory distortion. It is not right for this to be happening in a land that prides itself to be brave, and much less will it help America (or Europe for that matter) to get the jobs it needs. 

Stop it! Start working immediately for one and the same capital requirement for banks on any type of assets, to any type of client.

And please, don´t worry. Those perceived as risky have never ever caused a major bank crisis, and your regulators should know that.

Here is the complaint I presented to CFPB

Do bank regulators suffer from damage in the ventromedial prefrontal cortex?

All major bank crises originate not from too much lending to what is perceived as risky, that never happens, but from too much lending to something perceived as absolutely not risky but that later becomes very risky, and this often because too much has been lent to it. This is a fact, and regulators, financial journalists and other experts know it. 

And yet, bank regulators set up capital requirements for banks that were much higher when the perceived risk were higher than when the perceived risk were lower, and thereby generated the incentives for too much lending to the latter… as a result of that since banks were allowed to leverage their equity more when doing so, banks could obtain a higher return on their equity when lending to what was officially deemed as absolutely not risky. 

And that not only caused the current crisis but it also keeps us from digging ourselves out of it, as it discriminates against all the “risky” small businesses and entrepreneurs we need to help us. 

And no matter how much I have written about it, the regulatory nannies don’t seem to get it, and keep on digging us, deeper and deeper, into what I have called “L’economia castrata”, that which so dangerously discriminates against what seems as “risky”. Why is this so? 

Well Malcolm Gladwell, in his book “Blink”, 2005, wrote that those who suffer from damage in the ventromedial prefrontal cortex, “can be highly intelligent and functional, but they lack judgment”, and that it “causes a disconnect between what you know and what you do”. Could that be it?

Capital requirements for banks, according to any behavioral finance, should NOT be based on perceived risk, but on what banks do with any perceived risk.

PS. Here my 2019 letter to the Financial Stability Board

It’s the stupid bank regulations stupid!

Those perceived as “not risky”, they have always paid lower interest rates, gotten larger loans, on softer terms, and attracted that type of large bank exposures that has caused all major bank crises, when some of them turn out to be very-risky. And so why, Mr. Bright Bank Regulator, do you allow the banks to hold less capital when lending to the “not risky”? That way the "not risky" get even lower interest, even larger loans, on even softer terms and we risk an even major systemic crisis, when some of these “not-risky”, like the triple-A rated securities, the infallible sovereigns like Greece, Icelandic banks, Spanish real estate borrowers and what awaits us, turn out to be very risky. Why are you so chummy with the dangerous not-risky, are you stupid? 

Those perceived as “risky”, like the small businesses and entrepreneurs, they have always paid higher interest rates, gotten smaller loans, on harsher terms, and never ever caused a major bank crisis. And so why, Mr. Bright Bank Regulator, do you require the banks to hold more capital when lending to the “risky” than when to the “not risky”, and so that the "risky" get charged even higher interests, get even smaller loans, on ever hasher terms, and so have even less chance of helping us to generate the growth and job opportunities we need, and, like now, help us out of the crisis generated by some “not-risky” ex-ante, turning very-risky, ex-post. Why do you treat the useful risky so bad, are you stupid? 

Mr. Bright Bank Regulator, if you absolutely must mess around with market signals, so you feel you have earned your salary, then why do you not at least base the capital requirements for banks on job creation and environmental sustainability ratings. That way these would at least serve a purpose.

The Western world is being brought to its knees by mad bank regulators

The Western world is the result of risk-taking in all shapes and forms… “God make us daring!” ends one of the psalms sung in its churches… and we honor the successful and feel for the unsuccessful. 

But regulators, concerned only with bank failures, decided on capital requirements for banks based on perceived risk. And with these they gave the banks additional incentives to embrace lending to those perceived as “not-risky”, like the triple-A rated and “infallible” sovereigns, and to further avoid the “risky”, like the small business and entrepreneurs. And with this they stuck a dagger in the very soul of the Western world. 

And the dagger proved also to be more than useless for its initial purpose. Since it is precisely when banks embrace too much something that is perceived as absolutely not risky, that they fail en masse, the regulators doomed the world to this the mother of all systemic bank crises. 

The survival of the Western world now needs to begin by rescuing the possibilities of its risky risk-takers to take the risks we depend upon as a society, and that requires to allow the “risky” to compete for bank credit without regulators discriminating against them. 

And that begins by firing the nannies in the Basel Committee and in the Financial Stability Board, and renaming the latter immediately the Financial Functionability Board so that the regulators do not forget what they are there for.

“L'economia castrata”: The castrated economy which resulted from when regulation nannies castrated our banks

What would you think of a military high command that ordered a testosterone reducer to be fed to the soldiers so they would expose themselves less to risks, and so fewer of them would die? Right! That would indeed be high treason, as it would guarantee defeat. 

But that is precisely what bank regulators have done to our banks: 

Current capital requirements for banks, based on ex ante perceived risk, allow banks to hold much-much less capital on assets perceived as “absolutely safe” than on assets perceived as “risky”. 

That allows banks to earn much-much higher risk-adjusted returns on equity, when lending to “The Infallible”, than when lending to “The Risky”; 

And that results in that banks will lend, even more than usual, at even lower rates than usual, to sovereigns, housing and the AAAristocracy; and even less than usual, at even higher rates than usual, to medium and small businesses, the entrepreneurs and start-ups. 

And those regulations signify, as you can understand, a powerful testosterone inhibitor. 

And so the regulators have effectively castrated the banks and as a result we have a castrated economy with growing dangerous obese exposures to what was or is officially deemed as “not-risky”, triple A rated instruments and “infallible” sovereigns and housing; and equally or even more dangerous anorexic exposures to what is officially perceived as “risky”, like small and medium businesses, entrepreneurs and start-ups. 

God save us! From dumb regulators who do not understand that risk-taking is the oxygen of any movement forward. 

And before we get the testosterone level of banks back to normal, there is no stimulus package that will work, and we will only be wasting away whatever little fiscal and monetary policy space remains. 

God make us daring!