You, the bank regulating scientists, would you please explain something to a layman?

Below what I saw while walking around in the Washington Zoo with my constituency (my grandchild) and which inspired me to ask our bank regulation scientists friends a question.

Smithsonian scientists learn a lot by observing animals. 

Now its your turn to WATCH AND LEARN

So now it is with you bank regulator. You are the scientist. Scientist learns a lot, by observing banks and bankers. So please explain.

Observe what type of bank exposures have caused all major bank crises:

1. One or many of those ex ante considered risky, and that ex-post turned out to be risky?

2. One or many of those ex ante considered risky, and that ex-post turned out to be safe?

3. One or many of those ex ante considered absolutely safe risky, and that ex-post turned out to be safe?

4. One or many of those ex ante considered absolutely safe risky and that ex-post turned out to be very risky?

And now, you bank scientists answer us non bank scientists. 

For what type of exposures would the empirical evidence suggest the capital requirements for banks should be higher?

Aha! 

And so then explain to us, in easy terms, why you, the Basel Committee for Banking Supervision, the Supreme Global Bank Supervisor, set rules which allowed the banks to have much much less capital for what was ex ante perceived as "absolutely safe", than for what ex ante is perceived as risky?

Please?

PS. My own humble opinion is that our bank regulation scientist friends have got themselves trapped in quite a bit of confusion. They keep on analyzing the possible failure of bank borrowers and not, as they should, the reasons for why banks fail, as entities or in allocating credit to the real economy. And that is of course not the same thing, or, as they say in French, c’est pas la même chose… For instance instead of looking at the ex ante credit ratings of bank borrowers they should look at what bankers do when they see those same credit ratings.

In other words, the regulators instead of analyzing so much the ex ante creditworthiness of bank borrowers, to determine their risk weights, should have analyzed, at least a little, the ex-post explanations for why banks fail and for why bank crises occur. Holy moly!

PS. As I see it: The world (with its banks) is much better off thinking that the risky are less risky than we think them to be, than that the "safe" are as safe as we think.

What should the punishment be for those who risk Europe´s (and America's) unemployed youth to become a lost generation?

There are of course many who share the responsibility for risking that Europe´s (and America's) unemployed youth becomes a lost generation. But, in my opinion, the guiltiest party is regulators who came up with the absolutely lunatic criteria of making capital requirements for banks a function of the ex ante perceived risk which was already being cleared for by the banks, by means of interest rates (risk premiums), size of exposures and other contractual terms.

That distorted all common sense out of bank credit allocation in the real economy, and also caused that when something ex ante perceived “absolutely safe” turns out ex post to be “very risky”, the usual cause of all bank crises, that the banks ended up totally undercapitalized and at least temporarily unable to help out in any recovery.

These regulators have not been shamed sufficiently much less punished. In fact they were reauthorized to proceed to make a new set of regulations Basel III, conserving the same rotten apple of Basel II.

When I think about the pain and suffering these dumb regulators have and will be inflicting on millions of our young ones, then, parading them down avenues wearing dunce caps, seem to be sort of an absolute minimal social sanction.

We absolutely must hold these regulators accountable, but, until now, for around six years, they have been able to avoid taking any responsibility using a lot of distractive maneuvers. 

Many years ago, at a seminar, the facilitator asked the group to look at a video and try to keep count of how many times a group of persons passed a white ball among themselves. After one minute he asked around, getting answers like 13, 14, and 15. He then asked whether someone had noticed something strange. I, who had as it seems been distracted from looking at the ball (through luck or genes), had noticed the presence of a gorilla coming into the scene, pounding his chest and then leaving. 

So please, J'accuse...!, lookout for the Basel Committee's capital requirements for banks gorilla, who is pounding on our economies, and on the job prospects of our young

We need “The Risky” to access bank credit, competitively, especially in bad times, as “The Infallible” alone cannot pull us out of anything

If a bank charges a 3 percent risk premium to set of small and medium businesses, entrepreneurs and start-ups borrowers, then it is reserving for sustaining losses of about 30 percent on 10 percent of these borrowers, something which, as bankers do not give loans were they think they are going to lose, is a hell of a great reserve.

But, the higher risk premiums paid by “The Risky” was something completely disregarded by the regulators when setting those capital requirements for banks based on perceived risk and that so much favor bank lending to “The Infallible”, in essence sovereigns, housing and the AAAristocracy.

You see, our current set of bank regulators, they do not care one iota about the fact that their capital requirements utterly distorts the allocation of bank credit in the real economy, and in which, it is really the access to bank credit of “The Risky”, in competitive terms, what most needs to be assured.

You see our current bank regulators care only about the banks, and that is why they are so damn bad bank regulators.

You see our current bank regulators are so scared shit about all ex ante “risk”, they fail to understand that, ex post, only “The Infallible” cause major bank disasters.

There is nothing as risky for the banks, and for us, as not taking a risk on “The Risky” of the real economy.

God make us daring!

Why is the President of the World Bank not informed about consequences of risk-weighted capital requirements for banks?

In Russia, September 6, 2013, Jim Yong Kim, the President of the World Bank Group, said the following in his statement issued at the end of the G20 summit.

“The G20 has pledged to achieve strong, sustainable, balanced and inclusive growth, and creating more and higher-quality jobs.”

Mr. Jim Yong Kim. As long as bank regulators allow banks to hold much much less capital when lending to "The Infallible", like some sovereigns, housing or the AAAristocracy; than what they are required to hold when lending to “The Risky”, like medium and small businesses, entrepreneurs and start-ups; and which means the banks will earn much much higher risk-adjusted returns on their equity when lending to the former than when lending to the latter... "strong, sustainable, balanced and inclusive growth" able to create more and higher-quality jobs” will just not happen. 

The odious and dangerous discrimination of "The Risky" does only increase, not reduce, the gap between those perceived as safe, the past, the developed, the haves, and those perceived as “risky”, the future, the developing, the have nots.

And the truly sad thing is that no one in the world’s premier development bank wants to inform its president about it.

Mr. Jim Yong Kim. I assure you, risk-taking is the oxygen of development. God make us daring!

Per Kurowski

A former Executive Director of the World Bank, 2002-2004

The Financial Stability Board, Mark Carney, is not telling the truth to the leaders of G20

Mark Carney, in the name of The Financial Stability Board (FSB), on September 5, 2013, reports to the G20 Leaders the following:

"In Washington in 2008, the G20 committed to fundamental reform of the global financial system. The objectives were to correct the fault lines that led to the global financial crisis and to build a safer, more resilient source of finance to serve better the needs of the real economy... FSB members have made major progress correcting the fault lines that caused the crisis.”

And that is just not true.

The major fault line that lead to the global financial crisis, were capital requirements for banks which allowed banks to earn much much higher risk-adjusted returns on equity on exposures that were perceived as “absolutely safe”, than on exposures perceived as” risky”. 

That consequentially stimulated the banks to build up excessive exposures to The Infallible, The AAAristocracy, and which later, in much as a result of it, when some of these exposures turned sour, it found the banks standing there naked with little capital to cover themselves up with.

And that problem, of how the capital requirements distort and makes it impossible for the banks to allocated bank credit efficiently to the real economy, has not even yet begun to be discussed, at least not in public.

The ridicule small capital requirements for some “ultra-safe” exposures also served as the most important growth-hormone for the “too big to fail” banks.

FSB also states in the document that “the risk models that banks use to calculate their capital needs show worryingly large differences” . And I ask,  what’s their problem? Do they want the whole world to use the same risk models, so that when these turn out wrong, as they will do sooner or later, everyone goes down the tube in a virtuous kumbayah like solidarity? 

When will these regulators understand their duty is not to assure the existence of the right risk-models, but to prepare for when the risk-models of bankers turn out to be wrong?

In case you wonder what possible credential would I have to dare to call out the bluff of the Financial Stability Board, let me just put forward, as one of many, that as an Executive Director of the World Bank, in a written statement delivered in October 2004, I warned that “We believe that much of the world’s financial markets are currently being dangerously overstretched though an exaggerated reliance on intrinsically weak financial models that are based on very short series of statistical evidence and very doubtful volatility assumptions.”

Leaders of the G20. It is your duty to stop the nonsensical and extremely risky risk-aversion of the Basel Committee for Banking Supervision and the Financial Stability Board. Our children and grandchildren deserve it.

Finance ministers of the world. How many of you believe risk-aversion is good for the economy? Raise your hands!

What if Mark Twain knew about the capital requirements for banks in Basel I, II and III, based on ex ante perceived risks?

If Mark Twain resurrected, and read about what our current bank regulator came up with, in terms of capital requirements based on perceived risk, which allow the banks to earn much much higher risk-adjusted returns on equity when lending to “The Infallible”, than when lending to “The Risky”, he would need to expand on his opinion on bankers, to something like what follows:

“A bank regulator is one who likes the banker to lend out the umbrella when the sun shines, even more than what a banker likes to do that, truly amazing; and one who wants the banker to take that umbrella back when there is the slightest indication it could rain, even faster than what the banker would like to do, equally truly amazing.”

David A. Stockman’s “The Great Deformation” did not include what is perhaps the greatest deformation.

David A. Stockman’s The Great Deformation is a truly great book, except for the fact that sadly it misses out on what in my mind constitutes the greatest deformation… namely allowing for much much lower capital (equity) requirements for banks on exposures that are considered as “absolutely safe”, than what they are required to hold for exposures considered as “risky”.

That allows the banks to grow so as to end up as Too Big To Fail, and to earn much higher risk-adjusted returns when lending to “The Infallible”, than when lending to “The Risky”.

And that distorts completely the way credit is allocated within the real economy, so that too much at too low interest rates of it goes to the "The Infallible", like the sovereign and the AAAristocracy (or AAArisktocracy) and too little to at too high interest to "The Risky", like medium and small businesses, entrepreneurs and star-ups.

And that effectively increases the de-facto risk-adverseness of banks, in the home of the brave, and in all other countries were these truly lamentable regulations are applied. And if that is not a deformation, what is?

Stockman does not mention that because of Basel II, approved in June 2004, and what SEC approved for US investment banks, April 2004, the European banks and the US investment banks could hold AAA rated securities, or lend against these securities, holding only 1.6 percent in capital, meaning leveraging their equity a mind-boggling 62.5 times to 1. 

And a result, though Stockman, in Chapter 20, “How the Fed brought the gambling mania to America’s neighborhoods”, explains splendidly the tragedy of how extremely bad mortgages were awarded to the subprime and other sectors in the US, and then packaged into dubious AAA rated securities sold all over the world, he misses out completely on the main reason for why the world demanded these securities and all other “supper-safies” so much, that it completely lost its common sense.

Let me assure everyone that if the banks had needed to hold the 8 percent they have to hold when lending to their “risky” citizen, then the current US subprime, Greek sovereign, Spanish real estate, Cyprus' banks, and similar tragedies, would not have happened. It is as easy as that… which of course does not make it any easier to swallow.

I hope that in the next edition of “The Great Deformation” David Stockman at least rewrites his chapter 20 so as to include these considerations. It would be a shame not to do so in such a good book.

And I need to repeat it again: A nation were banks need to hold 8 percent in capital when lending to the citizens, but are allowed to lend to their government against zero capital, is a deformed nation.

PS. The risk weights of 0% for the Sovereign, 20% for the AAArisktocracy and 100% for We the People, is anathema to America.

God make us daring!