Fortune tellers’ bankers' bad-luck weighted capital/equity requirements for banks, would be better than the Basel Committee’s.

We have the Basel Committee’s risk weighted capital/equity requirements for banks. More ex ante perceived risk more capital/equity; less perceived risk less capital/equity. 

These are loony. First, since it considers that was is already perceived as risky, is riskier for the bank system than what is perceived as safe; and second, because it distorts the allocation of bank credit to the real economy, hindering banks from the much needed financing of the riskier future, making them concentrate on refinancing the safer past and present. 

Now, if we were to weigh the capital/equity requirements for banks based on the fortunetellers reading bankers' hands, to ascertain bankers' bad-luck, then we would at least have one capital/equity requirement against all assets; something that would at least not distort the allocation of bank credit to the real economy. And since this procedure would be based on bad-luck, and not on good luck, we could expect that capital requirement to be fairly high.

And if the fortune tellers got it all wrong, since they did not distort credit allocation, that would be less dangerous when compared to the credit rating agencies being wrong.

I challenge any of all current bank regulators to, in public, defend their risk weighting against that of my fortune tellers.

My opening question to them would be: What do you think of that Basel II assigned a risk weight of only 20% to the so dangerous AAA rated, and one of 150% for the so innocuous below BB- rated?

PS. Of course fortune tellers could be captured... but so can credit rating agencies be too.

PS. Now, what I would not suggest to do, is to allow big banks to use their own internal fortune tellers, as they currently use their own internal risk modellers to weigh the risks, and thereby set the capital/equity they are required to hold.

PS. Of course, if we land ourselves a fortune teller that wants to show-off, and for instance insists on that bad-luck depends on the day of the week a credit is approved, we better look for a less sophisticated one.

It's what bankers perceive as safe that's truly dangerous to our bank systems

Lawrence Summers, like most, is still blinded by the fairy tale of the risk-weighted capital requirements for banks

I refer to Professor Lawrence Summers “Five suggestions for avoiding another banking collapse” of May 21, 2017

In it Summers clearly evidences he has not yet woken up to the fact that the whole notion of the risk weighted capital requirements of banks is pure and unabridged nonsense… a regulatory fairytale. He still actually believes that risk weighting has anything to do with real risk weighting of the risks to our bank system.  In fact bad-luck risk weighted capital requirements might better cover for the unexpected risk in banking. And so here I explain it again, for the umpteenth time.

The current risk weighting is based on the ex ante perceived risk of bank assets, and NOT on the possibility of that those assets could ex post be risky for the banks and for the bank system

That is for example why regulators in Basel II assigned to what was perceived as AAA rated and that because of such perception of safety could lead to a build up of dangerously excessive exposures, a tiny 20% risk weight; while to the below BB- rated, so innocuous because the banks would never voluntarily create large exposures to it, they assigned a whamming 150%.

Rule: If bankers are not capable of managing perceived risks, then zero capital might be the best requirement, because the faster they would fold.

Truth: A bank system can collapse because of unexpected events (like devaluations), major financial fraud, and when assets ex ante perceived as very safe suddenly turn out ex post as very risky. None of these risks is covered by the Basel Committees’ risk weighted capital requirements.

Summers writes: “there is distressingly little evidence in favor of the proposition that banks that are measured as better capitalized by their regulators are less likely to fail than other banks.” That might be true but only to believe that the measuring of the “measured as better capitalized” is correct, is absurd. Too much reputable research has taken the historical not “risk weighted” capital to asset ratios to be the same as the current capital to risk-weighted asset ratios, which is comparing apples to oranges.

Summers explains: “Our paper examines a comprehensive suite of volatility measures including actual volatility, volatility implied by option pricing, beta, credit default spreads, preferred stock yields and earnings price ratios… none [of which] suggest a major reduction in leverage for the largest US financial institutions, large global institutions or midsize domestic institutions.” I just ask, Professor, amongst so much glamorous sophistications, did you examine the gross not risk weighted assets to capital ratio? That would have probably sufficed.

Summers recommends, “First, it is essential to take a dynamic view of capital” Absolutely! But Professor, do you not believe that a real dynamic view would have to take into account what the shape of the future real economy would be if regulators insist in distorting with their risk weighing the allocation of bank credit to the real economy? For instance should a real stress test not also look at what is not on banks’ balance sheets… like for instance to see if vital risky loans to SMEs and entrepreneurs are too inexistent?

Summers recommends: “banks should not be permitted to take excessive risks or treat customers unfairly in order to raise their franchise value.” Indeed, but what about by means of current risk weighting unfairly allowing those perceived, decreed (sovereigns) or concocted as safer, to have much better access to bank credit than usual than those perceived as risky? Does that not foster more inequality?

Summers very correctly write: “it is high time we move beyond a sterile debate between more and less regulation. No one who is reasonable can doubt that inadequate regulation contributed to what happened in 2008 or suppose that market discipline is sufficient to contain excessive risk-taking in the financial industry” But that requires understanding and accepting that the risk weighting, which so favored what was AAA rated and sovereigns was “the inadequate regulation”. Moreover, as Einstein said, “No problem can be solved from the same level of consciousness that created it”, that requires us to completely change all our current regulators and start from scratch. 

SO NO! Professor Lawrence Summers, with respect to bank regulations, may I respectfully suggest you either wake up or shut up!

PS. And that goes for most of you others bank regulation experts out there.

PS. This is not the first way I have told Professor Summers he does not get it.

PS. Here is a set of questions current bank regulators do not dare to answer.

Why are excessive bank exposures to what’s perceived safe considered as excessive risk-taking when disaster strikes?

In terms of risk perceptions there are four basic possible outcomes:

1. What was perceived as safe and that turned out safe.

2. What was perceived as safe but that turned out risky. 

3. What was perceived as risky and that turned out risky.

4. What was perceived as risky but that turned out safe.

Of these outcomes only number 2 is truly dangerous for the bank systems, as it is only with assets perceived as safe that banks in general build up those large exposures that could spell disaster if they turn out to be risky.

So any sensible bank regulator should care more about what the banks ex ante perceive as safe than with what they perceive as risky.

That they did not! With their risk weighted capital requirements, more perceived risk more capital – less risk less capital, the regulators guaranteed that when crisis broke out bank would be standing there especially naked in terms of capital. 

One problem is that when exposures to something considered as safe turn out risky, which indicates a mistake has been made, too many have incentives to erase from everyones memory that fact of it having been perceived as safe.

Just look at the last 2007/08 crisis. Even though it was 100% the result of excessive exposures to something perceived as very safe (AAA rated MBS), or to something decreed by regulators as very safe (sovereigns, Greece) 99.99% of all explanations for that crisis put it down to excessive risk-taking.

For Europe that miss-definition of the origin of the crisis, impedes it to find the way out of it. That only opens up ample room for northern and southern Europe to blame each other instead.

The truth is that Europe could disintegrate because of bank regulators doing all they can to avoid being blamed for their mistakes.

The insidious credit distorting risk weighted bank capital requirements’ tax, crosses the Laffer Curve at point zero

The Laffer Curve indicates at what rate, a tax will produce less tax revenues for the government.

For purposes of setting the capital requirements for banks in 1988 (Basel Accord) the regulators introduced the risk weighing of banks’ assets. And they decided that loans to the sovereign carried a 0% risk weight, while loans to the citizens (SMEs and entrepreneurs) 100%. 

That means banks need to hold less capital (meaning equity) against loans to the sovereign (meaning government) than against loans to citizens.

That means banks can leverage more their equity with the market risk adjusted interest rates for loans to the sovereign than with the market risk adjusted interest rates for loans to the citizens; which means sovereign will have more and cheaper access to bank loans, a regulatory subsidy, paid by lesser and more expensive access to bank credit for the private sector, a regulatory tax.

That de facto signifies that regulators believe government bureaucrats can make better use of bank credit than the private sector, something that is not true. 

As a consequence of this regulatory distortion, bank credit will not be allocated efficiently to the economy; and so the economy will grow less; and so the tax intake will be smaller; and so the Laffer curve has immediately been crossed. 

Of course, if the current generation does not care about falling tax revenues being compensated with higher debts to be repaid by grandchildren, then this is a moot issue.

PS. Of course all other favoring, like a 20% risk weight for the AAA-risktocracy and 35% for residential housing also to misallocate credit... and thereby cause less ordinary tax revenues. 

PS. Of course, sadly, nothing is gained in term of stability, as never ever do major bank crisis result from excessive exposures to something perceived risky. These results from excessive exposures to something perceived safe, like sovereigns like Greece, like AAA rated securities.