Charles Goodhart also pointed out the stupidity of risk weighted capital requirements for banks based on ex ante perceived risks… also with no luck!
In the very last page (540) of Charles Goodhart’s “The Basel Committee on Banking Supervision: A history of the Early Years, 1947-1997” of 2011 we read the following:
“Capital is supposed to be a buffer against unexpected loss: In so far as capital is required against unexpected loss, since expected loss should be handled by appropriate interest margins, the use of credit ratings as a guide to risk weights for capital adequacy requirements (CARs) is wrong and inconsistent, since these give a measure of expected loss. What is needed instead is a measure of the uncertainty of such losses, the second moment rather than the first.
If capital risk weights had been based, as they should logically have been, on the uncertainty attending future losses, rather than their expected modal performance, the financial system might have avoided much of the worst disasters of the 2007/08 financial crisis.
It remains surprisingly difficult to persuade regulators of this simple point.”
But to that Goodhart adds “It does however, get recognized from time to time”… though the examples he then indicates, are not so clear.
In the Epilogue (page 581) Goodhart list some of the failings of the BCBS’s regulations:
1. The lack of any theoretical basis.
2. The focus on the individual institution, rather that the system
3. The failure to reach an accord on liquidity;
4. The lack of empirical analysis;
5. The unwillingness to discuss either sanctions or crisis resolution, and so on.
That clearly adds up to a total regulatory failure... no wonder they don't want to discuss sanctions.
But, unfortunately as I see it, Charles Goodhart, though absolutely right, is only scratching the surface. What is most dangerously ignored are the distortions in the allocation of bank credit to the real economy that these risk weighted capital requirements for banks cause.
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