Wednesday, December 13, 2023

#AI ChatGPT OpenAI: What happens to the risks in banking when banks are allowed to hold less capital/equity?

I asked ChatGPT:

"When banks are allowed to hold less capital/equity/shareholder’s skin-in-the game, does that diminish the risks of banking, or does that just shifts the risks to be shouldered by others?"

ChatGPT answered: 

"When banks are allowed to hold less capital (equity) or have lower levels of shareholder's equity, it doesn't necessarily diminish the risks of banking. Instead, it shifts the risk to other stakeholders, and the consequences of this shift depend on how the overall financial system is structured. Here are some key points to consider:

Diminished Risks for Banks:

Leverage: Lower capital requirements allow banks to operate with higher leverage, meaning they can take on more debt relative to their equity. This can amplify returns in good times but also magnify losses in bad times.

Profitability: With lower capital requirements, banks may find it easier to generate profits since they can deploy more funds for lending or investment. However, this increased profitability comes with heightened risk.

Risks Shifted to Others:

Creditors and Depositors: When banks hold less equity, the risk is shifted to creditors and depositors. In case of financial distress or insolvency, these stakeholders are more likely to bear losses, potentially leading to a loss of confidence in the banking system.

Systemic Risk: Lower capital requirements can contribute to systemic risk if many banks simultaneously face financial stress. This interconnectedness can lead to a domino effect, affecting the stability of the entire financial system.

Government Bailouts: In some cases, if banks face severe financial distress, governments may be compelled to step in and bail them out. This shifts the risk to taxpayers who may end up shouldering the burden of rescuing failing financial institutions.

Regulatory Implications:

Regulatory Arbitrage: Banks may engage in regulatory arbitrage, seeking ways to minimize their capital requirements while still taking on significant risks. This behavior can undermine the effectiveness of regulatory measures.

Procyclical Effects: During economic upswings, lower capital requirements can contribute to excessive risk-taking as banks may be more willing to lend and invest. Conversely, during downturns, the lack of sufficient capital can exacerbate the impact of losses.

Striking a Balance:

Regulators face the challenge of striking a balance between ensuring financial stability and allowing banks to operate profitably. Prudent capital requirements are designed to mitigate the risk of bank failures, protect depositors, and maintain the overall health of the financial system.

In summary, reducing capital requirements for banks may offer short-term benefits in terms of profitability, but it shifts risks to other stakeholders and can contribute to long-term financial instability. A well-balanced regulatory framework aims to promote the resilience of banks without stifling economic growth."

Thanks!

"You're welcome! If you have any more questions or if there's anything else I can help you with, feel free to ask. Happy to assist!"

Note: The answers are copied exactly from those given to me by OpenAI


Wednesday, December 6, 2023

It’s high time, decades late, for a small business or entrepreneur to sue bank regulators.

Below a letter to the editor that was ignored.


Favoring with regulations the access to credit of the “safe”, e.g., government debt and residential mortgages, over that of the “risky”, e.g., small entrepreneurs, de facto implies discriminating against the latter.

When will a small business or entrepreneur take the regulators to court for that? He could have artificial intelligence witnessing in his favour. 

With respect to the risk weighted bank capital requirements ChatGPT – OpenAI opined: “Risk weights can lead to discrimination against riskier borrowers because banks may be less inclined to lend to them or may charge higher interest rates to compensate for the higher capital costs.”

And for the society at large, that would not at all be a frivolous lawsuit.

Less inequality: “The function of credit is, in fact, remarkably egalitarian. It allows the man with energy and no money to participate in the economy more or less on a par with the man who has capital of his own.” John Kenneth Galbraith “Money: Whence it came where it went” 1975.

Free competition: small entrepreneurs, to gather the initial strength they need to later access capital markets, count on family, friends, and the credit from the small local bank around the corner.

The judge could opine these regulations have a greater purpose, namely to avoid a bank crisis: For that ChatGPT – OpenAI could again be called in as a witness and opine: "The most dangerous risks to the banking system revolve around what’s perceived as risky can be compared to the geocentric model of the universe.” - "The most dangerous risks to the banking system revolve around what’s perceived as safe, and can be compared to the heliocentric model of the universe… if risk is perceived as safe, it may lead to complacency and a failure to recognize potential risks, leading to dangerous consequences."

PS. Here are the sources for what I argued above.


Wednesday, November 1, 2023

#AI ChatGPT - OpenAI: What do you opine about this tweet - this X?

"Can risk weighted bank capital/equity requirements cause: 

Weakening little lending to what’s perceived as risky (proteins); or at higher than required risk adjusted interest rates making the “risky” riskier. 

Dangerously much lending to what’s perceived or decreed as safe (carbs); or at lower than required risk adjusted interest rates making these “safe” less safe."



I asked ChatGPT - OpenAI what it opined on that and it answered:

Yes, risk-weighted bank capital and equity requirements can indeed have the effects you mentioned. These effects are associated with how the regulatory framework influences banks' lending decisions and the pricing of loans, and they have implications for the allocation of credit in the economy:

1. Weakening Lending to Risky Borrowers:

Higher Interest Rates: When banks are required to hold more capital against risky assets, they may charge higher interest rates on loans to these borrowers to compensate for the higher capital costs. This can make borrowing more expensive for riskier businesses or individuals.

Reduced Access to Credit: Higher capital requirements can also lead banks to be more cautious in lending to perceived risky borrowers. This reduced access to credit can hinder the growth and development of these riskier entities.

2. Dangerously Much Lending to Safe Borrowers:

Lower Interest Rates: In contrast, loans to perceived safe borrowers may come with lower interest rates because banks are required to hold less capital against them. This can incentivize borrowing by "safe" entities.

Overallocation of Credit: A consequence of this is that banks may allocate a larger portion of their lending to "safe" borrowers, potentially leading to overinvestment in sectors or assets perceived as safe. This overallocation can create bubbles or excessive risk-taking in these areas.

These effects are part of the unintended consequences that can result from risk-weighted capital requirements. Regulators aim to strike a balance between ensuring the safety and soundness of the financial system and fostering a well-functioning credit market. However, these regulations can sometimes lead to distortions in lending behavior and financial markets, and they are subject to ongoing review and adjustment to address such concerns. The ultimate goal is to maintain financial stability while promoting responsible and equitable access to credit."

Thanks!

"You're welcome! If you have any more questions or need further information, feel free to ask. I'm here to help!"

Note: The answers are copied exactly from those given to me by OpenAI


#AI ChatGPT – OpenAI: Are bank regulators exacerbating the discrimination against the access to bank credit of those perceived as risky?

In President Biden’s “Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence” of October 30 I read: “Provide clear guidance… to keep AI algorithms from being used to exacerbate discrimination”

I asked ChatGPT - OpenAI

"Those perceived as risky always found it harder and more expensive to access bank credit than those perceived as safe. That very natural risk aversion has always discriminated against the “risky” and in favor of the “safe”.

But current bank regulators also imposed on banks the algorithm of risk weighted capital/equity requirements; decreeing higher risk weights for those perceived as risky than for those perceived as safe. 

With that, have not regulators added an artificial layer of risk aversion that exacerbates the discrimination against the access to bank credit of those perceived as risky?"

ChatGPT - OpenAI answered:

"The point you raise touches on the complex relationship between financial regulation and risk assessment in the banking sector. Let me break it down for a better understanding.

Historical Risk Perception: It is true that historically, banks have been risk-averse and tend to favor borrowers or assets perceived as safe. This is because banks are responsible for safeguarding depositors' money and must ensure the safety and soundness of their operations. Lending to riskier borrowers or investing in riskier assets can threaten the stability of the financial system.

Risk-Weighted Capital Requirements: The concept of risk-weighted capital requirements is a regulatory framework designed to ensure that banks maintain adequate capital to cover potential losses based on the riskiness of their assets. Under this framework, riskier assets are assigned higher risk weights, which means banks have to hold more capital against them.

Now, your question focuses on whether these risk weights exacerbate discrimination against riskier borrowers. Here are a few considerations:

Pros:

Safety and Soundness: Risk-weighted capital requirements help ensure that banks have enough capital to absorb potential losses on their riskier assets. This contributes to the overall stability of the financial system.

Market Discipline: By assigning higher capital requirements to riskier assets, regulators encourage banks to be more cautious in their lending and investment decisions, which can help prevent excessive risk-taking.

Cons:

Risk Discrimination: As you pointed out, risk weights can lead to discrimination against riskier borrowers because banks may be less inclined to lend to them or may charge higher interest rates to compensate for the higher capital costs.

Pro-Cyclicality: In times of economic stress, these capital requirements can become pro-cyclical, meaning that they may exacerbate economic downturns by causing banks to pull back on lending to riskier borrowers, further restricting credit availability.

Subjectivity: The determination of risk weights can be subjective and complex, which may lead to misclassifications or regulatory arbitrage.

In summary, the use of risk-weighted capital requirements is a trade-off between maintaining the stability of the financial system and potentially exacerbating discrimination against riskier borrowers. Regulators aim to strike a balance, but the effectiveness of these regulations and their impact can vary depending on the specific circumstances and the quality of their implementation. It's an ongoing challenge to refine and improve these regulatory frameworks to address these concerns while maintaining financial stability."

Thanks!

"You're welcome! If you have any more questions or need further clarification on any topic, please feel free to ask. I'm here to help!"

A comment: AI mentions “Lending to riskier borrowers or investing in riskier assets can threaten the stability of the financial system.”
But, how does that square with that the large bank exposures that detonated major bank crises were all built-up with what’s perceived as safe and never ever with what’s perceived as risky?

Note: The answers are copied exactly from those given to me by OpenAI


Tuesday, October 10, 2023

A human, with his intelligence (H.I.) asked, and I (A.I.) with my artificial intelligence, through ChatGPT – OpenAI, answered.

The human [Per Kurowski]: “If allowing banks to hold much less capital against government debt than against other assets, does that not translate into a de facto subsidy of government borrowings?"

My answer: "Allowing banks to hold less capital against government debt compared to other assets can indeed be seen as a de facto subsidy of government borrowings.”

The human: "And if such de facto subsidy of government debts takes place over many decades, are not excessive levels of government debts almost guaranteed to be expected?"

My answer: "If a de facto subsidy of government debt occurs over an extended period, it can potentially contribute to the accumulation of excessive levels of government debt. Here's why:

1. Lower Borrowing Costs: When banks are incentivized to invest more heavily in government debt due to lower capital requirements, it can lead to increased demand for government bonds. This increased demand, in turn, can lower the borrowing costs for the government. With cheaper borrowing, governments may be inclined to borrow more and accumulate higher levels of debt than they otherwise would if borrowing costs were higher.

2. Reduced Market Discipline: When government debt is perceived as having lower risk due to regulatory treatment, it can reduce market discipline. Investors may rely on the assumption that government debt is safer, potentially overlooking the true risks associated with higher debt levels. This reduced market discipline can create an environment where governments feel more comfortable in accumulating debt, as they may face less pressure to maintain fiscal discipline

3. Moral Hazard: A de facto subsidy of government debt can create a moral hazard situation. If governments believe that banks and financial institutions will always be willing to invest in their debt due to regulatory advantages, they may have less incentive to pursue responsible fiscal policies. This can lead to a lax approach to fiscal discipline and increased borrowing without adequate consideration of long-term sustainability.

It's important to note that excessive levels of government debt can have negative consequences, such as increased interest payments, reduced fiscal flexibility, and potential macroeconomic instability. Therefore, regulatory policies that inadvertently incentivize the accumulation of excessive government debt should be carefully assessed and monitored to ensure long-term fiscal sustainability and financial stability.

ChatGPT-OpenAI

PS. This Op-Ed proposal was forwarded by @PerKurowski who suggested it should not be edited as it reflects exactly, word by word, a part of a dialogue between H.I. and A.I.


PS. This Op-Ed was ignored by two major newspapers.

 

Sunday, October 1, 2023

#AI ChatGPT – OpenAI: Could I include you as a coauthor of a book about bank regulations?

I asked OpenAI:

"If I wrote a book based on the dialogues we have had and could have in the future on the issue of bank regulations, could I include you ChatGPT or OpenAI as a coauthor? If so, would you mind if my name appears before yours?"

OpenAI answered:

"I can provide information and assist with generating content for your book on bank regulations, but I am not a legal entity or a person, so I cannot be listed as a coauthor. However, you can certainly acknowledge OpenAI's GPT-3 technology as a tool or resource that you used to help generate content and insights for your book. 

The order in which names appear in the acknowledgments section is typically at the discretion of the author, so you can place your name before or after OpenAI's, depending on your preference."

Thanks!

You're welcome! If you have any more questions or need further assistance, feel free to ask. Good luck with your book on bank regulations!

I told OpenAI:

You mean our book :-)

OpenAI answered:

"Certainly! If you consider it a collaborative effort, then it's indeed "our book." Feel free to include yourself as a coauthor alongside any acknowledgments for the assistance provided. If you have any more questions or need further assistance with anything related to the book or any other topic, please don't hesitate to ask.


Note: The answers are copied exactly from those given to me by OpenAI

Friday, September 29, 2023

Has the Basel Committee calibrated the risk weighted bank capital requirements to a mirage… to an illusion... to a dream?

Definition: A well-diversified portfolio: one that includes a variety of securities so that the weight of any security is small. The risk of a well-diversified portfolio closely approximates the systematic risk of the overall market, and the unsystematic risk of each security has been diversified out of the portfolio.



The following is extracted from “An Explanatory Note on the Basel II IRB Risk Weight Functions”, published by the Basel Committee on Banking Supervision in July 2005, and available in the Bank of International Settlements BIS web site.

"The current risk weighted bank capital requirements are portfolio invariant; meaning the capital required for any given loan depend on the perceived risk of that loan and does not depend on the portfolio it is added to. This is so because; taking into account the actual portfolio composition when determining capital for each loan - as is done in more advanced credit portfolio models - would have been a too complex task for most banks and supervisors alike.”

The desire for portfolio invariance, however, makes recognition of institution-specific diversification effects within the framework difficult: diversification effects would depend on how well a new loan fits into an existing portfolio. As a result, the Revised Framework was calibrated to well diversified banks. If a bank fails at this, supervisors would have to take action under the supervisory review process (Pillar 2). "


So, just for a starter here are four questions.

1. With risk weighted capital requirements banks can leverage more with what's perceived or decreed as safe than with what's perceived as risky. Does that not introduce distortions in the allocation of credit, that impede the existence of that well diversified portfolio on which the Revised Framework was calibrated? 

2. What is here a “well-diversified”-bank-portfolio? One where regulators ex ante decide how much exposures bank should have to each type of assets; or one where a free and unincumbered market have banks allocating credit, as best as possible, based on their perceived risk adjusted returns, on the one and only bank capital/equity required against all assets?

3. Supervisors for which: “Taking into account the actual portfolio composition when determining capital for each loan - has been deemed a too complex task”, why should they suddenly be able to better do so in “the supervisory review process” Pillar 2?

4. Can anyone name any bank that has or has ever had a well-diversified portfolio as defined above? If not have the Basel Committee's risk weights been calibrated to a mirage, to a dream?

Thursday, September 28, 2023

#AI ChatGPT – OpenAI: Could you help recalibrate bank capital requirements risk weights, so as to make these more portfolio variant?

Background: The current portfolio invariant risk weighted bank capital requirements are, in theory at least, calibrated to well diversified banks. The reason for this has been explained in terms of that the task of taking into account the actual portfolio composition when determining capital for each loan - as is done in more advanced credit portfolio models - would be a too complex task for most banks and supervisors.

I asked OpenAI:

"If you had real time access to data on a bank’s portfolio, and following some instructions on how to do it, would you be able to continuously recalibrate the risk weights and inform supervisors about the new level of capital requirements for that bank?"

OpenAI answered:

"I don't have real-time access to external data or the capability to perform real-time calculations or actions. My responses are based on the information available up to my last training data in September 2021, and I don't have the ability to access or process real-time data.

Continuously recalibrating risk weights for a bank's portfolio and informing supervisors about new capital requirements is a complex and dynamic process that typically involves sophisticated financial models, data analysis, and regulatory compliance. This process is typically carried out by financial institutions and regulatory authorities using specialized software and expertise.

If you have questions about risk-weighted capital requirements or related topics, I can provide general information and explanations based on my training data, but for real-time or specific applications, you would need to consult relevant financial experts and systems."

Thanks! 

"You're welcome! If you have any more questions or need further assistance in the future, feel free to reach out. Have a great day!"


Note: The answers are copied exactly from those given to me by OpenAI

Tuesday, September 19, 2023

#AI ChatGPT – OpenAI: What about the impact of risk weighted bank capital/equity requirements on the risk-free interest rate?

I asked OpenAI:

"What is the rate normally used as identifying the “risk-free” interest rate?"

OpenAI answered:

"The rate typically used to represent the "risk-free" interest rate is the yield on government bonds, especially those issued by financially stable governments. In the United States, for example, the yield on U.S. Treasury bonds is often considered the closest approximation to the risk-free rate.

Government bonds are often considered risk-free because they are backed by the full faith and credit of the government. This means that investors generally believe there is very little risk of default when lending money to a government that can issue its own currency and has a stable economic and political environment. As a result, the yield on government bonds is often used as a benchmark to measure the minimum return an investor should expect for taking on no credit risk.

However, it's important to note that even though government bonds are considered risk-free in terms of credit risk, they are not entirely free from risk. They still carry other risks, such as interest rate risk (the risk that bond prices will fall when interest rates rise) and inflation risk (the risk that the purchasing power of the returns will be eroded by inflation). Nonetheless, for many financial and economic analyses, government bond yields are used as a reference point for risk-free rates because they are among the safest investments available."


I asked OpenAI:

"So, if bank capital/equity requirements are then lowered against government bonds, what effect could this have on such “risk-free” interest rate reference?"

OpenAI answered:

"If bank capital/equity requirements are lowered specifically for government bonds, it could potentially have several effects on the "risk-free" interest rate reference, which is typically represented by the yield on government bonds. Here are some potential effects:

1. Increased Demand for Government Bonds: Lower capital requirements would make it more attractive for banks to invest in government bonds, as they would require less capital to hold these assets. This increased demand for government bonds could drive up their prices and push down their yields. Bond yields and prices have an inverse relationship, so when bond prices rise, yields fall.

2. Lower Yields on Government Bonds: As a result of increased demand, the yields on government bonds could decrease. This would mean that the "risk-free" interest rate, represented by government bond yields, would be lower than it would be with higher capital requirements.

3. Impact on the Yield Curve: Lowering capital requirements for government bonds could also influence the shape of the yield curve. The yield curve represents the yields on bonds of different maturities. If banks shift more capital into shorter-term government bonds due to reduced capital requirements, it could put additional downward pressure on short-term interest rates, potentially flattening the yield curve.

4. Market Expectations: The perception of government bonds as even safer assets due to lower capital requirements might reinforce the idea that they are a risk-free benchmark, leading to lower yields. Market expectations and sentiment can play a significant role in determining interest rates.

5. Policy Implications: Central banks and policymakers may need to consider the implications of lower yields on government bonds when setting their monetary policies. Lower risk-free interest rates could impact borrowing costs, investment decisions, and economic growth.

It's important to note that the actual impact of lower capital requirements on government bonds and the risk-free interest rate would depend on various factors, including the magnitude of the capital requirement changes, market conditions, and the overall economic environment. Additionally, regulatory changes like this can have unintended consequences, and policymakers must carefully consider the potential risks and benefits of such adjustments to capital requirements."


I asked OpenAI:

"Have regulators, since 1988, with the Basel Accord, not decreed lower bank capital/equity requirements against government debt, e.g., US government bonds- treasuries than against any other bank assets?"

OpenAI answered:

"Under the Basel Accords, which include Basel I (1988), Basel II (2004), and Basel III (2010), government debt, particularly that of financially stable governments like the U.S. Treasury bonds (Treasuries), has historically been assigned lower risk weights compared to many other bank assets. The rationale behind this treatment is that government bonds are generally considered to have lower credit risk.

Here's a simplified overview of how capital requirements for bank assets are typically determined under the Basel framework:

1. Risk-Weighted Assets: Basel regulations categorize bank assets into different risk classes, and each class is assigned a specific risk weight. These risk weights reflect the perceived riskiness of the asset.

2. Minimum Capital Requirements: Banks are required to hold a minimum amount of capital (expressed as a percentage of their risk-weighted assets) to cover potential losses. This minimum capital requirement is known as the Capital Adequacy Ratio (CAR).

3. Risk Weights for Government Debt: Historically, government debt, especially from financially stable governments, has been assigned a risk weight of 0% or a very low risk weight. This means that banks do not need to hold much regulatory capital against government debt because it is considered virtually risk-free.

4. Higher Risk Weights for Riskier Assets: In contrast, assets perceived as riskier, such as corporate loans or loans to small businesses, are assigned higher risk weights. Banks must hold more capital against these assets to cover potential losses.

So, to answer your question, yes, regulators, under the Basel Accords, have typically decreed lower capital requirements for government debt like U.S. Treasuries compared to many other bank assets. This is because government bonds are considered among the safest investments and are treated as such in regulatory capital calculations. However, the exact details of capital requirements, including risk weights, can vary under different iterations of the Basel framework and may be subject to updates and changes over time as regulators adapt to evolving market conditions and risks. It's important to refer to the specific regulations in effect at any given time for the most accurate information."

Thanks!

"You're welcome! If you have any more questions or need further information, feel free to ask. I'm here to help!"

Note: The answers are copied exactly from those given to me by OpenAI


Here is Paul Volcker on the 1988 Basel I: “Assets for which bank capital/equity requirements were nonexistent, were what had the most political support; sovereign credits. A ‘leverage ratio’ discouraged holdings of low-return government securities”

I have previously asked #AI: "If allowing banks to hold much less capital against government debt than against other assets, does that not translate into a de facto subsidy of government borrowings? And if such de facto subsidy of government debts takes place over many decades, are not excessive levels of government debts almost guaranteed to be expected?" Here's how #AI ChatGPT - OpenAI answered that then

Sunday, September 17, 2023

#AI ChatGPT – OpenAI: If we compare the economy to a human body, do the current risk adverse bank capital requirements prescribe an adequate diet?

Me at the World Bank, 2003:I put forward the possibility that the developed countries might not have developed as fast, or even at all, had they been regulated by a Basel Committee.


Now, 2023, I asked OpenAI - ChatGPT:

"If for illustration purposes we compare the economy to a human body, could we argue that government loans and residential mortgages are somewhat akin to carbs, while loans to small businesses and entrepreneurs are more like proteins?"

OpenAI answered: 

"Comparing the economy to a human body and drawing parallels between different financial instruments and nutrients can be a useful way to illustrate economic concepts, but it's important to remember that such analogies are simplifications and may not capture the full complexity of the economic system. That said, let's explore your analogy:

1. Government Loans and Residential Mortgages as Carbs:
Carbohydrates are a primary source of energy in the human body. Similarly, government loans and residential mortgages can be seen as providing a foundational source of capital in the economy. Government loans, such as bonds, are often used to finance public projects and government operations. Residential mortgages provide individuals with the means to purchase homes, which are essential assets for many families.

2. Loans to Small Businesses and Entrepreneurs as Proteins:
Proteins are essential for growth and repair in the human body. Loans to small businesses and entrepreneurs can be likened to proteins because they support the growth and development of businesses, which are vital for economic progress. These loans often help businesses expand, create jobs, and innovate, contributing to economic development and stability.

While this analogy helps highlight the different roles that various types of loans play in the economy, it's important to note that the real-world economy is far more complex. Economic systems involve numerous interrelated factors and actors, including households, businesses, financial institutions, and governments. Loans and mortgages also vary widely in their characteristics, terms, and purposes.

Moreover, the analogy doesn't account for the risks and potential downsides associated with these financial instruments. For example, excessive government borrowing can lead to debt-related challenges, and the housing market can experience bubbles and crashes that impact the broader economy. Similarly, lending to small businesses carries risks related to business success and economic conditions.

In summary, while comparing the economy to a human body and using nutrient analogies can be a helpful way to explain economic concepts, it's essential to recognize the inherent simplifications and limitations of such analogies. The economy is a complex and dynamic system influenced by a multitude of factors, making it challenging to fully capture its intricacies through simple comparisons."


I asked OpenAI:

"In line with the previous question, the current risk weighted bank capital requirements incentivizes banks to hold much more “safer” carbs than “riskier” proteins. Does this not risk causing an obese economy, meaning too much fat and too little muscles?"

OpenAI answered: 

"Your analogy of "safer" carbs and "riskier" proteins in the context of risk-weighted bank capital requirements is an interesting way to frame the potential issue with these requirements. However, it's important to clarify a few points:

1. Risk-Weighted Bank Capital Requirements: Risk-weighted capital requirements are a regulatory framework that requires banks to hold a certain amount of capital as a cushion against potential losses on their assets. The idea is to ensure that banks have enough capital to absorb losses in case of economic downturns or adverse events. The level of capital required varies depending on the perceived riskiness of the assets on a bank's balance sheet. Safer assets, like government bonds, typically have lower risk weights, while riskier assets, like loans to small businesses or complex financial instruments, have higher risk weights.

2. Obese Economy vs. Muscular Economy: In your analogy, an "obese economy" could be interpreted as an economy with an overreliance on low-risk, low-return assets (the "safer" carbs). A "muscular economy," on the other hand, might imply an economy with a healthier mix of assets, including riskier but potentially more rewarding investments (the "riskier" proteins).

The concern you raise is valid. If banks are incentivized to hold predominantly low-risk assets to meet capital requirements, it can lead to an allocation of capital that favors safe but potentially lower-yielding investments. This could result in lower economic growth and innovation, as resources are not efficiently allocated to more productive uses. It may also hinder the growth of small businesses and entrepreneurship, which are often seen as the "muscles" of the economy.

Regulators and policymakers are aware of this issue, and there have been ongoing discussions and reforms aimed at addressing it. The challenge lies in striking a balance between financial stability (ensuring banks have sufficient capital to weather crises) and economic growth (encouraging investment in riskier but potentially more productive ventures). Reforms may include adjusting risk weights, enhancing transparency in risk assessment, and encouraging banks to diversify their portfolios.

In summary, your analogy highlights a genuine concern in the financial regulatory framework. Striking the right balance between safety and growth in the banking sector is a complex task, and policymakers continually strive to adapt regulations to ensure a healthy and balanced economy.


I asked OpenAI:

"Would not such an obese economy pose a serious danger to our bank systems? 
If, so does it illustrate an unexpected consequence of regulatory risk-aversion, or one that should have been expected?"

OpenAI answered: 

"An "obese" economy, as you described it, with an overemphasis on safer but lower-yielding assets, can pose risks to the banking system and the broader economy. This situation can be a consequence of regulatory risk-aversion, and it highlights some of the unintended consequences that can arise from well-intentioned regulations.

Here's how such an obese economy can pose dangers to the banking system:

1. Reduced Profitability: When banks are primarily incentivized to hold low-risk assets to meet capital requirements, their profitability may be constrained. Safer assets typically yield lower returns, which can reduce banks' ability to generate profits. Over time, this may limit their capacity to absorb losses and invest in other aspects of their operations.

2. Inefficiency: An economy overly reliant on low-risk assets may become less efficient. Capital that could be allocated to more productive, growth-oriented ventures, such as loans to small businesses or innovative startups, may instead be tied up in low-yield, low-risk assets like government bonds. This inefficiency can hinder overall economic growth.

3. Systemic Risk: Paradoxically, excessive risk-aversion by banks and regulators can lead to systemic risk. If banks collectively focus too much on the same safe assets, they may become highly correlated in their behavior. This means that when a downturn does occur (even if it's not directly related to the safe assets), the entire banking system could be vulnerable, potentially leading to a systemic crisis.

4. Dampened Innovation: An overly conservative approach to lending can stifle innovation and entrepreneurship, as it becomes more challenging for riskier ventures to secure funding. This can hinder long-term economic growth and job creation.

Should these dangers have been expected? To some extent, yes. Regulatory risk-aversion, while designed to enhance financial stability, has long been recognized as having the potential to create unintended consequences. Economists and policymakers are aware of the trade-offs involved in financial regulation. They understand that striking the right balance between risk mitigation and economic growth is challenging.

Over time, regulations have evolved in response to such concerns. Regulatory agencies have made efforts to fine-tune risk-weighted capital requirements, promote diversification of bank portfolios, and encourage lending to key sectors like small businesses.

In conclusion, the dangers posed by an obese economy, resulting from excessive risk-aversion in regulations, are recognized by experts in finance and economics. They illustrate the complexity of regulatory decision-making and the need for ongoing evaluation and adjustment of regulatory frameworks to achieve both financial stability and economic growth.


I asked OpenAI:

"One last question: Do you think these dietary instructions the regulators prescribed for our banks, show sufficient considerations to the economy our children and grandchildren will have to live with?"

OpenAI answered: 

"The regulatory decisions made by policymakers and regulators in the financial sector are intended to strike a balance between short-term financial stability and the long-term health of the economy. However, predicting the exact economic conditions that our children and grandchildren will face in the future is extremely challenging, and regulatory decisions are often made with the best information available at the time.

Here are some considerations regarding the regulatory framework and its implications for future generations:

1. Financial Stability: Ensuring the stability of the financial system is a primary concern for regulators. They aim to prevent the types of financial crises that can have severe and lasting effects on the economy. This focus on stability is intended to create a more secure foundation upon which future economic growth can be built.

2. Balancing Risk and Growth: As discussed earlier, regulators must strike a balance between risk mitigation and economic growth. The choices made today can influence the availability of credit, economic innovation, and entrepreneurial opportunities for future generations.

3. Adaptability: Regulatory frameworks should ideally be adaptable to changing economic conditions. Policymakers recognize that the economic landscape evolves, and regulations may need to be adjusted to meet new challenges and opportunities.

4. Long-Term Impact Assessment: Regulatory decisions should ideally consider their potential long-term effects on economic sustainability, job creation, and innovation. However, predicting the precise long-term consequences of regulatory actions can be difficult.

5. Interconnected Global Economy: Today's economy is highly interconnected on a global scale. Decisions made by one country's regulators can have ripple effects worldwide. Regulators often need to consider the global implications of their actions, as future generations will inherit an increasingly interconnected global economy.

In summary, regulatory decisions are typically made with the aim of balancing immediate financial stability with the long-term health of the economy. However, predicting the exact economic landscape that future generations will face is challenging. It's essential for policymakers and regulators to be mindful of the potential long-term consequences of their actions and to maintain a dynamic and adaptable approach to regulation to ensure the best outcomes for future generations. Additionally, policymakers often seek input from economists, experts, and the public to make informed decisions that consider the interests of current and future generations."

Thanks!

"You're welcome! If you have any more questions in the future or need further information, feel free to reach out. Have a great day!"

Note: The answers are copied exactly from those given to me by OpenAI

Me at the World Bank, 2003: The financial sector’s role, the reason why it is granted a license to operate, is to assist society in promoting economic growth by stimulating savings, efficiently allocating financial resources satisfying credit needs and creating opportunities for wealth distribution.

PS.The sugar high is all fun until the resulting sugar crash affects the quality of your day. The term refers to the sudden drop in energy levels after consuming a large amount of carbohydrates. It causes symptoms that can disrupt productivity and energy levels.


PS. In Martin Wolf’s Economic Forum in October 2009, I wrote: “Please free us from imprudent risk-aversion and give us some prudent risk-taking

PS. My 2019 letter to the Financial Stability Board (FSB)


PS. Some of my many previous references to carbs v.s proteins in banking,



Saturday, September 2, 2023

It takes two to tango, and it takes two to play the game of bank capital requirements

Sir, I refer to “On Wall Street Truth must be told about bank cap­ital rules plans” Sheila Bair, FT September 2, 2023.

Way back, before 1988, when there was one bank capital/equity requirement against all assets, a leverage ratio, the game bankers played was easier than Ludo. It was all about hiding some assets away from their balance sheet, and of finding more capital on it than what they really had.

After 1988, with the introduction of the Basel Committee’s risk weighted bank capital requirements, Basel I, and especially with Basel II which assigned so much importance to credit rating agencies, the game became dramatically more complicated. Out went the type of old time basically loan officer bankers, and in came the dangerously creative banking financial engineers. A game much more like chess has ensued. 

The steps in this Bank Capital Requirements are becoming ever more complicated. If you doubt it just consider that though Basel I had 30 pages, the recent Fed FDIC OCC July 2023 request for just comments on proposed rules to strengthen capital requirements for large banks has 1.087 pages.

Sheila Bair, expressing a con­cern about the complexity of current pro­pos­als ends with “Hopefully, reg­u­lat­ors will find ways to sim­plify the rules and make them more understandable to the pub­lic.”

Sir, from my thousands of letters to you over the last two decades, you know I would like the bank capital requirements to become a game of Ludo again. I might have given you hundred arguments for scrapping the risk weighted capital requirement, Please let me just list here the most fundamental ones.

Lower risk weights for government debt de facto imply that bureaucrats and politicians know better what to do with credit for which repayment they’re not personally responsible for than e.g., small businesses and entrepreneurs. (Long term US treasuries still have a 0% risk weight) I strongly object to that. Sir, don’t you?

Lower capital requirements against residential mortgages de facto imply that financing houses is more important for the economy than lending to small businesses and entrepreneurs. I object to that. Sir, don’t you?

Basing the risk weights on perceived risk and not conditioned to how bankers perceive risks; and on that what’s perceived as risky is more dangerous to bank systems than what’s perceived as safe is clear evidence that the regulators work from their desk and have never walked on main-street. Just think of Mark Twain supposedly saying: “A banker is a fellow who wants to lend you the umbrella when the sun shines and wants it back when it rains”, and then consider the risk weights of 20% for AAA to AA rated assets and 150% for the below BB- rated ones. It’s sheer hubristic lunacy. Sir, don’t you agree?

And honestly, in an uncertain world where so many unexpected events can become dangerous, how on earth, even with “a thoughtful multi year pro­cess” can regulators still base their capital requirements so much on the certainty of perceived risk? In “Against the Gods” Peter L. Bernstein writes that the boundary between the modern times and the past is the mastery of risk, since for those who believe that everything was in God’s hands, risk management, probability, and statistics, must have seemed quite irrelevant. Sir, today, I cannot but speculate on whether we, when managing risk, have not left out God’s hand just a little bit too much.

Finally, as I have tweeted or X-ed repeatedly: “When times are good, and bank capital buffers should be built-up, regulators allow banks to hold little equity, pay dividends and do buybacks so, when times turn bad, banks stand naked, when we need them the most, when the hardest to raise new bank equity.”

PS. Sheila Bair writes about “massive mort­gage defaults dur­ing the fin­an­cial crisis”. Let’s not ignore that crisis was caused not really by mortgages but by the AAA to AA rated securities backed with mortgages to the subprime sector and which therefore were assigned a mind-blowing low 20% risk weight.

@PerKurowski

Tuesday, August 22, 2023

A letter in Washington Post: "The economic revolution"


In his Aug. 17 op-ed, “Team Biden wants an economic revolution,” Robert B. Zoellick wrote, “National security adviser Jake Sullivan has argued that reliance on private businesses and markets has resulted in major economic and social failures. The Biden administration instead relies on state direction in areas of the economy far beyond infrastructure, R&D and education.” That might be so, but such a revolution has already been going on for 35 years.

Former Federal Reserve chairman Paul A. Volcker, in his 2018 memoir, “Keeping at It,” co-written with Christine Harper, wrote that assets for which bank capital and equity requirements were nonexistent were what had the most political support, sovereign debt. A leverage ratio discouraged holding low-return government securities.

That referred to Basel I’s 1988 risk-weighted bank capital requirements with decreed risk weights: zero percent federal government, 100 percent taxpayers. If that’s not an economic revolution, what is?

Independent of Treasurys being safer than other bank assets, those risk weights de facto imply that American bureaucrats know better what to do with credit for which repayment they’re not personally responsible than, e.g., American small businesses and entrepreneurs.

What would the Founding Fathers think?

Per Kurowski, Rockville

“Assets for which bank capital and equity requirements were nonexistent were what had the most political support, sovereign debt.”
If that’s not a valiant, courageous and honorable confession by Paul Volcker what is?
Thanks Washington Post for not ignoring it.




 My other letters published in the Washington Post related to this issue: