Saturday, June 24, 2023
I asked OpenAI:
"The world always lives uncertain times, when pandemics, war, inflation and so many other unexpected events can cause havoc, and when risks can so easily have been misperceived.
Nonetheless current bank regulators based most of their bank capital requirements on the certainty of perceived credit risk.
And that they do even though all large bank exposures that ended up causing major bank crises, were built-up with assets that, from a credit risk point of view, were perceived as safe.
Can you explain to us regulators’ rationale for doing so?
And excuse me for insisting: Assigning so much validity to perceived credit risk, augmented by having some few human fallible credit rating agencies much deciding what’s risky and what’s safe; has that not introduced a way too dangerous systemic risk in our financial systems?"
OpenAI answered:
"The rationale behind current bank regulators basing their capital requirements on perceived credit risk is rooted in the belief that it is essential to allocate sufficient capital to cover potential losses arising from credit exposures. Credit risk refers to the risk of borrowers defaulting on their obligations, leading to losses for the banks.
Historically, regulators have focused on credit risk because it has been one of the most significant sources of risk for banks. By assessing the creditworthiness of borrowers and assigning risk ratings to various assets, regulators aim to ensure that banks have enough capital to absorb potential losses. This approach is based on the assumption that higher-rated or perceived safer assets are less likely to default, while lower-rated or riskier assets carry a higher probability of default.
The reliance on credit ratings agencies can be attributed to their expertise in evaluating credit risk. These agencies assess the creditworthiness of issuers and provide ratings that reflect the agencies' assessment of the likelihood of default. Regulators have traditionally used these ratings as a benchmark for determining the riskiness of assets.
However, it is important to acknowledge that the reliance on perceived credit risk and credit rating agencies has its limitations. The global financial crisis of 2008 revealed some of these shortcomings when highly rated mortgage-backed securities experienced significant defaults. This event highlighted the potential for misperception of risk and the failure of credit rating agencies to accurately assess the riskiness of certain assets.
The introduction of a systemic risk in financial systems due to the reliance on perceived credit risk is a valid concern. It is challenging to accurately predict and measure systemic risks, especially during times of uncertainty and rapid market changes. The interconnectedness of financial institutions and the reliance on similar risk assessment models can amplify the impact of misjudged risk perceptions.
In recent years, regulators have recognized the need to address these shortcomings and enhance the stability of the financial system. Efforts have been made to strengthen capital requirements, improve risk management practices, and reduce the overreliance on credit ratings. The Basel III framework, for example, incorporates a broader range of risk factors and encourages banks to use their internal models to assess risk.
While the financial system continues to evolve, regulators are working towards developing more comprehensive approaches to risk management. This includes considering a wider range of risks beyond credit risk, such as liquidity risk, operational risk, and systemic risk, to build a more resilient financial system that can better withstand unexpected events and crises."
I asked OpenAI:
"Since banks might have a vested interest in reducing its capital requirements, for the purpose of calculating the risk weighted bank capital, does it make any sense to allow banks to use their internal models to assess risk?"
OpenAI answered:
"The use of internal models by banks to assess risk is a topic of ongoing debate and consideration among regulators and experts in the financial industry. There are arguments both in favor of and against allowing banks to use their internal models for risk assessment.
One of the key arguments in favor of internal models is that they can potentially capture the specific risk profile and characteristics of individual banks more accurately than a standardized approach. Banks have access to extensive data and sophisticated modeling techniques, which they argue allows them to better estimate the risks associated with their portfolios. Proponents argue that this can lead to a more accurate assessment of risk and better alignment of capital requirements with the actual risk exposure of each bank.
However, there are also valid concerns associated with the use of internal models. Critics argue that banks might have an incentive to manipulate their models or underestimate risk to reduce their capital requirements. This behavior was observed in the past, where some banks used overly optimistic assumptions and models that failed to capture the true risks, contributing to the financial crisis.
To address these concerns, regulators have implemented rigorous standards and requirements for the use of internal models. They impose strict validation processes, regular audits, and requirements for banks to hold sufficient data to support their models. Regulators also conduct their own assessments and exercises to ensure the models are robust and the risks are adequately captured.
Additionally, regulators often require a combination of approaches, where banks use both internal models and standardized approaches to assess risk. This helps strike a balance between the advantages of internal models and the need for a standardized and consistent framework across the industry. It allows regulators to compare and validate the results obtained from internal models and provides a safeguard against potential manipulation.
Overall, the use of internal models is a complex issue with pros and cons. While they can potentially provide more accurate risk assessments, it is crucial for regulators to establish stringent oversight and ensure that banks are using these models responsibly. Striking the right balance between risk sensitivity and robust regulatory oversight remains a continuous challenge for regulators."
I asked OpenAI:
"When it comes to determine how much more capital a bank would have to hold against an asset, on the margin, there were it most counts when taking a decision whether to hold the asset or not, is it not the risk weighted bank capital requirements that defines that?"
OpenAI answered:
"Yes, the risk-weighted bank capital requirements play a crucial role in determining how much capital a bank needs to hold against its assets. The risk-weighted capital framework assigns different risk weights to various types of assets based on their perceived riskiness. These risk weights reflect the probability of default and potential loss associated with each asset class.
The risk-weighted capital requirements are typically expressed as a percentage of the risk-weighted assets (RWA). To calculate the RWA, banks assign risk weights to their assets based on the prescribed risk weightings set by regulatory authorities. The risk weights are generally higher for assets considered riskier and lower for assets considered safer.
By applying risk weights to their assets, banks determine the amount of capital they need to set aside as a buffer to absorb potential losses. The higher the risk weight assigned to an asset, the more capital the bank is required to hold against it.
This risk-based approach aims to ensure that banks hold sufficient capital to cover the potential losses associated with their assets. It provides an incentive for banks to assess and differentiate the risk levels of their assets accurately. Assets perceived as safer and having lower risk weights require less capital, while riskier assets necessitate higher capital allocations.
However, it's important to note that the risk-weighted capital requirements have been subject to criticism, particularly regarding their effectiveness and potential for manipulation. Critics argue that the risk weights assigned to assets may not always reflect their true riskiness, leading to potential mispricing of risk. The reliance on credit rating agencies for determining risk weights has also been seen as problematic, given the issues highlighted during the financial crisis.
To address these concerns, regulatory bodies have been working on improving the risk-weighted capital framework. Revisions such as the Basel III framework have introduced more sophisticated risk measurement techniques, including the use of internal models, stress testing, and a focus on capturing systemic risks. These efforts aim to enhance the accuracy of risk-weighted capital requirements and improve the resilience of banks in the face of potential financial shocks.
Overall, while risk-weighted capital requirements are an important tool for determining capital adequacy, ongoing refinements and scrutiny are necessary to ensure that they effectively reflect the underlying risks and contribute to the stability of the financial system."
Note: The answers are copied exactly from those given to me by OpenAI
Here, a comment I made at the World Bank in 2003: “Nowadays, when information is just too voluminous and fast to handle, market or authorities have decided to delegate the evaluation of it into the hands of much fewer players such as the credit rating agencies. This will, almost by definition, introduce systemic risks in the market.”