I warned many about the coming crisis, long before it happened, on many occasions and in many places, even at the World Bank. The regulators did not want to listen and that´s ok, it usually happens, but what's not ok, is that they still do not seem to want to hear it. “We can easily forgive a child who is afraid of the dark; the real tragedy of life is when men are afraid of the light.” (Plato: 427 BC – 347 BC)
"When regulators, based on believing they know enough about the risks in the banking systems, they impose risk weighted bank capital requirements, does that not suggest a certain dose of hubris?"
OpenAI answered:
"Yes, the imposition of risk-weighted bank capital requirements by regulators based on the belief that they possess sufficient knowledge about the risks in the banking system can indeed suggest a certain level of hubris. Hubris refers to excessive pride, overconfidence, or arrogance, often accompanied by a belief in one's superiority or infallibility.
In the context you described, if regulators firmly believe they possess a comprehensive understanding of the risks and subsequently impose risk-weighted capital requirements without considering alternative perspectives or acknowledging potential limitations in their knowledge, it can indicate a degree of hubris. It suggests they may be overly confident in their ability to accurately assess risks and determine appropriate capital requirements.
Hubris can be problematic because it can lead to the neglect of important information, blind spots in decision-making, and an underestimation of the complexity and uncertainty inherent in financial systems. It is generally considered more prudent and responsible for regulators to approach their decision-making processes with a certain level of humility, acknowledging the limitations of their knowledge and seeking input from various sources to ensure a well-rounded understanding of risks.
However, it's important to note that not all instances of confidence or assertiveness in regulatory actions necessarily imply hubris. Assessing hubris requires a more comprehensive understanding of the specific behaviors, attitudes, and intentions of the regulators involved."
I asked OpenAI:
"If with some hubris regulators believe they know enough about risks, so as with risk weighted bank capital requirements risk distort the allocation of credit, something which could be dangerous, could that be considered as professionally unethical?"
OpenAI answered:
"Determining whether a specific action is professionally unethical requires a nuanced assessment of the context and motivations involved. However, I can provide some general insights that may help you evaluate the situation you described.
If regulators, driven by hubris, impose risk-weighted bank capital requirements that distort the allocation of credit and potentially create dangerous consequences, it could be viewed as a professional ethical concern for a few reasons:
1. Lack of competence: If regulators believe they possess comprehensive knowledge about risks but their actions lead to distorted credit allocation and potential dangers, it suggests a lack of competence. Ethical responsibility entails recognizing one's limitations and seeking input from diverse perspectives to make informed decisions.
2. Neglecting public interest: Regulators have a responsibility to act in the public interest and ensure the stability and integrity of the financial system. If they knowingly implement policies that distort credit allocation and endanger the system, it would be ethically problematic as they are neglecting their primary duty.
3. Disregard for consequences: Ethical decision-making involves considering the potential consequences of one's actions. If regulators prioritize their own beliefs over the potential risks and adverse outcomes, it reflects a disregard for the consequences and a failure to uphold ethical principles.
However, it's important to note that assessing professional ethics often requires a deeper understanding of the specific circumstances, motivations, and intentions involved. Additionally, regulatory decisions can be influenced by various factors, such as political pressures or differing interpretations of risks. Therefore, a comprehensive analysis of the situation is necessary to form a definitive judgment on whether the regulators' actions are professionally unethical."
I asked OpenAI:
"When regulators imposed risk weighted bank capital requirements, as if they knew sufficiently about risks in banking so as to risk distorting the allocation of bank credit, if hubris did not play a role, what other factors could be present?"
OpenAI answered:
"While hubris can be one factor that may lead regulators to impose risk-weighted bank capital requirements without acknowledging the potential for distorting credit allocation, there could be other factors at play as well. Here are a few possibilities:
1. Limited information: Regulators might be operating based on the information available to them at the time, which may be incomplete or imperfect. They may genuinely believe they have sufficient knowledge about risks in the banking system, but due to limited data or analysis, they may overlook potential consequences and unintended effects on credit allocation.
2. Regulatory capture: In some cases, regulators may be influenced by industry stakeholders or special interest groups, leading them to implement policies that favor certain institutions or sectors. This can result in regulations that prioritize the interests of specific actors over broader systemic considerations, potentially distorting credit allocation.
3. Political considerations: Regulatory decisions can be influenced by political pressures or considerations. Regulators may face pressure to take action or appear proactive, leading them to implement capital requirements without fully considering the potential impact on credit allocation. Political motivations can sometimes override a thorough and objective assessment of risks.
4. Different interpretations of risks: Regulators may genuinely believe that their understanding of risks is accurate, but their perspectives may differ from alternative viewpoints or dissenting opinions. Differing interpretations of risks can lead to varying approaches to capital requirements, potentially resulting in unintended consequences for credit allocation.
5. Institutional constraints: Regulators operate within institutional frameworks that can shape their decision-making. These frameworks may have inherent biases or limitations that influence the design and implementation of capital requirements, which could inadvertently distort credit allocation.
It's worth noting that these factors are not mutually exclusive, and multiple factors may be present simultaneously. Understanding the specific circumstances, motivations, and dynamics surrounding regulatory decisions is crucial for a comprehensive analysis of the factors involved."
I asked OpenAI:
"Is it inconceivable that, when imposing risk weighted bank capital requirements, the regulators did not understand, did not consider or did not care about how that could distort the allocation of bank credit?"
OpenAI answered:
"While it is difficult to definitively determine the intentions or motivations of regulators, it is not inconceivable that they may not fully understand, consider, or care about how risk-weighted bank capital requirements could distort the allocation of bank credit. Regulatory decision-making processes can be influenced by various factors, and regulators may prioritize certain objectives or overlook potential unintended consequences.
Here are some potential reasons why regulators might not fully understand, consider, or care about the potential distortion of credit allocation:
1. Knowledge limitations:Regulators may lack a comprehensive understanding of the complex dynamics of credit allocation within the banking system. They may have a limited perspective on the potential impacts of their policies and may not fully grasp the intricacies of how risk-weighted capital requirements could affect credit allocation.
2. Incomplete analysis: Regulators might not have conducted a thorough analysis of the potential consequences of risk-weighted capital requirements on credit allocation. This could be due to resource constraints, time limitations, or a failure to consider alternative viewpoints.
3. Other priorities: Regulators may prioritize specific objectives, such as financial stability or capital adequacy, over the potential distortion of credit allocation. They may be more focused on mitigating risks to the overall system rather than considering the potential effects on individual credit allocation.
4. Industry influence: Regulators may face pressure or influence from industry stakeholders or special interest groups. These external influences can shape regulatory decisions and potentially divert attention from considering the distortion of credit allocation.
5. Lack of accountability:Regulatory bodies may operate within a framework that lacks sufficient accountability mechanisms. This can result in regulators not feeling a strong obligation to fully understand or consider the potential consequences of their actions.
It is important to note that the above reasons are speculative and should not be assumed to apply to all regulators in all circumstances. Regulatory decision-making is a complex process influenced by multiple factors, and individual regulators may vary in their level of understanding, consideration, and care regarding the potential distortion of credit allocation caused by risk-weighted bank capital requirements."
Note: The answers are copied exactly from those given to me by OpenAI
The less the perceived risk of default is, and the higher the leverage allowed, the greater the systemic risk.
My huge problem!
Q. "If Kurowski is right, why are his arguments so ignored? A. If I had argued that the regulators were 5 to 10 degrees wrong, I would be recognized, but since I am arguing they are 150 to 180 degrees wrong, I must be ignored.
The deafening noise of the Agendas
The fundamental reasons why it is so hard to advance the otherwise so easy explainable truth of this financial crisis, is because of the deafening noise of the Agendas…
On one side, we have the "progressives" who want to put all the blame on capitalistic banksters, and, on the other, the "conservatives" who want to blame the socialistic government sponsored enterprises GSEs of Fanny Mae and Freddy Mac.
For any of both sides accepting the fact that it was mostly a regulatory failure of monstrous proportions would seemingly be a highly inconvenient truth that would not help them to advance their respective agendas.
What is more dangerous in a systemic way, that which is perceived as risky or that which is perceived as not risky? Right!
How can the Basel Committee be so dumb?
Systemic risks is about something that can become as big so as to threaten the system… and our bank regulators in the Basel Committee are incapable or unwilling to understand that what has the largest possibilities of growing as big so as to threaten the system is what is perceived as having little or no risk, not what is perceived as risky… which makes their first and really only pillar of their regulations, that of capital requirements of banks that are lower when perceived risks are lower… so utterly dumb!
We must stop our gullible and naive financial regulators from believing in never-risk-land.
The stuff that bonuses are made of
Whenever a credit rating corresponds exactly to real underlying risk neither borrower nor lender loses but the intermediary cannot make profits… it is only when the credit ratings are too high or too low that those margins that can generate that profitable stuff that bonuses are paid for exist.
What were they thinking?
The default of a debtor is about the most common, natural and even benign risk in capitalism, so it is so hard to really get a grip on what was going around in the minds of the regulators when they decided to construe capital requirements for banks based exclusively on discriminating against that risk as it was perceived by some credit rating agencies.
Day by the day it is becoming more relevant... scary!
http://theaaa-bomb.blogspot.com
This I published in November 1999... Read it!
The possible Big Bang that scares me the most is the one that could happen the day those genius bank regulators in Basel, playing Gods, manage to introduce a systemic error in the financial system, which will cause the collapse of the OWB (the only bank in the world) or of the last financial dinosaur that survives at that moment.
Currently market forces favors the larger the entity is, be it banks, law firms, auditing firms, brokers, etc. Perhaps one of the things that the authorities could do, in order to diversify risks, is to create a tax on size.”
This I wrote, October 2004, as an Executive Director of the World Bank
We believe that much of the world’s financial markets are currently being dangerously overstretched through an exaggerated reliance on intrinsically weak financial models that are based on very short series of statistical evidence and very doubtful volatility assumptions.
Regulatory hubris
In a world with so many different risks, some naïve gullible and outright stupid regulators thought everything would be fine and dandy if they just had some few credit rating agencies determine default risks and then gave the banks great incentives, by means of different capital requirements, to follow those credit risk opinions.
On bs.
When experts bs..t the world that’s bad news, but when experts allowed themselves to be bs..ted by bs..ing experts that’s is when the world goes really bad.
This crisis resulted directly from the Potemkin credit ratings the market produced to satisfy the demand for AAAs created by the regulators.
Lower the capital requirements for banks on:
the loans to those who had nothing to do with creating the current AAA crisis, like small businesses and entrepreneurs but are anyhow the ones which most suffer the current scarcity of bank capital
My most current proposal on the regulatory reform for banks
They were supposed to teach the world prudent risk-taking and instead they taught it imprudent risk-aversion.
The deal!
This was the deal! If you convinced risky and broke Joe to take a $300.000 mortgage at 11 percent for 30 years and then, with more than a little help from the credit rating agencies, you could convince risk-adverse Fred that this mortgage, repackaged in a securitized version, and rated AAA, was so safe that a six percent return was quite adequate, then you could sell Fred the mortgage for $510.000. This would allow you and your partners in the set-up, to pocket a tidy profit of $210.000
Calling it quits?
A world that taxes risk-taking and subsidizes risk adverseness is a world that seems to want to lie down and die
Let´s neutralize the wimps!
If we are to keep on using Basel methodology for establishing the minimum capital requirements for banks, beside better risk weights, we must demand it also uses “societal purpose” weights.
What other word could describe a bank regulatory system designed exclusively to avoid bank crisis as if that is the only purpose of banking. You might just as well order the kids to stay in bed all life so as to diminish the risk of them tripping.
The minimum capital requirements of Basel that are based on default risks as measured by the credit rating agency amount to a dangerous tax on the risk, the oxygen of development.
Blindly focusing on default and leaving out any consideration that a credit with a low default risk but for a totally useless or perhaps even an environmentally dangerous purpose is much more risky for the society than a credit with a higher default risk destined to trying to help create decent jobs or diminish an environmental threat, is just silly.
But do I have to be disrespectful and call them silly? Well, individually perhaps they are not, but, as a group, bank regulators are so full of hot air that someone has to help them to puncture their cocoon balloon and let them out.
Breathe!
I’m going to third-pillar what?
By now the desperate bank regulators are throwing at us the third pillar of their Basel regulations which implies the need that we ourselves privately monitor our banks. Great, in my country, a couple of decades ago, I did just that and had a fairly good grip on whom of my banker neighbors were good bankers and whom to look out for.
But sincerely what am I supposed to do know when about 50 per cent of the retail deposits in my country are in hand of international banks (Spain) and that might be losing their shirt making investments in subprime mortgages in California?
Tragedy!
It is very sad when a developed nation decides making risk-adverseness the primary goal of their banking system and places itself voluntarily on the way down but it is a real tragedy when developing countries copycats it and fall into the trap of calling it quits.
Development rating agencies?
A bank should be more than a mattress!
When considering the role of the commercial banks should not the developing countries use development rating agencies instead of credit rating agencies?
Clearly more important than defending what we have is defending what we want to have.
What do we want from our banks?
Over the last two decades we have seen hundreds if not thousands of research papers, seminars, workshops conferences analyzing how to exorcize the risks out of banking; and if in that sense the bank regulation coming out from Basel was doing its job; and centred around words like soundness, stability, solvency, safeness and other synonyms. Not one of them discussed how the commercial banks were performing their other two traditional functions, namely to help to generate that economic growth that leads to the creation of decent jobs and the distribution of the financial resources into the hands of those capable of doing the most with it.
At this moment when we are suddenly faced with the possibilities that all the bank regulator’s risk adverseness might anyhow have come to naught, before digging deeper in the hole where we find ourselves fighting the risks, is it not time to take a step back and discuss again what it is we really want our commercial banks to do for us? I mean, if it is only to act as a safe mattress for our retail deposits then it would seem that could be taken cared of by authorizing them only to lend to the lender of last resort; but which of course would leave us with what to do about the growth and the distribution of opportunities.
We are suffering from more and more answers than questions begging for them, and so I work on the latter.
Read it all in my one and only book!"Voice and Noise"
Pssst... so few have read this book so it is slowly turning into a collector item (I do not say a "cult"... yet) and so you might benefit from getting your very own copy now.