Bank regulators, go west!

Sir, I refer to John Dearie’s “Go west, Federal Reserve” Washington Post December 5, 2024.

In his book "Money: Whence it came, where it went” (1975), John Kenneth Galbraith discusses banks and banking issues which, because of the risk weighted bank capital/equity requirements, is very timely today.

In one section, he addresses the function of banks in the creation of wealth. Galbraith speculates on the fact that one of the basic fundamentals of the accelerated growth experienced in the western and south-western parts of the United States during the past century was the existence of an aggressive banking sector working in a relatively unregulated environment. He writes:

“Banks opened and closed doors and bankruptcies were frequent, but as a consequence of agile and flexible credit policies, even the banks that failed left a wake of development in their passing.”

And in a second section, Galbraith refers to the banks’ function of democratization of capital as they allow entities with initiative, ideas, and will to work although they initially lack the resources to participate in the region’s economic activity. In this case, Galbraith states that as the regulations affecting the activities of the banking sector are increased, the possibilities of this democratization of capital would decrease. There is obviously a risk in lending to the poor.

Sir, is that all not a good reason why bank regulators should also have a look at how the west was won?

PS. Sir, that book set me up for an already over twenty-five years fight against the Basel Committee’s risk weighted bank capital/equity requirements.

https://subprimeregulations.blogspot.com/1997/06/puritanism-in-banking.html

#AI ChatGPT: At what point can the allocation of bank credit to the economy be more important than the safety of banks?

I asked ChatGPT:

John Kenneth Galbraith in “Money: Whence it came where it went” 1975, wrote:

“For the new parts of the country [USA’s West] … there was the right to create banks at will and therewith the notes and deposits that resulted from their loans…[if] the bank failed…someone was left holding the worthless notes… but some borrowers from this bank were now in business... [jobs created] … The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done”

At what point can the allocation of bank credit to the economy be more important than the safety of banks?"

ChatGPT answered:

"The allocation of bank credit to the economy and the safety of banks are both important considerations in the functioning of a financial system. However, the relative importance of each can vary depending on the specific circumstances and goals of the economy.

In certain situations, particularly during periods of economic expansion or in developing regions, the allocation of bank credit to the economy can be prioritized over the safety of banks to foster economic growth and job creation. This is often seen in frontier or emerging economies where access to credit is crucial for entrepreneurship, investment, and the development of new industries.

In the example you mentioned, John Kenneth Galbraith highlighted the role of banks in supporting economic growth in the new parts of the country during the westward expansion in the United States. The more relaxed approach to banking and credit creation allowed for greater access to funds, which facilitated economic activity and job creation, even though it came with the risk of bank failures and some individuals being left with worthless notes.

However, it is important to note that prioritizing credit allocation over bank safety carries inherent risks. Without appropriate regulatory measures and prudential safeguards, excessive risk-taking by banks can lead to financial instability and systemic crises. History has shown that a lack of oversight and inadequate risk management in the financial sector can have severe consequences, as witnessed during the global financial crisis of 2008.

Therefore, finding the right balance between allocating credit to the economy and ensuring the safety and stability of banks is crucial. Regulatory frameworks are designed to strike this balance by setting standards for capital adequacy, risk management, and oversight to mitigate systemic risks and protect depositors.

Ultimately, the allocation of bank credit and the safety of banks are interconnected aspects of a well-functioning financial system. While promoting economic growth and providing credit access is important, it should be done in a manner that also ensures the long-term stability and resilience of the banking sector."

Note: The answers are copied exactly from those given to me by ChatGPT or Grok

PS. "History has shown that a lack of oversight and inadequate risk management in the financial sector can have severe consequences, as witnessed during the global financial crisis of 2008." Here my questions to AI on that.

Here my many other questions to ChatGPT – Grok on bank regulations

Two questions to America’s economists, and one for its lawyers.

Bear with me.

Let me start with two passages from John Kenneth Galbraith’s “Money: Whence it came where it went” 1975.

First: “For the new parts of the country [USA’s West] … there was the right to create banks at will and therewith the notes and deposits that resulted from their loans…[if] the bank failed…someone was left holding the worthless notes… but some borrowers from this bank were now in business... [jobs created]

It was an arrangement which reputable bankers and merchants in the East viewed with extreme distaste… Men of economic wisdom, then as later expressing the views of the reputable business community, spoke of the anarchy of unstable banking… The men of wisdom missed the point. The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done…. what is called sound economics is very often what mirrors the needs of the respectfully affluent.”

Second: “The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is… Bad banks, unlike good, loaned to the poor risk, which is another name for the poor man.”

Then, in Steven Solomon's “The Confidence Game” we read:

“On September 2, 1986, the fine cutlery was laid once again at the Bank of England governor’s official residence at New Change… The occasion was an impromptu visit from Paul Volcker… When the Fed chairman sat down with Governor Robin Leigh-Pemberton and three senior BoE officials, the topic he raised was bank capital…” 

Finally in his autobiography “Keeping at it” of 2018, penned together with Christine Harper, Paul Volcker wrote:

“The assets assigned the lowest risk, for which capital requirements were therefore low or nonexistent, were those that had the most political support: sovereign credits and home mortgages. Ironically, losses on those two types of assets would fuel the global crisis in 2008 and a subsequent European crisis in 2011. The American “overall leverage” approach had a disadvantage as well in the eyes of shareholders and executives focused on return on capital; it seemed to discourage holdings of the safest assets, in particular low-return US government securities."

Thanks!

So, now let me ask America’s economists two questions:

If since its Founding Fathers’ days America’s banks had been regulated so as to finance much more the government and residential mortgages than loans to its small businesses and entrepreneurs, would America be where it is now? 

Knowing that all those excessive bank exposures that have set on major bank crises were always built-up with what was ex ante perceived as very safe, what true precautionary purpose do these regulations serve?

And one question to America’s lawyers:

The risk weighted bank capital requirements with decreed weights of 0% Federal Government 100% - We the People, do they really conform with what 's wanted in the U.S. Constitution?

Where do I come from? 

At the World Bank “Let us not forget that the other side of the Basel [Committee’s regulatory risk weighted capital requirements] coin might be many, many developing opportunities in credit foregone”

As one of the Christian Western World? God make us daring!

As one having a strong opinion? My letter to the Financial Stability Board.

25 years on the issue. My first Op-Ed ever, began with what this post does.

What if in the early 19th century The First Bank of the United States had regulated banks as the Federal Reserve began to do in 1988.

Sir, it is only now I read Steven Pearlstein reviewing Jonathan Levy’s “Age of American Capitalism”, “From commerce to chaos: An economic history of the United States”, Washington Post, June 4, 2021 

It says: “The ‘American system’ … required a new system of credit built around a government-chartered National Bank and government debt”.

That contrasts with John Kenneth Galbraith's: “Banks opened and closed doors and bankruptcies were frequent, but as a consequence of agile and flexible credit policies, even the banks that failed left a wake of development in their passing” “Money” (1975)

Why does not Washington Post invite some prominent financial historians to debate: Where would America be if “The First Bank of the United States” (1791-1811) had imposed bank capital requirements similar to those the Federal Reserve did in 1988? 

What the Fed did was succinctly explained by Paul Volcker in his 2018 autobiography in terms of: “The assets assigned the lowest risk, for which bank capital requirements were therefore low or nonexistent, were those that had the most political support: sovereign credits and home mortgages”. 

Would that not be an important debate that should have been started long ago? 

PS. That quote from Galbraith’s “Money” has a very personal meaning to me. It inspired my very first Op-Ed, 1997 in Caracas Venezuela. 

PS. Steve Pearlstein wrote: “Moral Capitalism: Why Fairness Won’t Make Us Poor”. Since current bank capital requirements, by doubling down on perceived credit risk unfairly decrees that the less creditworthy are also less worthy of credit, he could be interested in what Galbraith, opined in that same “Money”.

“The banks’ function of democratization of capital as they allow entities with initiative, ideas, and will to work although they initially lack the resources to participate in the region’s economic activity. In this second case, Galbraith states that as the regulations affecting the activities of the banking sector are increased, the possibilities of this democratization of capital would decrease. There is obviously a risk in lending to the poor.” 

Indeed, when it comes to access to bank credit, fairness, can only help to make us rich.

Any risk, even if perfectly perceived, causes the wrong answer to it, if excessively considered.

Any risk, even if perfectly perceived, causes the wrong action, if excessively considered.

“A banker is a fellow who lends you his umbrella when the sun is shining, but wants it back the minute it looks to rain” Mark Twain (supposedly)

And Mark Twain is right in that bankers, in general are risk adverse and, when they accept taking some, it is usually in small amounts and against high risk premiums.

And, for around 600 years, bank credit was allocated, usually with a view on the portfolio, based on risk adjusted net interest rates.

But then, in 1988 with Basel I, the Basel Committee introduced (I would say ‘concocted’ is a more precise term) the concept of risk weighted bank capital requirements, based on exactly the same credit risk aversion.

With that the regulators ignored that any risk, even if perfectly perceived, causes the wrong answer to it, if excessively considered.

If Twain was alive he could just as well be writing: “A bank regulator is a fellow that allow banks to hold little capital when the sun is shining, so that banks can pay lots of dividends and buy back lots of stock, but wants banks to hold much more capital, the moment it starts to rain”

And, since then, bank credit is allocated based on risk adjusted returns on equity and, of course, the higher the allowed leverage is the easier it is to obtain a higher return on equity.

John A. Shedd (1859 – 1928) wrote “A ship in harbor is safe, but that is not what ships are for”. And that should also apply to banks. Unfortunately, these capital requirements guarantee that banks stay in safe harbors, running the risk of dangerously overcrowding these, and stay away from the risky oceans, and most certainly not lending enough to those “risky” entrepreneurs and SMEs on which our real economies so much depend.

In his book “Money: Whence it came, where it went” (1975), John Kenneth Galbraith wrote “The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is”

By doubling up on credit risk, the regulators made it so much more difficult for banks to fulfill such important societal function.

And it’s all so much worse. With their much lower bank capital requirements on loans to governments than on loans to citizens, statist/communist/ fascist regulators de facto imply bureaucrats/politicians know better what to do with credit for which repayment they’re not personally responsible for, than e.g. entrepreneurs.

And it is all so stupid. There’s never ever been a major bank crisis caused by the buildup of excessive exposures to what’s perceived as risky, those exposures have always been built up with assets perceived as safe.

The regulators, by basing most of their pro-cyclical bank capital requirements on perceived credit risks; not on misperceived credit risks, or unexpected dangers, like a pandemic, guaranteed all banks now stand there with their pants down. Basel Committee, Good Job!

My 2019 letter to the Financial Stability Board. Received and never answered 

And the Academia, scared of the Banking Inquisition’s High Priests, have kept silence, for decades

Risk-taking is the oxygen of all human development: God make us daring!

Why are not the absurd risk weighted capital requirements for banks more questioned?

John Kenneth Galbraith in his “Money: Whence it came, where it went” (1975), about such silences wrote: 

“If one is pretending to knowledge one does not have, one cannot ask for explanations to support possible objections” 

“What people do not understand, they generally think important. This adds to the prestige and pleasure of the participants” 

"What politicians do not understand, adds to their fear of that in rejecting the resulting action, they may be doing serious damage” 

Upton Sinclair Jr. would have been more direct with his “It is difficult to get a man to understand something, when his salary depends on his not understanding it.” And so, the Academia (also desperately wanting to be counted among the Pigs on Orwell’s farm) kept silence.

PS. "No ordinary man could be such a fool"

PS. An aide memoire on some of the absurdities

“You’re crazy!” That’s what John K. Galbraith would have said; about Basel’s risk weighted capital requirements for banks

I quote from John Kenneth Galbraith’s “Money: Whence it came where it went” 1975.

“For the new parts of the country [USA’s West]… there was the right to create banks at will and therewith the notes and deposits that resulted from their loans…[if] the bank failed…someone was left holding the worthless notes… but some borrowers from this bank were now in business...[jobs created] 

The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is… Bad banks, unlike good, loaned to the poor risk, which is another name for the poor man.”

[But that] was an arrangement which reputable bankers and merchants in the East viewed with extreme distaste… Men of economic wisdom, then as later expressing the views of the reputable business community, spoke of the anarchy of unstable banking… The men of wisdom missed the point. The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done…. what is called sound economics is very often what mirrors the needs of the respectfully affluent.”

So, on behalf of "the men of wisdom", in came the Basel Committee for Banking Supervision. With Basel I 1988, and Basel II 2004, it told bankers that even when they already consider perceived risk when setting interest rates and deciding on the amount of exposures, they also had to consider the perceived risks for how much capital their banks needed to hold.

In other words bank regulators ordered the banking system to double down on ex ante perceived, (decreed or concocted) risks.

For a while, while bankers were exploiting all the opportunities of being able to mind-boggling leverage their equity with what was thought safe (a banker’s wet dream come true) all seemed fine and dandy. 

The immense growth of bank credit (later followed up with QEs) injected tremendous amount of liquidity into the economy… all until some safe havens, like AAA rated securities and Greece, in 2007/08 became dangerously overpopulated and burst.

One should think the “men of wisdom” would have updated their wisdom, but no!

“The risky”, like SMEs and entrepreneurs, still have to compete with “The Safe” for access to bank credit while carrying the burden of generating larger capital requirements for the banks… while “the safe” havens run the risk of being dangerously overpopulated.

I have no doubt John Kenneth Galbraith, if alive, would say: “You’re crazy!”

My 1997, Puritanism in banking

In 2016, Decreed Inequality

Bank regulators should be forced to see “Hell on Wheels” and read John Kenneth Galbraith’s “Money: Whence It Came, Where It Went”

In the TV series Hell on Wheels, its main character, Cullen Bohannon, when asked to testify before the US Senate about all the obvious corruption of Thomas ‘Doc’ Durant, someone absolutely not Bohannon’s friend, someone absolutely not one having been sanctimonious or behaved according to any social norms, repeats, over and over again, to the great chagrin of his interrogators: “The Transcontinental railroad could not have been built without Thomas Durant”

And John Kenneth Galbraith wrote in his “Money: Whence it came where it went” 1975 the following: “For the new parts of the country [USA’s West]… there was the right to create banks at will and therewith the notes and deposits that resulted from their loans…[if] the bank failed…someone was left holding the worthless notes… but some borrowers from this bank were now in business...[jobs created]

It was an arrangement which reputable bankers and merchants in the East viewed with extreme distaste… Men of economic wisdom, then as later expressing the views of the reputable business community, spoke of the anarchy of unstable banking… The men of wisdom missed the point. The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done…. what is called sound economics is very often what mirrors the needs of the respectfully affluent.”

And Galbraith also opined in his book that: “The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is… Bad banks, unlike good, loaned to the poor risk, which is another name for the poor man.”

Therefore I cannot but conclude in that bank regulators should be forced to see “Hell on Wheels” and read John Kenneth Galbraith’s “Money: Whence It Came, Where It Went”. That in order to, hopefully, be able realize that with their risk weighted capital requirements for banks, these will not finance the risky future, but only refinance the safer past and present and, as a result, the economy will stall and fall. 

To add insult to the injury, bank regulators are doing all this in the belief that bank crises result from excessive exposures to what is perceived as risky, which is utter nonsense. Bank crises have always, and will always, result from uncertainties; that which includes unexpected events, like devaluations earthquakes and regulators not knowing what they are doing, criminal behavior and excessive exposures to something ex ante perceived as safe but that ex post turned out to be very risky.

“If you see something, say something”. Someone should run to the Homeland Security of the Home of the Brave and denounce that, most probably, unwittingly; some serious terrorism is taking place by means of dangerously risk adverse faulty bank regulations.

Dumb G20 ministers reiterated in Hangzhou their support of the inept Basel Committee on Banking Supervision (BCBS)

We read in the “G20 Leaders’ Communique Hangzhou Summit”

“We reiterate our support for the work by the Basel Committee on Banking Supervision (BCBS) to finalize the Basel III framework by the end of 2016, without further significantly increasing overall capital requirements across the banking sector, while promoting a level playing field”

Clearly the Ministers did not dare to ask the regulators some minimum minimorum questions like:

What do you believe is the purpose of banks? Should it not have something to do with what like John A Shedd opined: “A ship in harbor is safe, but that is not what ships are for” 

If the purpose of the banks includes that of allocating credit efficiently to the real economy, why then do you distort that with risk weighted capital requirements for banks?

Can you indicate us one single bank crisis derived from excessive exposures to what was perceived as risky when incorporated to the balance sheets of banks? Voltaire said “May God defend me from my friends. I can defend myself from my enemies”. 

So, could that lack of questioning by the ministers be explained by John Kenneth Galbraith’s “If one is pretending to knowledge one does not have, one cannot ask for explanations to support possible objections”?

Frankly, neither Hollywood nor Bollywood, would insist in supporting the work of someone producing such Basel I-II flop, as the 2007/08 crisis and the thereafter continued stagnation evidences.

PS. Here is a short aide memoire on some of the monstrous regulatory mistakes

Decreed Inequality

United Nations - Human Rights: 1986 -Declaration on the Right to Development

The worst inequality is the one that exists in access to opportunities... that one kills hope.

John Kenneth Galbraith wrote: “The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is… Bad banks, unlike good, loaned to the poor risk, which is another name for the poor man.” “Money: Whence it came where it went” 1975.

And that pro-egalitarian function had to face that natural risk aversion of bankers supposedly described by Mark Twain with “A banker is a fellow who wants to lend you the umbrella when the sun shines and wants it back when it rains”.

But since “poor risks” could always offer to pay higher risk premiums than the “safe”, and a dollar paid in interest was a dollar whoever paid it, the “poor risks” of yesterday, quite often got the opportunities for bank credit that, in many cases, transformed these, into the safe of today. 

No longer. In 1988 the Basel Committee, wanting nothing else from banks than for these to be safe, considered that the natural risk aversion of bankers was insufficient and decreed risk weighted bank capital/equity requirements.

With this those perceived as risky and who, because of that, already found it harder to access credit, and when they did have to (naturally) pay higher for it, needed to additionally carry on their shoulders the load of higher bank capital/equity requirements against loans to them, than against assets perceived or decreed as safe e.g., public debt and residential mortgages.

As a result banks could leverage less their capital/equity with loans to those perceived as risky than with loans to those perceived as safe; which meant banks would earn lower expected risk adjusted returns on equity lending to the risky than lending to the safe; which means that dollars paid in net risk adjusted margins on loans by the risky, do not any longer have the same value than the same dollars paid by the safe; which means that no longer have the “risky poor” fair access to bank credit, while that of the “safe rich” is de facto subsidized. 

And this is what I mean with “Decreed Inequality”. How many millions of SMEs and entrepreneurs have not been given the opportunity to advance with credits over the last 25 years as a direct result of it? That would never have resulted in a free market with unregulated banks. And it sadly also means that banks no longer finance the “riskier future” but only refinance the “safer past”.

And in terms of “safer banks” it was and is all for nothing, as major bank crises never ever result from excessive exposures to something perceived ex ante as risky. The 2007/2008-bank crisis would never have happened or, if so, remotely had been of the same scale had banks not been regulated. A free market would never have knowingly allowed banks to leverage 30 to 50 times their equity like regulators did.

Do I think banks should not be regulated? Absolutely not! I am only reminding everyone of the fact that the damage dumb bank regulators can cause with their meddling, by far surpasses anything the free market can do.

And please, please, please, stop talking about "deregulation" in the presence of such an awful and intrusive mis-regulation.The regulators imposed the worst kind of capital controls.

Note: I expressed concerns about the distortions that capital requirements based on perceived risks could cause in my very first Op-ed, back in 1997.

Question: SCOTUS, does such discrimination in the access to bank credit reflect the spirit of the US Constitution?

PS. Through the bathroom window of the Basel Committee for Banking Supervision, and by decreeing the risk weight of the sovereign to be zero percent, while that of the private sector was set at 100 percent, the regulators also smuggled in horrendous statism. 

P.S. Here is a link to a more detailed aide memoire on the horrible mistakes of risk-weighing the capital requirements

PS. Then on top of it all, they top it up with QEs fiscal deficits and other stimulus, that primarily benefit those who already own assets (shares/houses)

PS. Here is a letter on this issue the Washington Post published 

And here is my 2019 letter to the Financial Stability Board

Here is a recent numerical explanation that might better illustrate my point

“delta, vega and curvature risk” Basel Committee’s member understand less and less what they are doing, by the minute

To read the Basel Committee’s “Minimum capital requirements for market risk” of January 2016 is truly mindboggling. Do yourself a favor and just look at the index.

Do those really responsible for what is coming out of the Basel Committee truly understand what is said there?

I'm sure that John Kenneth Galbraith’s “If one is pretending to knowledge, one does not have, one cannot ask for explanations to support possible objections”, applies to most [perhaps all] of them.

And it is not like the Basel Committee has shown itself to be a good regulatory body. It has actually been one of the most failed ones… so failed that they should have been prohibited from having anything to do with bank regulations… forever.

Do you really think its current Chair, Stefan Ingves, could provide you with a lucid explanation of it?

I know enough about finance to know when our banks are being dug even deeper in the hole in which they should not be.

The regulators wrote that the bank capital requirements are portfolio invariant because … otherwise it “would have been a too complex task for most banks and supervisors alike”... and now they come with "delta, vega and curvature risk"?

PS. 2024: Inviting comments the Basel Committee issued a document on Technical Amendments. On e.g., “SCO60.80: Curvature charge for Group 2a crypto-assets”, I challenge you to draft a comment that an economist like me could understand. 

The financial crisis explained to dummies in terms of capital requirements for banks: Lehman Brothers - AIG - Greece

The regulators, with Basel II, decided that against any private sector assets rated AAA banks, and against any sovereign rated as Greece was until November 2009, banks needed to hold only 1,6 percent in capital, meaning these could with those assets leverage their capital over 60 times to 1. (When holding “risky” assets like loans to entrepreneurs and SMEs they were only allowed to leverage 12 times to 1. 

On April 28, 2004 the SEC decided that was good for the Basel Committee was good enough for them and allowed Lehman to leverage over 60 times to 1 with AAA rated securities guaranteed with mortgages to the subprime sector… Since Europe were allowing their banks to do the same… the demand for these AAA securities became so huge that it overpowered all the quality controls in their manufacturing and packaging process… and Bang!

If AIG that was AAA rated guaranteed an asset, banks could dramatically reduce the capital they needed to hold against that assets, and this overwhelmed AIG’s capacity to resist selling “very profitable” loan default guarantees… and Bang!

Greece was of coursed offered loans in such amounts and in such generous terms, so their otherwise "so" disciplined and fiscally conservative governments could not resist the temptations… and Bang!

And as should have been expected not one single asset class that was perceived as risky played any role in causing the financial crisis… although of course these assets also suffered a lot when the “safe” came tumbling down.

One would think regulators would by now have discovered that banks already clear for the perceived risks with their risk premiums and the size of their exposure; and so to also force them to also clear in the capital for exactly the same risks, would cause banks to overdose on perceived risks. But no, they haven’t. So this little financial history lesson for dummies is of course primarily directed to them.

What is our major problem now? John Kenneth Galbraith explained it well: “If one is pretending to knowledge one does not have, one cannot ask for explanations to support possible objections.”

We’ve heard a lot about predatory lending, and it should be avoided, but why allow predatory regulations?

An audit report from the office of inspector general of the FDIC broadly defines predatory lending as "imposing unfair and abusive loan terms on borrowers”

Regulators know very well that those perceived as risky have to pay higher risk premiums and have less access to bank credit than those perceived as safe. 

Nonetheless regulators currently also require banks to hold much more capital against loans to those perceived as risky, when compared to what they need to hold against assets perceived as safe. And as a direct consequence those perceived as risky, when compared to those perceived as safe, will have to pay even higher interests and have even less access to bank credit. 

Since that imposes unfair and abusive loan terms on borrowers… it should be regarded as predatory regulations… and of course, to top it up, by negating fair access to the opportunities for credit of those perceived as risky, these also represent a driver of inequality.

Let me quote here two passages from John Kenneth Galbraith’s “Money: Whence it came where it went” 1975.

First: “For the new parts of the country [USA’s West]… there was the right to create banks at will and therewith the notes and deposits that resulted from their loans…[if] the bank failed…someone was left holding the worthless notes… but some borrowers from this bank were now in business...[jobs created]

It was an arrangement which reputable bankers and merchants in the East viewed with extreme distaste… Men of economic wisdom, then as later expressing the views of the reputable business community, spoke of the anarchy of unstable banking… The men of wisdom missed the point. The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done…. what is called sound economics is very often what mirrors the needs of the respectfully affluent.”

Second: “The function of credit in a simple society 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. And the more casual the conditions under which credit is granted and hence the more impecunious those accommodated, the more egalitarian credit is… Bad banks, unlike good, loaned to the poor risk, which is another name for the poor man.”

And finally, let me just add that never ever are truly dangerous financial bank excesses built up with assets perceived as risky; these are always caused by excessive bank exposure to what is perceived ex ante as safe but that ex-post tum out to be risky… and so all this odious regulatory discrimination against the risky… is all for nothing.

PS. “If one is pretending to knowledge one does not have, one cannot ask for explanations to support possible objections” John Kenneth Galbraith dixit.

Puritanism in banking

In his book Money: Whence it came, where it went” (1975), John Kenneth Galbraith discusses banks and banking issues which I believe may be applicable to the Venezuela of today.

In one section, he addresses the function of banks in the creation of wealth. Galbraith speculates on the fact that one of the basic fundamentals of the accelerated growth experienced in the western and south-western parts of the United States during the past century was the existence of an aggressive banking sector working in a relatively unregulated environment.

Banks opened and closed doors and bankruptcies were frequent, but as a consequence of agile and flexible credit policies, even the banks that failed left a wake of development in their passing.

In a second section, Galbraith refers to the banks’ function of democratization of capital as they allow entities with initiative, ideas, and will to work although they initially lack the resources to participate in the region’s economic activity. In this second case, Galbraith states that as the regulations affecting the activities of the banking sector are increased, the possibilities of this democratization of capital would decrease. There is obviously a risk in lending to the poor.

In Venezuela, the last few years [the 1990s] have seen a debate, almost puritan in its fervor, relative to banking activity and how, through the implementation of increased controls, we could avoid a repeat of a banking crisis like the one suffered in 1994 at a cost of almost 20% of GDP. Up to a certain point, this seems natural in light of the trauma created by this crisis.

However, in a country in which unemployment increases daily and critical poverty spreads like powder, I believe we have definitely lost the perspective of the true function of a bank when I read about the preoccupation of our Bank Regulating Agency that “the increase in credit activity could be accompanied by the risk that loans awarded to new clients are not backed up with necessary support (guarantees)” and that as a result we must consider new restrictions on the sector.

It is obvious that we must ensure that banks do not overstep their bounds while exercising their primary functions—a mistake which in turn would result in costly rescue operations. We cannot, however, in lieu of perfecting this control, lose sight of the fact that the banks’ principal purpose should be to assist in the country’s economic development and that it is precisely with this purpose in mind that they are allowed to operate.

I cannot believe that any of the Venezuelan banks were awarded their charters based purely and simply on a blanket promise to return deposits. Additionally, when we talk about not returning deposits, nobody can deny that—should we add up the costs caused by the poor administration, sins, and crimes perpetrated by the local private banking sector throughout its history—this would turn out to be only a fraction of the monetary value of the comparable costs caused by the public/government sector.

Regulatory Puritanism can affect the banking sector in many ways. Among others, we can mention the fact that it could obligate the banks to accelerate unduly the foreclosure and liquidation of a business client simply because the liquid value for the bank in the process of foreclosure is much higher than the value at which the bank is forced to carry the asset on its books. In the Venezuela of today, we do not have the social flexibility to be able to afford unnecessary foreclosures and liquidations.

In order to comprehend the process involved in the accounting of losses in a bank, one must understand that this does not necessarily have anything to do with actual and real losses, but rather with norms and regulations that require the creation of reserves. Obviously banks will be affected more or less depending on the severity of these norms. Currently, a comparative analysis would show that Venezuela has one of the most rigid and conservative sets of regulations in the world.

On top of this, we have arrived at this extreme situation from a base, extreme on the other end of the spectrum, in which not only was the regulatory framework unduly flexible, but in which, due to the absence of adequate supervision, the regulations were practically irrelevant.

Obviously, the process of going from one extreme to the other in the establishment of banking regulations is one of the explanations for the severe contraction of our banking sector. Until only a few years ago, Venezuela’s top banks were among the largest banks of Latin America. Today, they simply do not appear on the list.

It is evident that the financial health of the Venezuelan banking community requires an economic recovery and any Bank Superintendent complying with his mission should actively be supporting said recovery instead of, as sometimes seems evident, trying to receive distinctions for merit from Basel (home of the international bank regulatory agencies).

If we insist in maintaining a firm defeatist attitude which definitely does not represent a vision of growth for the future, we will most likely end up with the most reserved and solid banking sector in the world, adequately dressed in very conservative business suits, presiding over the funeral of the economy. I would much prefer their putting on some blue jeans and trying to get the economy moving.

As edited for "Voice and Noise" 2006

Originally published in The Daily Journal, Caracas, June 1997

PS. Here my 2019 letter to the Financial Stability Board

PD. And then, in 2023, I began dialoguing with AI: ChatGPT - Grok about Basel Committee’s insane risk weighted bank capital/equity requirements.

Traducción:

PURITANISMO BANCARIO

Con ocasión de una mudanza me reencontre con un libro escrito en 1975 por el reconocido economista John Keneth Galbraith titulado "Dinero. De donde vino y adonde fué" Ojeandolo me encontre con dos subrayados relativos a las funciones de la banca y los cuales creo son recordatorios oportunos en la Venezuela actual. El primer subrayado tiene que ver con la función creadora de riquezas que tiene la banca y donde Galbraith especula sobre el hecho de que una de las bases que fundamento en el siglo pasado en muy acelerado desarrollo del oeste y sur-oeste de los Estados Unidos era la existencia de una banca agresiva y no regulada que abria y cerraba puertas, quebrando con frecuencia, pero que, a consecuencia de una política de créditos agil y flexible, dejaba una estela de desarrollo. El segundo subrayado se refiere a la función democratizadora de capital que posee la banca al permitir a personas con iniciativas ideas y voluntad de trabajo pero sin recursos el participar en la actividad económica. En este último caso Galbraith indica con sagazidad que obviamente a menor grado de regulaciones que afecte la actividad bancaria, mayor es la posibilidad de democratizar el capital.

En Venezuela, durante los últimos años el debate relativo a la actividad bancaria se ha centrado con un fervor casi puritano sobre el como mediante el incremento de controles lograr evitar una repetición de la crisis bancaria. Hasta cierto punto lo anterior resulta natural ya que indudablemente la crisis bancaria venezolana fué traumática. Pero, cuando en una Venezuela donde el desempleo se incrementa a diário y la pobreza crítica se extiende como pólvora, se lee sobre una actual preocupación de la Superintendencia de Bancos por cuanto el "repunte de la actividad crediticia pueda traer consigo un riesgo en el otorgamiento de préstamos a nuevos clientes que no presenten los soportes necesarios." y por lo tanto hay que considerar nuevas restricciones, creo que definitivamente se ha perdido la perspectiva de la verdadera función de la banca.

Por supuesto se debe asegurar el que la banca no cometa excesos en el desempeño de sus funciones y que obligue acometer costosos rescates, pero en el ejercicio de dicha función controladora no puede perderse de vista de que el principal proposito de la banca debe ser coadyudar en el desarrollo económico del pais y justamente para cumplir dicha función es que se les permite operar. No creo que ninguno de los bancos venezolanos obtuvo su permiso de funcionamiento en base a una limitada promesa de devolver los depositos. Y si a la no devolución de depósitos vamos, nadie puede discutir que de sumar todos los costos de las malas administraciones, pecadillos, pecados y crimenes que toda la banca privada venezolana pueda haber acumulado en toda su historia, no llegarian ni a una fracción de haber causado perdidas en el valor del dinero comparable con los costos causados por el sector oficial. A tal fin y como simples ejemplos basta recordar los costos derivados del sistema de Recadi o simplemente aquellos derivados del manejo inadecuado de la crisis financieras y donde obviamente el costo que cobro el taller estatal por reparar el golpeado vehículo bancario venezolano, multiplico varias veces el costo original del daño.

Un puritanismo regulador puede afectar la banca de muchas formas. Entre los resultados podemos mencionar el que frecuentemente obliga la banca acelerar el proceso de liquidación de una empresa simplemente por el hecho de que el valor liquido que obtiene la banca en dicha liquidación supera los valores a los cuales se les permite mantenerlos contabilizados. En la Venezuela de hoy creo que no tenemos espacio social para permitirnos el lujo de cierres y liquidaciones no absolutamente necesarias.

Para entender el proceso del registro de las perdidas contables en un banco hay que comprender que estas a veces no tienen nada que ver con perdidas reales sino con simples exigencias normativas que obligan a la creación de reservas. De acuerdo a lo estricto de las normas la banca quedara afectado en mayor o menor grado. Actualmente cualquier analisis comparativo daria como resultado de que en Venezuela tenemos una de las normativas más rigidas y conservadoras del mundo. Para rematar, llegamos a dicho extremo, partiendo de una situación donde no solo las normativas eran muy flexibles sino que además, por la ausencia de una adecuada supervisión, eran practicamente irrelevantes.

Obviamente este proceso irracional de ir de un extremo a otro en la aplicacion de las regulaciones bancarias, y unido a la política devaluacionista de un sector fiscal ávido de recursos, implico un verdadero achicamiento del sector bancario. Hace pocos años Venezuela presentaba varios bancos entre los grandes bancos latinoamericanos, hoy en día ni siquiera aparecen en la lista.

Muchas veces y en respuesta a nerviosas interrogantes sobre la salud del sector bancario venezolano, originados sobre la cuantia de los ingresos extraordinarios, no me ha quedado otra respuesta que el indicar el hecho de que si a un banco le obligan reservar todo, pues todos sus ingresos futuros han de ser extraordinarios.

Resulta evidente que la misma salud financiera de la banca venezolana requiere de una urgente reactivación económica y una Superintendencia de Bancos que hoy estuviese cumpliendo sus funciones tendría que estar activamente apoyando dicha reactivación en vez de, como a veces se percibe, tratar de obtener distinciones al mérito emiitidos por Basilea. 

Si se persiste en mantener firme una actitud casi derrotista y que definitivamente no representa una visión de crecimiento futuro, puede que terminemos con la banca mas reservada y sólida del mundo, una banca vestida no de bluejean sino de etiqueta, pero lamentablemente no presenciando una fiesta sino el entierro económico de un pais.