Did someone ever looked into the role of bank regulations causing Iceland's bank crisis?

I do not know, but I guess not.

From Wikipedia we read the following about the causes for the Iceland bank crisis:

“In 2001, banks were deregulated in Iceland. This set the stage for banks to upload debts when foreign companies were accumulated. The crisis unfolded when banks became unable to refinance their debts. It is estimated that the three major banks held foreign debt in excess of €50 billion, or about €160,000 per Icelandic resident, compared with Iceland's gross domestic product of €8.5 billion”

That seems true. But where does it say anything about why Iceland's banks were able to get so much debt? For instance from UK and Holland?

If I were an investigative reporter, which I am not, I would start by looking at how much capital UK and Dutch banks had to hold when lending to these banks of Iceland... and then compared this to how much capital they needed to hold when lending to a small or medium unrated enterprises in the UK or in Holland. 

That should give you an idea of where UK and Dutch banks would think they would earn their highest risk-adjusted returns on equity... and the rest should be easy to figure out.

Perhaps Iceland should have sued the Basel Committee for Banking Supervision.

PS. The Eurozone was in effect also affected by the same distortions.

Willful (or naive) blindness of epical proportions, reigns in the world of the Basel Committe’s bank regulations

Note: The following comments have been inspired by beginning to read Margaret Hefferman’s “Willful Blindness”

To agree with bank regulations for which the regulators have not even defined the purpose of the banks they regulate… is that not an act of willful (or naive) blindness?

To agree with bank regulations that look to hinder banks to hold assets ex ante perceived as risky, when these kinds of assets have never created a bank crisis… is that not an act of willful (or naive) blindness?

To agree with bank regulations based on perceived credit risks, when obviously what matter are unexpected events or not perceived credit risks… is that not an act of willful (or naive) blindness?

To believe that you could place so much decision power into the hands of some few human fallibe credit rating agencies, without intriducing a systemic risk of gigantic proportions… is that not an act of willful (or naive) blindness?

Not seeing that allowing banks to leverage their equity, and the support they receive from society differently, with different assets, will produce a serious distortion in the allocation of bank credit to the real economy… is that not an act of willful (or naive) blindness?

Not seeing that curtailing the access to bank credit of the risky, more than it is already curtailed increases inequality… is that not an act of willful (or naive) blindness?

Not seeing that future generations will be affected by denying them the risk-taking that brought current generation to where its at… is that not an act of willful (or naive) blindness?

Not understanding that banks, if allowed to use their own risk models to set their capital requirements will lower these so as to maximize their expected risk adjusted returns on equity… is that not an act of willful (or naive) blindness?

Believing that some Basel I and II regulators who were totally surprised by the 2007/08 crisis have it in them to fix it with a Basel III… is that not an act of willful (or naive) blindness?

To believe that a 2007/08 crisis and the following stagnation can be cured by just throwing QEs, fiscal deficits and low interest rates at it… is that not an act of willful (or naive) blindness?

And the list of questions related to current bank regulations that gives ground to believing willful acts of blindness takes place goes on and on and on… and I might add some with time after finishing the book that inspired this. 

PS to Financial Times: To receive thousands of letters on these problems from someone that has been showned right on many letters previously published… is that not an act of willful (not naive) blindness?

If ever allowed, the following would be my brief testimony about what caused the 2008 bank crisis

The following, if I am ever allowed to give it, as so many would not like to hear it, would be my brief testimony on what caused the 2008 bank crisis 

Sir, as I have learned to understand it, the 2008 crisis resulted from a combination of 3 factors.

The first were some very minimal capital requirements for some assets that had been approved, starting in 1988 with Basel I, for sovereigns and the financing of residential housing; and made extensive in Basel II of 2004 to private sectors assets with good credit ratings.

These allowed banks then to earn much higher expected risk adjusted returns on equity on some assets than on other, which introduced a serious distortion. After Basel II the allowed bank equity leverages were almost limitless when lending to “sound” (or friendly) sovereigns; 36 times to 1 when financing residential housing; and over 60 to 1 with private sector assets rated AAA to AA. Just the signature, on some type of guarantee by an AAA rated, like AIG, also allowed an operation to become leveraged over 60 times to 1. 

The second was Basel II’ extensive conditioning of the capital requirements for banks to the decisions of some very few (3) human fallible credit rating agencies. As I so many times warned about (in a letter published in FT January 2003 and even clearer in a written statement at the World Bank) this introduced a very serious systemic risk.

The third factor is a malignant element present in the otherwise beneficial process of securitization. The profits of that process are a function of how much implied and perceived risk-reduction takes place. To securitize something safe to something safer does not yield great returns for the securitization process. Neither does to securitize something risky into something less risky. 

What produces BIG profits is to securitize something really risky, and sell it off as something really safe. Like awarding really lousy subprime mortgages and packaging them in securities that could achieve an AAA rating. A 11%, 30 years, $300.000 mortgage, packaged into a security rated AAA and sold at a 6 percent yield, can be sold for $510.000, and provide those involved in the process an instantaneous profit of $210.000

With those facts it should be easy to understand the explosiveness of mixing the temptations of limitless, 36, and more than 60 to 1 allowed bank equity leverages providing huge expected risk adjusted ROEs; with subjecting the risk-assesment too much to the criteria of too few; with the huge profit margins when securitizing something very risky into something “very safe”. Here follows some indicative consequences:

As far as I have been able to gather, over a period of about 2 years, over a trillion dollars of the much larger production of subprime mortgages dressed up in AAA-AA ratings, ended up only in Europe. Add to that all the American investment banks’ holdings of this shady product.

To that we should also add Europe’s own problems with mortgages, like those in Spain derived in much by an excessive use of “teaser interest rates”, low the first years and then shooting up with vengeance.

And sovereigns like Greece, would never have been able to take on so much debt if banks (especially those in the Eurozone) would not have been able to leverage their equity so much with these loans.

Without those consequences there would have been no 2008 crisis, and that is an absolute fact.

The problem though with this explanation is that many, especially bank regulators, especially bank bashers, especially equity minimizing bankers, especially inattentive finance academicians, especially faulty besserwissers (those who love the sophisticated taste of words like "derivatives"), they all do not like this explanation, so it is not even discussed.

The real question though is: Who is the guiltiest party, those who fell for the temptations, or those who allowed the creation of the temptations?

I mean how far can you go blaming the children from eating some of that deliciously looking chocolate cake you left on the table, at their reach?

PS. Please do not categorize misregulation as deregulation. 

PS. Here's a letter published by the Washington Post, December 2009

PS. Here is a current summary of why the risk weighted capital requirements for banks, is utter and dangerous nonsense.

PS. And here is my letter to the Financial Stability Board that was officially received. Will it be answered?

When and where did the last bank crisis resulting from excessive exposures to something ex ante believed risky occur?

I don't know. Ask the regulators in the Basel Committee on Banking Supervision and the Financial Stability Board. 

I mean they must have much data on this because, without it, why would they impose credit risk weighted capital requirements for banks, knowing that carried the huge cost of distorting the allocation of bank credit to the real economy?

I mean that if they use the theorem that what's perceived as risky is riskier to the bank system than what is perceived as safe, then they are indeed using a loony theorem.

Or did they not look for the data?  Or did they not understand it?

There is only one 100 percent sure cause for the financial crisis 2007/08, and it is discussed less than 0.01 percent

The crisis exploded because of excessive exposures to AAA rated securities, real estate (Spain), loan to sovereigns (Greece) and short-term loans to banks (Iceland). They all one thing in common, namely that banks were required by regulators to hold very very little capital against these assets, and so banks could leverage very very much their equity with these assets, meaning that banks could expect to earn very very high risk adjusted returns on equity for these assets.

Had banks been required to hold the same level of capital against all assets, other crisis could have happened, but not one as large as the one in 2007/08.

So how much have you read about the problems related to the distortions produced by the risk weighted capital requirements in the allocation of credit to the real economy? Probably nothing!

Why? There are many explanations to that but, one of the most important, is that there is much more political interest in blaming bad bankers than laying it on good regulators.

Is this a problem? 

Yes, those regulations are still in place and so could still lead banks to create similar dangerously large exposures to something perceived or deemed safe. 

And since that still favors The Safe over The Risky, those who could most help us get our economies moving again, the SMEs and the entrepreneurs, have a lousy access to bank credit.

Right now banks are not financing the risky future, they are just refinancing the safer past, that which might soon turn risky, because of excessive financing.

PS. Here is a more extensive aide memoire on the mistakes in the risk weighted capital requirements for banks.

The Per Kurowski rule: The safer a bank asset is perceived, the worse its negative impact if it turns out to be risky.

If credit risks are correctly perceived by banks, one or another bank could still run into problems, but there will be no major bank system crises. It is when credit risks are incorrectly perceived that things with our bank system can get really bad.

So what the Basel Committee for Banking Supervision has done, which is creating credit risk weighted capital requirements for banks, based on as if the perceived risks are correct, makes absolutely no sense. If anything those capital requirements should have been based on the possibilities of those credit risks being more risky than what they are perceived to be. 

But the impact of all credit risk perceptions being wrong, is not the same over the whole spectrum of risks. In fact bank regulators ignored what I quite presumptuously have decided to dub the Per Kurowski rule; namely that the more the credit risk perception is one of safeness, the larger the negative impact on a bank if that perception turns out to be wrong.

That rule should be easy to understand when one realizes that it is for what is considered as very safe, that a bank most runs the risk of running up too high exposures, in too lenient terms, and charging too little compensating risk premiums.

The impact on banks of what is considered as risky, if it turns out to be more risky, is ameliorated by the fact that it usually represents smaller exposures, and usually belongs to a group of exposures  which are mutually covered through much larger risk premiums.

Since different capital requirements allows some assets to produce higher risk-adjusted returns than others, and that distorts the allocation of bank credit to the real economy, I favor one single percentage capital requirement for all bank assets.

But, if regulators absolutely feel they must meddle, in order to show they earn their salaries and their societal recognitions, then they should at least abandon the current capital requirements based on credit risk weighting, in favor of an impact weighting of credit risks being wrongly perceived.

What would this mean in practice? That our banks would again be allowed to lend to the risky but tough small businesses and entrepreneurs we all need to get going when the going gets tough.

In other words… just what a doctor would order, for example for Europe… and so that banks can help to produce the next generation of jobs for the next generations of Europeans.

Intuitive decision: Perceived safe is safe, perceived risky is risky.

Deliberate decision: Perceived safe is risky, perceived risky is safe.

PS. Per Kurowski's second rule: Any perfectly perceived credit risk, causes wrong credit decision, if the perceived risk of credit is excessively considered.

Three Qs and As on our banks

Q. What is the first worst that can happen to our banks, excessive exposures to the risky?

A. No, the “risky” never poses any risk of excessive exposures, The first worst is when something considered as “absolutely safe”, and to which therefore bank exposures could be huge, blows up in their face.

Q. What is then the second worst?

A. That when the first worst happens, the banks would not have the capital needed to cover for the losses.

Q. But, if then regulators, by setting quite decent capital requirements for banks for holding what is perceived as “risky”, but almost nonexistent for exposures to what is perceived as “absolutely safe”, make it more likely that the first worst and the second worst come together… is that not sort of dumb?

A. Yes, indeed, I take it back. The first worst thing that can happen to our banks, are dumb regulators.

Conclusion: Throw out Basel's capital requirements for banks based on perceived risk and use a simple and straightforward leverage ratio of between 8 and 10%

Who can explain the absolute absurdity of Basel II bank regulations?

If bankers knew how to manage risks perfectly there would be no need for bank capital. But, since they don’t, the regulators naturally require banks to have some capital. 

But when bankers get it wrong managing risks that are perceived as high, this does normally not cause any problems. In that case the exposures to the high-risks are small, the terms of contract quite strict and the interest rate already includes a high risk-premium. 

It is when bankers’ get it wrong managing risks which are perceived as almost non-existent, that shit really hits the fan. In this case the exposures are huge, the risk-premiums low and the contract terms quite often too generous. 

And so it would seem that any prudent regulator would ask the bank to have some reasonable capital, let us say 8 to 10 percent, especially against all the assets perceived as “absolutely not risky” 

But what did the Basel regulators do with Basel II? They decided that if a bank lends to one of “The Infallible”, the potentially really problematic lending, it can do so holding only 1.6 percent in capital, 5 times less than the 8 percent capital it is required to have when lending to “The Risky” the usually non-problematic lending. 

Who can explain such absurdity? And why is such absurdity not even debated?

One of the greatest myths is that if Greece had collected all taxes, Greece would not have been in trouble.

Greece is not in trouble because of the taxes it did not collect. Greece is in trouble because its government squandered away funds it borrowed. And because the Greek government was able to borrow so much, thanks to the loony bank regulations. 

For instance, if a German bank wanted to lend to a German entrepreneur, according to Basel II it needed to hold 8 percent in capital, which meant it could leverage its capital 12.5 to 1 times, but, if it lent to Greece, the way Greece was rated at the time, it only had to hold 1.6 percent in capital, which meant it could leverage its capital a mind-boggling 62.5 times to 1. No unregulated or shadow bank would ever manage to do that. 

And that meant, sort of, that if the bank could earn a risk and transaction cost adjusted margin of 1 percent when lending to a German small entrepreneur, it could expect to earn 12.5 percent on its capital, but, if it expected to earn the same margin lending to Greece, it could earn a whopping 62.5 percent on its equity per year. And that is of course a temptation that not even the most disciplined Prussian would be able to resist. And of course what Greek (and many not Greek) politician can resist the temptation of abundant and cheap loans? 

And so had all Greeks paid all their taxes that would have made no difference, in fact, since the Greek government could then have been able to show greater fiscal income, it could have justified keeping credit ratings great for a longer time, which meant having taken on even bigger debts.

Or did the Greek politicians think the loans Greece took on would be repaid by them being able to make of the Greeks exemplary tax–paying-citizens in just some few years? If they did, then they are more stupid than any ordinary politicians.

And now what? Yes Greeks, pay your taxes! But of course only after Greece creditors have accepted a reasonable deal based on a very substantial haircut, and only after you are sure your government will not keep squandering away your taxes.

It is of course very understandable that many Greeks are mad at those who have not paid their taxes but, let’s face it, on the other hand, the way things have turned out, those taxes that were not paid in earlier, might come in very handy now, and will, hopefully, we pray, be put to a much better use.

PS. This post was made before I realized that reality was much worse. Instead of applying to Greece the risk weights dependent on credit ratings that Basel II ordered, EU authorities assigned to all Eurozone sovereigns' debts, including Greece's a 0% risk weight, this even when none of theses nations can print the euro. So European banks, when lending to Greece, did/do not have to hold any capital at all. Now how crazy is that?

PS. At the end of the day the EU authorities kept total silence about their mistake and blamed Greece for it all. What a sad European Union L

A conversation with a prominent, probably brilliant, though mostly silent and invisible bank regulator

You must all have heard Mark Twain’s description of a banker; he who lends you the umbrella when the sun shines and wants it back when it rains. 

But, over the last couple of decades, bank regulators, by allowing banks to have less capital when an asset is perceived as safe, began to even pay the bankers more to lend the umbrella when the sun shines; and, by requiring banks to hold more capital when something is perceived as risky, to even charge the bankers more for not taking the umbrella back fast when it rains. 

And that silliness is the result of regulating banks without defining the purpose of the banks... and of regulators considering the credit ratings, instead of considering what bankers do when they consider credit ratings.

Frankly, who authorized bank regulators to do to our banks what they did?

The bank crisis and the Basel Committee banking regulations explained to a golfer

Once there was a Golf Club with a somewhat narrow golf course and where, even though the members were very careful, sometimes the hooking or slicing of the golf balls into adjacent holes, caused some serious accidents.

The Club’s Board was ordered to find a solution. To that effect the elected members of the Board consulted with some Experts and asked for recommendations. The Experts told the Board “most of the slicing and hooking is the product of bad players and so, if you want to solve this problem, you need to get rid of them”. Knowing this idea would not be received with much enthusiasm, and could in fact pose a direct threat to their reelection as members of the Board, they all decided to immediately delegate the “how to” to a Committee of Experts.

The Committee of Experts decided they needed to appoint some Golf-Player Rating Agencies (GPRAs) to rate the real quality of the players and thereafter created a parallel handicap adjustment requirement that effectively eliminated the bad players… without these even noticing it. According to their ratings, the AAA rated players had their normal handicap increased by 5 strokes, while the players rated B- or worse had their normal handicaps officially reduced by 5 strokes.

It worked! Though, just initially… Since having to play with a very low handicap was pure hell for a bad player, most of the bad players rapidly decided to change clubs and, as a result, the Club gained immense recognition for having the best players and being the safest club in the country… and the Committee of Experts was wildly acclaimed for having true experts. We will never ever have more accidents in our Club… was the Board’s self congratulatory message at the year’s end… four years ago.

But life is life, even among golfers, even in a golf club… and so the membership of the Club started changing. For instance, many great golfing has-beens around the country were attracted by a system that so clearly could help to pro-cyclically prolong their golf-life, just like many never-able-to-be-good players were also attracted by the possibility of joining a club renowned for having exclusively good golf players… and so they all started to read up and converse with the GPRAs about what was necessary in order to be conveniently rated.

There was such an avalanche of enquiries that the GPRAs got confused and overworked and started to make mistakes… to such an extent that the Club rapidly became overcrowded with dubiously rated golf-players. This would, of course, not have meant anything in the old days, but, since everyone had been duly informed that the accidents had been forever eliminated and that therefore there was no need for being careful… the accident rate shot up and rapidly turned, three years ago, into a pandemic disaster that threatens even the survival of the Club… and aggravated by the fact that the beginners and the decent-bad players, those who really are the heart and soul and economical support of a golf club, want nothing to do with a club that has a handicap system that so harshly discriminates against them, and have therefore joined other clubs.

But, golfing friends, the saddest part of this story is that since the logic of “getting rid of bad players and allowing only good players” sounds so very attractive and so very logical, the Board has not even today understood what they did wrong and so they insist on using exactly the same Committee of Experts to come up with better solutions. And the Committee of Experts is currently studying only refinements of their original handicap adjustment requirement formulas because, as “experts”, they cannot under any circumstances acknowledge that they were so fundamentally wrong.

And, unfortunately, the local media has not been sufficiently “without fear and without favour” to dare to really fundamentally question the wisdom of the local Club´s Board or of the Committee of Experts.

Bank regulators, why, why, why?

If all bank crisis in history have resulted from excessive exposures to what was perceived as “absolutely safe”, or at least very safe, and none ever from excessive exposures to what was perceived as risky… what is the rationale behind capital requirements for banks which are much lower for what is perceived as absolutely safe, or at least very safe, than those for what is perceived as “risky”? 

Some questions today to The Masters of Risk