Showing posts with label internal models. Show all posts
Showing posts with label internal models. Show all posts
Saturday, June 24, 2023
I asked ChatGPT:
"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?"
ChatGPT 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 ChatGPT:
"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?"
ChatGPT 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 ChatGPT:
"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?"
ChatGPT 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.”
Saturday, December 9, 2017
The Finalization of Basel III’s is just a photo-op for the Committee members to go home for Christmas with, as it does nothing to correct the fundamental flaws of current bank regulations.
The Basel Committee’s “Finalizing Basel III” brief states:
1. “What is Basel III? The Basel III framework is a central element of the Basel Committee’s response to the global financial crisis. It addresses a number of shortcomings in the pre-crisis regulatory framework and provides a foundation for a resilient banking system that will help avoid the build-up of systemic vulnerabilities. The framework will allow the banking system to support the real economy through the economic cycle.”
Since the risk weighted capital requirements are kept, that is simply not true! The global financial crisis was a direct consequence of regulations that allowed banks to leverage immensely their capital as long as they kept to “safe” assets: limitless leverage with exposures to friendly sovereigns, 62.5 times with private sector exposures rated AAA to AA, and 35.7 times with residential mortgages.
The exaggerated demand these regulations created for residential mortgages and highly rated securities, which caused serious deteriorations in their quality, and of loans to low risk decreed sovereigns, like Greece, explains 99.9% of the financial crisis.
In contrast when lending to an entrepreneur or an unrated small or medium size enterprise, as that was (is) considered risky, banks were only allowed to leverage 12.5 times. The differences in potential risk adjusted returns on equity between “safe” and “risky” assets hindered, and hinders, the banking system from adequately supporting the real economy
2. “What do the 2017 reforms do? “The 2017 reforms seek to restore credibility in the calculation of risk-weighted assets (RWAs) and improve the comparability of banks’ capital ratios. RWAs are an estimate of risk that determines the minimum level of regulatory capital a bank must maintain to deal with unexpected losses. A prudent and credible calculation of RWAs is an integral element of the risk-based capital framework.”
But the fundamental question of why it should be prudent to require banks to hold more capital against what is perceived risky, when the real dangers to the bank system is when something perceived as safe turns out risky, remains unanswered.
3. “Credibility of the framework: A range of studies found an unacceptably wide variation in RWAs across banks that cannot be explained solely by differences in the riskiness of banks’ portfolios. The unwarranted variation makes it difficult to compare capital ratios across banks and undermines confidence in capital ratios. The reforms will address this to help restore the credibility of the risk-based capital framework.
Internal models should allow for more accurate risk measurement than the standardised approaches developed by supervisors. However, incentives exist to minimise risk weights when internal models are used to set minimum capital requirements. In addition, certain types of asset, such as low-default exposures, cannot be modelled reliably or robustly. The reforms introduce constraints on the estimates banks make when they use their internal models for regulatory capital purposes, and, in some cases, remove the use of internal models.”
Where do regulators get the idea that if there are less-variations in RWAs, the standardized RWAs, based on how regulators perceive risks, are any more accurate? Excessive hubris? Have they forgotten their own “Standardized” risk weights? Alzheimer?
Also, since banks should clear for perceived risks in the size of the exposures and interest rates, making them clear for those same risks in the capital too, causes an excessive consideration of perceived risks. The regulators clearly keep on ignoring that any risk, even if perfectly perceived, causes the wrong actions, if excessively considered.
That regulators now, at long last, have understood that “incentives exist to minimise risk weights when internal models are used to set minimum capital”, serves little as consolation, as it just evidences their original naiveté.
PS. As an aide memoire for the regulators to take home for Christmas here’s a list of their mistakes. Am I being nasty? No! How many millions of entrepreneurs have over the years been negated access to the life changing opportunities of a bank credit, only because of these regulators? How many young must live in the basement of their parents houses without jobs, only because regulator think it is safer to finance houses than job creation opportunities? Let’s pray all the Ebenezer Scrooge in the Basel Committee will see light one day... or at least have the decency to fade away.
Sunday, April 30, 2017
IMF does still not understand how the risk weighted capital requirements for banks distort. Why? Groupthink?
IMF’s Global Financial Stability Report 2017 on page 43 and 44 Box 1.2. “Regulatory Reform at a Crossroads” states:
Finalization of the Basel III package of reforms— the revision of the “standardized” approach to the calculation of risk-weighted assets and limits on the use of internal models to assess risks—appears to have faltered… The outstanding challenge is to reconcile views on the weight to attach to each element, particularly to the balance between reliance on internal models and constraint through the calibration of the floor [based on a standardized approach]”
So regulators wants to reconcile between:
Use of internal risk models, which is basically similar to allowing Volkswagen to calculate their own carbon emissions.
Using the standardized approach designed by regulators and which included, for instance risk weights of only 20% for what is perceived very safe, like what’s AAA rated, and which precisely because of that perception can lead banks to build up dangerously large exposures; and a 150% risk weight for what is rated below BB-, something to which banks would never dream to expose their balance sheets much to.
We all know that minus times minus leads to a positive number but does reconciling one craziness with another craziness lead to a sane regulation. NO!
Box 1.2 also includes: “countries outside the central standards-setting bodies [in particular emerging markets]…rely heavily on a strong global standard to level the playing field and support financial stability”
Question: Does allowing the safe to have better access than usual and the risky less than usual really signify to “level the playing field”?
Box 1.2 concluding states: “Completion of the reforms is vital to address previously identified fault lines and thus ensure that the global financial system is safe and can promote economic activity and growth.”
Congratulations! I believe this is the first time I have read from somebody close to the regulators, as IMF is, that besides “safe and resilient”, the banking system needs also to “promote economic activity and growth.”
It is truly sad this comes at such a late stage. Anyone wanting banks to promote economic activity and growth, would never have accepted the risk weighted capital requirements for banks, as these dangerously distorts the allocation of credit to the real economy.
So clearly, IMF still has much internal analysis to do before they get there. I hope its groupthink allows it.
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