Janet Yellen why are bank capital requirements based on credit ratings and not on job creation ratings?

Bank lending to small businesses has never had anything to do with causing the latest or any other financial crises for that matter; and risk-weighted capital requirements for banks makes it impossible for “the risky” small businesses to access bank credit in a fair way… 

Now knowing that, as Federal Reserve Chair Janet L. Yellen must know, how can you give a speech such as that delivered at the National Small Business Week Event at the U.S. Chamber of Commerce in May 2014?

She speaks much of the importance of job creation. Indeed, if I had been invited and allowed to make a question, that one would be… why do you base capital requirements for banks on perceived credit risk ratings and not on job creation ratings?

Don’t you understand how utterly immoral and dumb current bank regulatory discrimination is?

Suppose a busybody ministry of economy came up with the idea that in order to strengthen the competitiveness of the nation’s private sector, and make really sure the firms employed the best and brightest, they were going to give special tax incentives for hiring students with grades over a specified level. 

What would happen?

All those who had not achieved that great level of grades would scream bloody murder and accuse the ministry for discriminating against them, for something which they were already being discriminated in the job market. And if by any chance the ministry would still be able to impose its nutty and odiously discriminatory plan… you would automatically begin to see some inexplicable inflation in the level of grades.

And that is basically what the risk-weighted capital requirements for banks concocted by the Basel Committee for Banking Supervision do:

First: These capital requirements odiously discriminate, for a second time, against those who because of being perceived as risky already get smaller loans and pay higher interest rates.

Second: Borrowers have always wanted to be perceived as safer than what they are… but now the lenders dangerously have a vested in sharing that interest in too... so the credit rating agencies will be pressured for better ratings from both sides.  

Third but foremost: By allowing banks to earn higher risk-adjusted returns on equity when lending to “the safe” these capital requirements distort the allocation of bank credit to the real economy

And fourth: It all serves absolutely no purpose, since never ever do bank crises result from excessive exposures to what is perceived as risky, but always from excessive exposures to something erroneously ex ante perceived as absolutely safe.

Here for discussion is an alternative, less distorting, risk-weighted bank capital requirement regulation.

I have for more than a decade strongly opposed the Basel Committee’s risk-weighted capital requirements for banks. 

This primarily because these seriously distort the allocation of bank credit in the real economy, but also because they make little empirical sense, since what historically have caused all major bank crises, are not big bank exposures to what ex ante is considered risky, but always too large exposures to what was erroneously perceived ex ante as absolutely safe.

But since it seems that regulators do not feel they are doing their job if they don’t do risks weighting, my criticism has not been sufficiently considered.

In that respect let me here briefly express a simple alternative of risk-weighing the capital of a bank.

Though it would not increase the ultimate long term safety of the banks, because of the fundamental regulatory mistake of confusing ex-post risks with ex-ante perceptions, it could at least produce much less distortion in the allocation of bank credit.

1. Calculate the risk-weighted size of the bank’s balance sheet. 

2. Divide that number by the gross balance sheet of the bank. 

3. Multiply the resulting ratio times a basic capital requirement, for instance Basel II’s 8 percent.

4. Make the resulting percentage the general capital requirement for that bank in particular and to be applied to all its assets.

5. Make a medium term plan on how to increase that percentage for that particular banks, to for instance Basel II's 8 percent.

Comments? perkurowski@gmail.com

What caused regulators to concoct crazy risk-weighted bank capital requirements? Lack of testosterone, cortisol, cocaine, hubris or ideology?

The pillar of current bank regulations are the risk weighted capital requirements for banks. For instance in Basel II: 0 percent when lending to an “infallible sovereign”; 1.6 percent when lending to a slightly less “infallible sovereign”, or to a private member of the AAAristocracy; and 8 percent when lending to “a risky” medium and small businesses, or to an entrepreneur or a start-up.

John Coates a PhD research fellow in neuroscience at the university of Cambridge in his “The hour between dog and the wolf: How risk taking transform us, body and mind” writes “The financial system, as we have recently discovered to our dismay, balances precariously on the mental health of [financial] risk-takers. And he mentions testosterone, cocaine and hubris as risk-taking inducers; and cortisol as a risk-aversion generating hormone.

It would be interesting to hear John Coates opinion of what he thinks was present in the bodies’ of bank regulators when they concocted their regulations.

For instance, was it cortisol which made regulators so adverse to banks taking any kind of risks? Clearly, by allowing banks to earn so much higher risk-adjusted returns on equity when lending to the “absolutely safe” than when lending to “the risky”, they evidenced they were so insanely risk-adverse against banks running into short term problems, they even preferred to risk the misallocation of bank credit, something which had to guarantee that our real economy, and our banks, would run into problems long term.

Or was it testosterone, cocaine, or hubris which turned our bank regulators, those who foremost should be on the outlook for unexpected losses, into some risk taking monsters?  Allowing banks to leverage their equity 62.5 to 1 when lending to a private corporation, only because of AAA ratings, or to a nation with ratings such like those Greece had; or to even assume the existence of “infallible sovereigns” and in which case they allowed banks to leverage their capital infinitely… points at nothing else but insane risk-taking. Unless they are plain dumb something external must have influenced regulators to blind themselves to the fact that financial crises are never caused by excessive exposures to "the risky", but always by excessive bank exposures to something erroneously thought as "absolutely safe"

Coates refers to Lord Owen, a former British foreign secretary and a neurologist by training describing the “hubris syndrome” as “a disorder of the possession of power, particularly power which has been associated with overwhelming success, held for a period of years and with minimal constraint on the leader [which] can result in disastrous leadership and cause damage on a large scale. And Coates further clarifies it writing “This syndrome is characterized by recklessness, an inattention to detail, overwhelming self-confidence and contempt for others.”

I do not know about testosterone, cortisol or cocaine but,  since I quite recently heard one of the most important bank regulators saying “if bankers don’t like it let them be shoemakers” I would settle for the hubris of bank regulators, that which made them think they could act as risk managers for the whole world, as being the principal cause of the financial crisis… sprinkled of course with a heavy dose of ideology.

In Bill Easterly´s terms... God save us from the tyranny of experts!

Who is Mark Carney to talk about providing equal opportunity to all citizens?

We read Mark Carney the governor of the Bank of England saying “there is growing evidence that relative equality is good for growth. At a minimum, few would disagree that a society that provides opportunity to all of its citizens is more likely to thrive than one which favours an elite, however defined”

Who is he to talk about this? As a chairman of the Financial Stability Board, Mark Carney has approved for years risk-weighted capital requirements for banks, which discriminate against bank lending to “the risky”, those already discriminated against, precisely because they are perceived as “risky”, and favors bank lending to the “absolutely safe”, those already favored, precisely because they are perceived as “absolutely safe”.

Young unemployed Europeans, you cannot afford having Mario Draghi, Mark Carney and Stefan Ingves hanging around.

Mario Draghi is the former chairman of the Financial Stability Board (FSB) and the current President of the European Central Bank, ECB.

Mark Carney is the current governor of the Bank of England and the current Chairman of the Financial Stability Board.

Stefan Ingves is the current Governor of Sveriges Riksbank, the Swedish Central Bank, and the Chairman of the Basel Committee for Banking Supervision.

These three gentlemen all believe that what is really risky is what is perceived ex ante as risky, which is something like believing the sun revolves around the earth... because any correct reading of financial history would make it clear that what is really risky ex post, is what is ex ante perceived as absolutely safe.

And that is why they have approved of risk weighted capital requirements for banks which allow banks to have much much less capital when lending to “The infallible”, like to sovereigns, the AAAristocracy or the housing sector, than when lending to “The Risky”, like to medium and small businesses, to entrepreneurs and start ups.

And that is why banks can earn much much higher risk adjusted returns when lending to “The Infallible” than when lending to “The Risky”.

And that is why banks cannot allocate bank credit efficiently to the real economy.

And that is why so many young Europeans are out of jobs and without real prospects of being able to land themselves some decent jobs, in their lifetime.

And that is why you must, urgently, let the Copernicus', the Galileo's, and the Kepler’s of financial regulations in.

Those who before they start avoiding risks might have asked themselves: "What risk is it that we can the least risk our banks not to take?"; and have answered that with…“the risk that banks do not lend to the risky medium and small businesses, to entrepreneurs and start ups... those who most need bank credit... those who are best positioned to find the luck we need to move forward”

Young of Europe... if you do not rock this regulatory boat you're lost! 

There is, might really be unwittingly, a high treason going on, against the western world, against the Judeo Christian civilization.

I was born a coward. Or at least quite risk adverse. And the many risk I have taken, is mostly because of blissful ignorance, or a glass of wine too much.

But I have always known about the importance of risk-taking, which is why I have always been grateful that my world was able to ride on the coattails of daring risk-takers; and that is why I often complained that Mark Twain was too right when he, supposedly, described bankers as those who lend you the umbrella when the sun is out, and want it back as soon as it seems it is going to rain.

But then came some bank regulators and really messed it up. Even more wimpy than I, they decided banks could hold less capital when lending to what was perceived as safe than when lending to what was perceived as risky, which meant banks would be able to earn much higher risk-adjusted returns on what was perceived as “safe” than on what was perceived as ”risky”. 

And, of course, that meant banks stopped giving credits in competitive risk-adjusted terms to the medium and small businesses, entrepreneurs and start-ups, to those that keep our bicycle moving forward, not stalling, not falling.

And now I fret for my daughters, and I fret even more for my grandchild, soon grandchildren, because I know that if my western world, my Judeo-Christian civilization, stays in the hands of adversaries to risk taking, it will just go down, down, down.

Regulators, if you really must distort, why not do it for a purpose in mind? Why not use, instead of credit ratings, job for our youth ratings?

Mamma Mia!

If the Basel Committee had had anything to do with it we, the Western World, would not be cycling.

If the largest of the apprehensions of our mother and of our grandmother about cycling had determined our bicycling, we would still be cycling.

But, if the apprehensions of our mother and our grandmother about cycling had been added up, we would not been cycling.

And that is another way to explain how, when our bankers apprehensions about lending to “the risky”, those reflected in higher interest rates, smaller loans and tighter conditions, got added up to our bank regulator’s apprehensions about risks, those reflected in the capital requirements... it all resulted in our banks not lending to “the risky”, like to the medium and small businesses, entrepreneurs and start-ups.

We need to stress test our bank regulators too! How? Analyze what assets banks do now not have on their balance sheets... thanks to the regulators' interfering and arrogantly playing risk managers for the world

God save us from these regulators.... God please make us daring!

CFPB concern yourselves more with why Payday borrowers need to borrow, than with the conditions and the rates they borrow at

Yes, the Payday borrowers borrow too expensively, but… the other side of that coin is that medium and small businesses, entrepreneurs and startups, those who most could give the Payday borrowers an opportunity of not having to borrow, borrow less, and at higher risk-adjusted rates, than the “infallible sovereigns” and the AAAristocracy… thanks to the colleagues of CFPB… the regulators 

I just wish that CFPB would dare to look into the odious discrimination and odious distortion in the allocation of bank credit to the real economy that the risk-based capital requirements for banks cause.

The world needs regular jobs, not just jobs for bank regulators.

With their distortions of the allocation of bank credit to the real economy, which their Basel II risk-based capital requirements cause, has turned the regulators into the worst enemy of the creation of the jobs our young ones need, in order not to become a lost generation.

But it is just getting worse. Every clause I read of Basel III or Dodd Frank Act, or all thereto referenced regulations, ticks off in my mind a calculation of how many more jobs will this mean for regulators and aspiring regulators, and how many more opportunities of regular jobs will be lost because of it. 

And the ratio that keeps popping up in my mind is about 10.000 regular jobs lost for each job created for a regulator or for a bank regulation consultant.

The tyranny of [bank regulatory] experts. The forgotten rights of “the risky” to access bank credit.

Bank regulatory experts in the Basel Committee, and the Financial Stability Board, with their risk based capital requirements, by allowing banks to earn much higher risk adjusted returns on equity when lending to “The Infallible”, are blocking the access of “The Risky” to bank credit.

With that these tyrants are killing our economies… Who authorized them to such odious and senseless discrimination? Did we not become what we are because of risk taking? 

World Bank, IMF what’s wrong with you? You must know this is not right.

Note: Inspired by William Easterly’s “The Tyranny of experts”

We must stop bank regulators from increasing the risks of our banking system… they´ve done enough damage as is.

The real risks for a bank regulator, and ours as well, has nothing to do with one or even a couple of banks going busts; it has all to do with the whole banking system melting down, or not doing well what it is supposed to do, namely to allocate bank credit efficiently in the real economy.

And that translates into that the risk of a bank regulator has little to do with the type of assets a bank holds, and a lot to do with the capacity of bankers to pick the assets the banks should hold.

But current bank regulators, with their risk based capital requirements, allow banks to hold extremely large amounts of assets against extremely little capital only because bankers, and sometimes regulators themselves, say they perceive these as being “absolutely safe”. And that allows banks to earn much higher risk adjusted returns on equity when lending to for instance the “infallible sovereigns”, the housing sector and the AAAristocracy, than when lending to the “risky” medium and small businesses, entrepreneurs and start-ups.

And that means, effectively, that regulators are assisting banks to create that kind of excessive exposures to what is perceived as “absolutely safe” which has been the source of all bank system crisis when these, surprisingly, turn out to be risky. And all this is worsened by the fact that when now one of these safe exposures blows up, banks stand there holding extremely little capital in defense.

And that also means, effectively, that our banking sector is not allocating sufficient bank credit to those in the real economy who are in most need of it.

And so to sum it up: current regulators are betting more than ever our whole banking system on the bankers being able to pick the right assets… while at the same time distorting the picking of those assets. Sheer lunacy! We need to get rid of them urgently.