Showing posts with label risk weighted. Show all posts
Showing posts with label risk weighted. Show all posts

Wednesday, November 20, 2024

If keeping current bank capital/equity requirements, how can you dream of MAGA?

Sir, Elon Musk and Vivek Ramaswamy write: “Most legal edicts [that] aren’t laws enacted by Congress but ‘rules and regulations’ promulgated by unelected bureaucrats”, “The DOGE Plan to Reform Government” WSJ, November 20

Among these “edicts” the most important, and in that respect the least discussed, is the risk weighted bank capital/equity requirements, that with lower decreed weights for government debt and residential mortgages than for loans to small businesses and entrepreneurs, distorts the allocation of bank credit. De facto it implies:

That bureaucrats know better what to do with credit, for which repayment they're not personally responsible for, than small businesses.

That residential mortgages are more important for the economy than small businesses and entrepreneurs.

That refinancing the “safer” present has priority over financing the riskier future.

Questions: 

Was this how America became great? 

With this what chances do the authors, and the elected president, give to the possibilities of a MAGA? 

Does this “edict” conform with the wishes of America’s Founding Fathers?

Sunday, September 25, 2022

If you want your nation to prosper and become strong, what bank capital (equity) requirements would you prefer?

The current risk weighted ones, which have banks allocating their credit based on risk adjusted return on required equity (ROrE)? 

These imply e.g.:

Bureaucrats knowing better what to do with credit for which repayment they’re not personally responsible, for than small businesses and entrepreneurs.

Financing the purchase of houses with residential mortgages has priority over financing those who can create the jobs, the incomes, by which repay mortgages and service utilities. (Which makes houses become more investment assets than affordable homes)

Or, just one single capital requirement against ALL assets, a leverage ratio, which will have everyone compete for credit with risk adjusted interest rates, and banks allocating their assets based on maximizing their risk adjusted return on one single equity (ROE)?


Or, would you argue: “But, the risk weighted makes our bank system safer”  Sorry, No! It’s just another dangerous Maginot Line

The first nation to kick out Basel Committee regulations and return to one single bank capital requirement against all assets, has the best chance of getting back on the right track. How to transition from here to there? Not easy, but here’s one route.


A tweet to @imfcapdev April 5 2021
"Excess of carbs e.g., government loans, residential mortgages; insufficient proteins e.g., bank loans to entrepreneurs and lack of exercise e.g., no creative destruction/zombification, causes GDP obesity. Can IMF/WBG develop a Body Mass Index for GDP?"



Tuesday, May 10, 2022

Neoliberalism’s history is not being correctly recorded

The two policies most mentioned in connection with neoliberalism (please google it) are “privatization”, referring to that the private sector knows better, and “deregulation”, referring to that it's better when the government interferes less. And one of the moments most mentioned about when neoliberalism crumbled, is the 2008 global financial crisis GFC.

But, in 1988, with Basel I, bank capital requirements changed from one single capital requirement e.g., 10 percent against all assets, to multiple risk weighted requirements, and with its most defining weights being 0% the government, 100% citizens. Basel III, the short version, contains 1626 pages.


So, banks being allowed to leverage more their capital... meaning making it easier for banks to earn higher risk adjusted returns on equity with government debt than with loans to e.g., small businesses and entrepreneurs, please, what has that to do with the private sector knowing better what to do than the public sector?

So, deregulation, please, has that not much more to do with putting regulations (with all its possible miss-regulations) in overdrive?

And please, would there ever have been a 2008 GFC if banks had been limited to leverage their equity 10 times with AAA to AA rated mortgage-backed securities, and not the 62.5 times European banks and US investment banks 2004’s Basel II allowed them to do?

Does arguing this make me defender of neoliberalism? No and Yes! 

I often identified the privatizations, for instance of utilities, as just a trick by the bureaucrats in turn to lay their hands on some easy fiscal revenues, which would later have to be repaid by us consumers through higher tariffs.

But, do I believe that small businesses and entrepreneurs know better what to do with bank credit than the bureaucrats not personally responsible for the repayment of it do? You bet!

Has the end of neoliberalism in 1988 been recorded for the history books? No! There's surely many who even swear it is still alive and kicking.

PS. You don't have to just take my word on it: Assets for which bank capital requirements were nonexistent, were what had most political support: sovereign credits. A simple ‘leverage ratio’ discouraged holdings of low-return government securities” Paul Volcker


Wednesday, May 4, 2022

The regulatory distortion that shall not be understood… or at least not be named

My twitter thread.

The regulatory distortion that shall not be understood… or at least not be named.
After the operational costs and the perceived credit risks have been cleared for with higher or lower cost/risk adjusted interest rates, we get the expected risk adjusted return of a bank asset.

If a bank asset produces an expected risk adjusted return of 1 percent, then, if the capital requirement is 8 percent, it can be leveraged 12.5 times and it will produce an expected risk adjusted return on bank equity of 12.5 percent. 

But if a bank asset produces an expected risk adjusted return of 1 percent, and the capital requirement is only 2.8 percent, it can be leveraged 35 times, and it will produce an expected risk adjusted return on bank equity of 35 percent.

So, exactly the same expected risk adjusted return on assets, if deemed “safe” by regulators, e.g., residential mortgages, could produce almost three times the expected risk adjusted return on bank equity than if regulators deem it “risky”, e.g., loans to small businesses.

The consequence?
For the bank system, dangerously too many residential mortgages, most at lower than their correct risk-adjusted interest rates, and, for the economy, dangerously too few loans to small businesses, most at higher than their correct risk-adjusted interest rates.

Those perceived less creditworthy and who always got less credit and paid higher rates were, with this, also declared less worthy of credit. Does that promote or decrease inequality?

And since banks are subject to capital requirements mostly based on perceived credit risks, not misperceived risks or unexpected events, e.g., pandemic or war, they will now stand there naked, just when we surely need them the most.
Basel Committee… Good Job!

And what if the bank capital requirement is much lower and the allowed leverage much higher for government debt, Treasuries?
Well then, the regulators are really empowering the Bureaucracy Autocracy with loads of credit at ultra-low rates… and this even before the QEs.

And don’t just take my word for it.
“Assets for which bank capital requirements were nonexistent, were what had most political support: sovereign credits. A simple ‘leverage ratio’ discouraged holdings of low-return government securities” Paul Volcker


Friday, February 11, 2022

Some unasked questions that all nominees to the Federal Reserve Board, and of course its current members, should be dared to answer

Intro: The Federal Reserve’s risk weighted bank capital requirements allow banks to hold much less capital, translating into being able to leverage much more with assets perceived (or decreed) as safe e.g., Treasuries, residential mortgages and those with an AAA rating, than with e.g., small businesses, entrepreneurs and assets rated below BB-.

Q. With what assets do you think all those excessive bank exposures that have and could cause really serious bank crisis are built up with: with those perceived as safe or with those perceived as risky?

Intro: When times are rosy, these risk weighted bank capital requirements, allow banks: to lend dangerously much to what’s perceived as very safe; to hold much less capital; to do more stock buybacks and to pay more dividends & bonuses.

Q. Does this not sound like that when times turn bad, banks will stand naked when they are most needed

Intro: It is much easier for banks to obtain the risk adjusted returns on equity they look for with assets they can leverage more, and so therefore banks will naturally prefer these, that is unless assets which could be leveraged less, provide additional risk adjusted margins.

Q. Do you think it is more important for banks to finance residential mortgages than to finance those loans to small businesses that could help people get the jobs with which service mortgages and pay utilities?

Intro: The Fed when in 1988 it accepted the Basel Committee’s risk adverse bank capital requirements, it decreed weights of 0% the federal government and 100% “We the people”. 

Q. Do you think the Founding Fathers of The Home of the Brave would agree with regulators imposing risk aversion on its banks; and with bureaucrats knowing better what to do with credit for which repayment they’re not personally responsible for than American small businesses?

Q. Do you have an opinion on how much the strength of the US dollar depends on the United States remaining being perceived as the foremost military power in the world, and of course on its willingness and capacity of exercising such power?

Please, if I may, one last question:

Q. Where do you think America would be, if these bank regulations had been in place the last couple of centuries?

@PerKurowski

Monday, October 18, 2021

But with questions that shall not to be heard, courage might not suffice

“A lot of people want to convince you that you need a Ph.D. or a law degree or dozens of hours of free time to read dense texts about critical theory to understand the woke movement and its worldview. You do not. You simply need to believe your own eyes and ears.”

Indeed: 

We should need nothing of that sort in order to understand that… risk weighted bank capital requirements based on that what’s perceived as risky is more dangerous to our bank systems than what’s perceived as safe, is as wrong/as woke as can be.
2004, Basel II assigned to the safest of the perceived safe, a risk weight of 20% and, to the riskiest of the perceived risky, a risk weight of 150%... Translating into a Basel II capital requirement of 1.6.% for the safest and 12% for the riskiest... Meaning banks were allowed by their regulators to leverage their capital 62.5 with assets some few human fallible credit rating agencies consider to be the safest, and 8.3 times with what these agencies consider to be the riskiest.

We should need nothing of that sort in order to understand that… decreed risk weights of 0% the government and 100% citizens, de facto implies that bureaucrats know better what to do with credit for which repayment they’re not personally responsible for than e.g., small businesses and entrepreneurs. 
Should we agree with such statism/communism/fascism?

We should need nothing of that sort in order to understand that… allowing banks to leverage more their capital with some assets than others, make it easier for them to obtain a higher risk adjusted return on equity with some assets than with other. 
Should we agree with such in distortion of the allocation of bank credit?

We should need nothing of that sort in order to understand that… those less creditworthy already get less credit and pay higher interest rates.
Should we agree with bank regulations that declare the less creditworthy to also be less worthy of credit?

We should need nothing of that sort in order to understand that… … and on this issue I could go on and on… like wondering why the Academia says nothing. Might it be an Inquisition has declared questions on this issue shall not be heard?


PS. My 1999 Op-Ed in which, like Bari Weiss, I quote Arthur Koestler. “I automatically learned to classify all that is repugnant as an »inheritance from the past», and all that is attractive as the »seed of the future». With the aid of this automatic classification it was still possible for a European in 1932 to visit Russia and continue to be a communist.”

Wednesday, October 13, 2021

The confession of a regulatory hit man… one that shall not be heard.

Paul Volcker, in his autography “Keeping at it”, penned together with Christine Harper in 2018, 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… 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."

What does that mean? It means exactly, no way around it, that if banks needed to hold as much capital against government securities and residential mortgages than what they were required to hold against e.g., loans to small businesses and entrepreneurs, banks would either hold less governments securities or residential mortgages or require higher interest rates on that… which also translates into banks holding more loans to small businesses and entrepreneurs at lower interest rates.

Volcker referred therein to 1988 Basel I regulations’ risk weighted bank capital requirements, but that remains totally applicable to Basel II and Basel III.

Thirty-three years without free-market set interest rates in the Western world, and I believe not one single Nobel Prize in Economic Sciences winner, or reputable or disreputable PhD anywhere, or distinguished journalist, has referred to this. Could it be that risk weights 0% government, 40% residential mortgages have created such a strong alliance between statists/communists and home owners, that the 100% risk weighted citizens stand no chance.

With banks giving too much credit at too low rates to what’s perceived or decreed as safe, where do you think this will all end? Have a guess. 

“NOISE” defines me as noisy. I've got no problem with that.

Reading “Noise: A Flaw in Human Judgment" by Daniel Kahneman, Olivier Sibony and Cass R. Sunstein

Noise: “People who make judgments behave as if true value exists, regardless of whether it does. The think and act [as besserwissers] as if there were an invisible bull’s eye at which to aim, one that they and others should not miss by much”

Me: The Basel Committee’s risk weighted bank capital requirements, based on that what’s perceived as risky being more dangerous to our bank systems than what’s perceived (or decreed) as safe, is a pure and unabridged baseless judgment, held by Monday Morning Quarterbacks.


Noise: “Bias exist when most errors in a set of judgments are in the same direction”

Me: 2004, Basel II’s risk weights of 20% for what human fallible credit ratings agencies have assigned a AAA to AA rating, and 150% for assets assigned a below BB-rating, is clearly the previous judgement was set on steroids, by an ex-ante runaway risk aversion.


Noise: “Eliminating bias from a set of judgments will not eliminate all error. The errors that remain that remain when bias is removed are not shared. They are unwanted divergency of judgments, the unreliability of the measuring instrument we apply to reality. They are noise.” 

Me: So, I who for decades have been convinced of that what’s perceived (or decreed) as safe is much more dangerous to our bank system than what’s perceived as risky, seem to have been declared here, as pure unadulterated noise.

PS. Would Daniel Kahneman have been awarded the Nobel Memorial Prize in Economic Sciences if Sveriges Riksbank had known how much his 2011 “Thinking, fast and slow” helps explain how stupid their risk weighted bank capital requirements are?

P.S. After titling my book “Voice and Noise” I found an article by Ingo R. Titze, Ph.D., in the Journal of Singing titled “Noise in the Voice”. It argued “A little noise, turned on at the right time, can go a long way toward enlarging the interpretive tool”. It reassured me a lot.


Saturday, September 11, 2021

A much-needed and much overdue conference

John A. Shedd, in his 1928 “Salt from my attic” wrote: “A ship in harbor is safe, but that is not what ships are for”. 

Does that not apply to banks too?In his autobiography “Keeping at it”, penned together with Christine Harper in 2018, Paul Volcker, the Chair of the Federal Reserve from August 1979 to August 1987, with respect to the credit risk weighted bank capital requirements approved in 1988 and which are known as Basel I, valiantly confessed:

“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… 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."

Allowing banks to leverage much more with Treasuries and residential mortgages, which means it is easier for them to obtain satisfactory returns on equity with these assets, made it of course much harder for the “risky” e.g., small businesses and entrepreneurs to compete for credit. They now get less credit or pay higher interest rates than in absence of these regulations. Direct results? More government debt, higher house prices and less private sector jobs/incomes.

The harsh truth is that with the risk-weighting, the Fed decreed the less creditworthy to also be less worthy of credit, and that banks financing or refinancing the “safer” present would have priority over their financing the riskier future. 

An even harsher truth is that, in terms of financial stability, it’s all for nothing… even counterproductive. All the excessive exposures that could lead to major systemic bank crises, have always been built-up with what’s perceived as safe, never ever with what’s perceived as risky.

Who is going to pay by far the most for all the consequences? Our children and grandchildren.

“Where would America, the Home of the Brave be, if the credit risk averse bank regulations had not been introduced?”, is that not a question that merits a conference transmitted live on prime time? 

Why has it not taken place yet? Thirty-three years of silence clearly evidences this is not a red or blue issue and, sadly, violet is so out of fashion.

Why does your paper/organization sponsor such a conference?

Thursday, August 26, 2021

Zero dividends, buy-backs and big bonuses, before banks have ten percent in capital against all assets

We urgently need our banks to be banks again

Current bank capital requirements, with capital meaning equity, meaning the skin in the game bank shareholders should have, are mostly based on perceived credit risks; not on misperceived risks, or the unexpected, like a Covid-19.

That would be less of a problem, if those capital requirements were based on risks conditioned to how credit risks are perceived.

But they’re not! What’s perceived more creditworthy, meaning what’s preferred by banks, have much lower capital requirements than what’s perceived less creditworthy.

And lower capital requirements mean higher leverages, making it therefore easier to earn risk adjusted returns on equity with what’s perceived (or decreed by regulators) as safe, than with what’s perceived as risky.

The consequence? A procyclicality that fosters higher and higher exposures to what’s safe, against less and less capital.

And what’s defined as “safe”? Loans to sovereigns, residential mortgages and assets with very high credit ratings?

And what’s risky? E.g., loans to small businesses and entrepreneurs.

So precisely like in 2007-08, when banks were caught with their pants down because of huge exposures to mortgage-backed securities with misperceived AAA ratings, they’re now standing there naked because of the unforeseen economic consequences of Covid-19; especially those derived from lockdowns.

The procyclicality of it all; when times are rosy banks can hold little capital but when times get hard banks have a hard time raising capital, sets us up to the fact 

And so, just when we now most need banks to help us out, it’s the hardest for them to raise the capital that would allow them to do so. What a mess!


So, what would I propose? In few words, the following: 

“Banks, you can now hold zero capital, but that comes with: zero dividends, zero buy-backs and zero bonuses until you have ten percent in capital against all assets; and until you’ve paid back, including a reasonable interest, all what central banks or taxpayers have assisted you with.”

To ease the transition one could allow all bank assets incorporated some months before the change, to be held, until its maturity, against the capital requirement valid when put on banks' balances.

And I would allow small investors to buy some of that bank equity that helps these meet that ten percent requirement on favorable conditions… so as to connect the banks with the citizens again

Fellow citizens, let’s rescue our banks from hands of those financial engineers concerned with “how much can we leverage this asset?”, so as to put these back into hands of loan officers whose first question to applicants is, “what are you going to use the money for?”

And let’s rescue banks from that statism/communism/fascism implied with risk weights of 0% the Government, 100% the citizens… all as if bureaucrats/politicians know better what to do with credit for which repayment they’re not personally responsible for, than e.g., entrepreneurs.

Let’s be clear. Risk taking is the oxygen of all development and so, in that vein, for the real economy what’s “safe” represents carbs, while what’s “risky”, proteins and vitamins.


And finally let’s stop putting financial instability on steroids. The large dangerous exposures that could become dangerous for our bank systems are always built up with what’s perceived as safe, never ever with what’s perceived risky. 


Give it a thought, the newspaper you read; would it dare to publish a Galileo-heliocentric opinion and risk being confronted by the Basel Inquisition?


Sunday, June 20, 2021

Could/would an Inquisition Tribunal nominate as a Nobel Prize winner in Physics, someone arguing a heliocentric world?

Why do I ask?

The Nobel Memorial Prize in Economic sciences is officially the Sveriges Riksbank Prize in Economic Sciences in Memory of Alfred Nobel. The Governor of Sveriges Riksbank since 2006, is Stefan Ingves, and who, from 2011 to 2019 served as the Chairman of the Basel Committee on Banking Supervision. 

And the Church of the Basel Committee holds, as a dogma, with their credit risk weighted capital requirements, that even though never ever have those excessive exposures that caused bank crises been built up with what’s perceived as risky, but always with what was perceived as safe, that what is really dangerous to our bank systems, is what’s perceived as risky, or what has not been decreed by them as being very safe... like loans to governments.

So, could an economist who argues that what’s perceived as safe is much more dangerous to our bank systems than what's perceived as risky be nominated to such a Nobel Memorial Prize in Economic sciences?

You tell me.


Thursday, May 27, 2021

Where would the Home of the Brave be, if all its immigrants had been met by risk-adverse bank regulations?

In his Washington Post May 27 op-ed, “Subsidizing America’s most important product," George F. Will referred to “Joseph Schumpeter an immigrant from Austria” whose theory was that “the principal drivers of social dynamism are… innovators — inventors of new things and companies” and added that “The common denominator [of it] is the restless, risk-taking spirit of a talented few.”The de facto spirit of the risk weighted bank capital requirements in the United States can currently be summarized in the following way: 

“We regulators allow you banks to leverage your capital a lot, and therefore earn high risk adjusted returns on equity, with what’s safe, e.g., Treasuries and residential mortgages. But, as a quid pro quo, you need to stay away from what’s risky, e.g., small businesses and entrepreneurs”

So, let me ask: Where would the Home of the Brave be if all its immigrants had been met by such regulatory risk adverseness?


PS. John Kenneth Galbraith 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]. “Money: Whence it came where it went” 1975

PS. And at the World Bank I argued time and time again: “There’s a clear need for an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth.”


PS. And, to top it up, in The Land of the Free, that risk aversion came hand in hand with outright statism

Monday, May 24, 2021

On the morality of current banker's decisions

A banker confronts a choice:

On one hand, Alt. A, a number of not so creditworthy borrowers who are asking for small loans, accepting to pay what could rightly be deemed a bit higher interest rate than what the risk adjusted interest rate should be.

On the other hand, Alt. B, a very creditworthy borrower, that is asking for a very large loan, at a rate lower than what an adequate risk adjusted interest rate should be.

Years ago, the banker would gladly gone for Alt. A, but, after the introduction of risk weighted bank capital requirements, which mean banks can leverage much more with what’s more creditworthy than with what’s less so, means the bank would obtain a higher risk adjusted return on its equity with Alt. B.

A banker has to pick Alt B. or he’s toast… and so he picks it… (that is unless he would not want to be a banker any more… and instead, like George Banks, go and fly a kite)

In reference to Per Bylund’s twitter thread on “morality of actions”, how would you classify the banker’s action.

Monday, April 12, 2021

Bank regulators, please wake up, being more creditworthy, should not mean, as you have decreed, being also deemed more worthy of credit.

Anyone deemed more creditworthy in terms of representing less risk of default will, by definition, get more credit and on better terms (like lower risk adjusted interest rate) than anyone deemed to be less creditworthy.

But if banks are allowed to leverage their equity more with the more creditworthy, and can so easier earn higher risk adjusted returns on equity, that does also imply these borrowers to be more worthy of credit than the less creditworthy… and that’s as wrong and dangerous as can be, for the bank system and for the real economy... and in reality, that's even immoral.

The wealthy are usually creditworthy, but they not more worthy of credit than the “riskier” poor. The risk weighted bank capital requirements, wrongly and immorally, Decreed Inequality.

A government is (at least in the short run) quite often very creditworthy, but it is not more worthy of credit than its citizens, as the risk weighted bank capital requirements so wrongly decree.

A house buyer is often creditworthy, but he is not more worthy of credit than e.g., small businesses and entrepreneurs, as  the risk weighted bank capital requirements so wrongly decree.

A house buyer with a larger down-payment, a lower loan to value LTV, is more creditworthy, but he is not more worthy of credit than a riskier house buyer providing a smaller down-payment, a higher LTV, as the risk weighted bank capital requirements so wrongly decree.

A developed nation is (at least in the short run) quite often very creditworthy, but it is not more worthy of credit than riskier developing nations, as the risk weighted bank capital requirements so wrongly decree.

A federal government is (at least in the short run) quite often very creditworthy, but it is not more worthy of credit than riskier local governments, as the risk weighted bank capital requirements so wrongly decree.

An AAA rated corporation is credit creditworthy, but it is not more worthy of credit than a much riskier below BB- rated one, as the risk weighted bank capital requirements so wrongly decree.

And I could go on and on





 

Thursday, February 4, 2021

Do the risk weighted bank capital requirements make the risky more or less risky?

Basel III’s bank capital requirement’s risk weights (RW) for residential mortgages depending on Loan to Value (LTV); implied Allowed Leverage of capital/equity (AL) and expected Return On Equity (eROE), calculated with a Risk Adjusted 0.5% expected Return on Asset (eROE) 

LTV<50%: RW = 20%: AL = 62.5 to 1: eROE = 31%
50% < LTV ≤ 60%: RW = 25%: AL = 50 to 1: eROE = 25%
60% < LTV ≤ 80%: RW = 30%: AL = 41.7 to 1:  eROE = 21%
80% < LTV ≤ 90%: RW = 40%: AL 31.25 to 1: eROE = 16%
90% < LTV ≤ 100%: RW = 50%: AL 25 to 1: eROE = 12%
LTV > 100%: RW = 70%: AL 17.9 to 1: eROE = 9%

Those with higher LTV, because they are riskier, must naturally pay banks higher risk adjusted interest rates. But, since banks can hold less capital against lower LTVs, they must also compensate banks, so as to provide these with a competitive risk adjusted return on equity.

So, in order for those who have no money to put down (LTV) > 100%, and with which banks can leverage 17.9 times, in order to compete with those who put down LTV <50%, need to provide an expected Risk Adjusted Return on Asset of 1.73 (31%/17.9); meaning in this case a 1.23% higher interest rate than without this distortion.

And we ask: charging those who have no money to put down, and who should perhaps not even have access to a residential mortgage, a 1.23% higher interest rate than what their risk adjusted interest rate would otherwise be, does that make these more or less risky?

Conclusion: The risk weighted bank capital requirements have, de facto, 0% to do with credit risk reduction, and 100% to do with risk generating distortions.

If race can be correlated to higher LTV mortgages, does this not de facto imply regulators are engaged in discrimination based on race?

Basel Committee... Good Job!



And we must also ask, are the risk weighted bank capital requirements really in accordance with the spirit of the Equal Credit Opportunity Act (ECOA) or the Community Reinvestment Act (CRA)?



Thursday, January 28, 2021

Five sad musings on the current bank regulations autocratically dictated by central bankers.

It is so hard for me to muster enough interest about central bankers’ monetary policies, while they make these so ineffective by imposing regulations that dangerously distort the allocation of bank credit.

Credit risk weighted bank capital (equity) requirements” 
translates as 
Worthy of credit allowed bank capital (equity) leverages

Their lower bank capital requirements when lending to the government than when lending to citizens, de facto implies bureaucrats know better what to do with credit they’re not personally responsible for than e.g. entrepreneurs... and so are more worthy of it.

Their lower bank capital requirements for banks when financing the central government than when financing local governments, de facto implies federal bureaucrats know much better what to do with credit than local bureaucrats... and so are more worthy of it.

Their lower bank capital requirements for banks when financing residential mortgages, de facto implies that those buying a house are more important for the economy than, e.g. small businesses and entrepreneurs... and so are more worthy of it.

Their lower bank capital requirements for banks when financing the “safer” present than when financing the “riskier” future, de facto implies placing a reverse mortgage on the current economy and giving up on our grandchildren’s future.

And all that for nothing. Those excessive bank exposures that could be dangerous to our bank systems are always built-up with assets perceived or decreed as safe, and never ever with assets perceived as risky.



https://subprimeregulations.blogspot.com/2019/07/risk-weights-are-to-access-to-credit.html

Thursday, January 21, 2021

Might “availability heuristic” “availability bias” explain the loony risk weighted bank capital requirements?

"The availability heuristic, also known as availability bias, is a mental shortcut that relies on immediate examples that come to a given person's mind when evaluating a specific topic, concept, method or decision. The availability heuristic operates on the notion that if something can be recalled, it must be important, or at least more important than alternative solutions which are not as readily recalled. Subsequently, under the availability heuristic, people tend to heavily weigh their judgments toward more recent information, making new opinions biased toward that latest news.

The availability of consequences associated with an action is positively related to perceptions of the magnitude of the consequences of that action. In other words, the easier it is to recall the consequences of something, the greater those consequences are often perceived to be. Most notably, people often rely on the content of their recall if its implications are not called into question by the difficulty that they experience in bringing the relevant material to mind"

Could that explain why the world, so submissively, has accepted the regulators' bank capital requirements based on that those excessive exposures that could be dangerous to bank systems are built-up with assets perceived risky, and not with assets perceived as safe? 

Has the immediate example of the certainty of Monday Morning Quarterbacks, informing them about the awful consequences of what was very risky after the game, totally blocked regulators from even looking at what was considered as very safe before the game?

Richard Thaler
Cass Sunstein
Daniel Kahneman

Thursday, December 31, 2020

How come we ended up with stupid portfolio invariant risk weighted bank capital requirements?

Which are based on:

That those excessive exposures that can really be dangerous to our bank systems are build up with assets perceived as risky and not with assets perceived as safe.



That substituting risk adjusted returns on equity for risk adjusted interest rates, would not seriously distort the allocation of bank credit.



Though Paul A. Volcker, in his autography “Keeping at it”, valiantly confessed “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


And here my explanations:

All bank regulators faced/face a furious attack mounted by dangerously creative capital minimizing / leverage maximizing financial engineers, who, getting rid of traditional loan officers, those with their “know your client” and their “what are you going to use the money for?”, managed to capture the banks. (And, since less capital means less dividends, they can also pay themselves larger bonuses.)

Hubris! “We regulators, we know so much about risks so we will impose risk weighted capital requirements on banks, something which will make our financial system safer” Yep, what’s risky is risky, what’s safe is safe. What is there not to like with such an offer? And the world, for the umpteenth time, again fell for demagogues, populists, Monday morning quarterbacks and those who find it so delightful to impress us rolling off their tongues sophisticated words like derivatives.

In a world full of mutual admiration clubs, like the Basel Committee and Academia in general, you do not ask questions that can imply criticism of any of your colleagues or superiors, “C’est pas comme il faut», nor, if you are a high shot financial journalist, do you risk not being invited to Davos or IMF meetings.

"It is difficult to get a man to understand something, when his salary depends upon his not understanding it!" Upton Sinclair

Clearly there are many more jobs with ever growing thousands of pages of regulations than with just a one liner: “Banks shall have one capital requirement (8%-15%) against all assets”. And so, instead of getting rid of the extremely procyclical credit risk weighted capital requirements, they designed new insufficient countercyclical ones.

The time spent on any item of the agenda will be in inverse proportion to the sum involved." Parkinson’s law

Since bank regulators must have heard of (supposedly) Mark Twain’s “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” it is clear they all missed their lectures on conditional probabilities.


There are some mistakes it takes a Ph.D. to make”, Daniel Moynihan.

One has to belong to the intelligentsia to believe things like that: no ordinary man could be such a fool”, George Orwell, in Notes on Nationalism


And so now: 

A ship in harbor is safe, but that is not what ships are for” John A. Shedd, something that should apply to banks too. Sadly, dangerously our bank systems, banks are overpopulating safe harbors and, equally dangerous for our economy, underexploring risky waters. 

What gets us into trouble is not what we don't know. It's what we know for sure that just ain't so.” Mark Twain

And since current bank capital requirements are mostly based on the expected credit risks banks should clear for on their own; not on misperceived credit risks, like 2008’s AAA rated MBS, or unexpected dangers, like COVID-19, now banks stand there with their pants down.

Let us pray 2021 will not be too hurtful.

PS. Might “availability heuristic” “availability bias” help explain these loony risk weighted bank capital requirements?

Saturday, December 26, 2020

My very brief summary of Basel I, II, III history... and my hopes for a future Basel IV

1988 Basel I (30 pages) decreed risk weighted bank capital requirements with risk weights of 0% the sovereign and 100% citizens, which de facto indicates bureaucrats know better what to do with credit they’re not personally responsible for than citizens.


2004 Basel II (251 pages), (creative capital minimizing/leverage maximizing financial engineers, fooled regulators into believing that the buildup of those excessive exposures that could endanger our bank systems, is done with assets perceived as risky.

2010 Basel III (the current version has so many pieces it’s hard to say how many pages it contains but it's at least 1.600), some small gestures of rationality like a leverage ratio and countercyclical capital buffers BUT, on the margins of bank capital requirements, which is where it most counts, Basel I's and Basel II's distortions are alive and kicking.

202X Basel IV, lets pray they throw Basel I, II and III out, and set a fix bank capital requirement of 10%-15% on absolutely all assets. That would allow the so much needed traditional bank loan officers to return to the banks

Sunday, December 20, 2020

Small businesses (like restaurants) besides Covid-19 lockdowns, when it comes to bank credit, these have also for a long time suffered lockouts

Before Basel Committee’s risk weighted capital requirements, if a residential mortgages and loans small businesses produced the same risk adjusted expected net margin/return on asset (eROA), these would produce the same risk adjusted expected returns on equity (eROE)

That was then: Now, with Basel III a residential mortgage with e.g., a loan to value of 80% to 90%, has a risk weight of 40%; which times the basic 8% requirement, results in a capital requirement of 3.2%, which allows banks to leverage 31.25 times their capital (equity).

While a loan to small businesses have a risk weight of 100%; which results in a capital requirement of 8%, which allows banks to leverage 12.5 times their capital.

So, if the eROA for residential mortgages and loans to small businesses is 1%, then residential mortgages produce a eROE of 31.25%, while loans to small businesses only a eROE of 12.5%

And so, even if interest rates on residential mortgages were reduced by e.g. 0.5%, resulting in a lower risk adjusted expected ROA of 0.5%, residential mortgages, yielding banks a 15.625% risk adjusted eROE, would still be more interesting to banks than loans to small businesses

And therefore, small businesses, in order to access credit, must pay higher interest rates so as to increase the expected risk adjusted ROA, in order to produce banks a competitive risk adjusted eROE.

And so, though the less creditworthy (small businesses/entrepreneurs) always got smaller bank loans and paid higher interest rates but, with risk weighted bank capital requirements, the regulator also decreed them to be less worthy of credit.

What’s the net result of all this? Too much credit at too low interest rates for the purchase of houses, and too little credit to the small businesses/entrepreneurs who could generate the jobs/the incomes/the down-payments, for house buyers to service their mortgages and pay food and utilities.

Conclusion: The risk weighted bank capital requirements have, de facto, 0% to do with credit risk reduction, and 100% to do with risk generating distortions.


Basel Committee… Good Job!

PS. There has too be and adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth.