Thursday, December 8, 2016

That banks allocate credit efficiently to the real economy is more important than avoiding bank failures

“THE MINNEAPOLIS PLAN reduces the risk of financial crises and bailouts to as low as 9 percent, at only a modest economic cost relative to the typical cost of a banking crisis. 

The Minneapolis Plan will (a) increase the minimum capital requirements for “covered banks” to 23.5 percent of risk- weighted assets, (b) force covered banks to be no longer systemically important—as judged by the U.S. Treasury Secretary—or face a systemic risk charge (SRC), bringing their total capital up to a maximum of 38 percent over time, (c) impose a tax on the borrowings of shadow banks with assets over $50 billion of 1.2 percent for entities not considered systemically important by the Treasury Secretary and 2.2 percent for shadow banks that are systemically important, and (d) create a much simpler and less burdensome supervisory and regulatory regime for community banks”

NO! Except for (d) “a simpler and less burdensome supervisory and regulatory regime for community banks” the Minneapolis plan suffers from the same fundamental mistake of current bank regulations. 

It fixates itself on avoiding bank failures, while entirely ignoring the much more important social purpose of the banks, that of allocating credit efficiently to the real economy.

To achieve that is impossible, while using risk weighting based on ex ante perceived risks to determine capital requirements. 

Would the Minneapolis Fed be able to provide me the answers to those questions the Basel Committee and the Financial Stability Board refuse to even acknowledge?

PS. And in any adjustment plan grandfathering existing capital requirements for the existing assets held by the banks would be required, so as to not risk contracting the credit market excessively. 

FSB’s Mark Carney is no one to lecture us on inequality, lack of opportunities and intergenerational divide

Mark Carney, the Governor of the Bank of England, in a speech titled “The Spectre of Monetarism” December 5, 2016 said: 

“For both income and wealth, some of the most significant shifts have happened across generations. A typical millennial earned £8,000 less during their twenties than their predecessors. Since 2007, those over 60 have seen their incomes rise at five times the rate of the population as a whole. Moreover, rising real house prices between the mid-1990s and the late 2000s have created a growing disparity between older homeowners and younger renters...  At the same time as these intergenerational divides are emerging, evidence suggests that equality of opportunity in the UK remains disturbingly low, potentially reinforcing cultural and economic divides.”

But Mark Carney is also the current Chairman of G20’s Financial Stability Board and, as such, one of the primarily responsible for current bank regulations… the pillar of which is the risk weighted capital requirements for banks.

That piece of regulation decrees inequality resulting from negating “the risky”, like SMEs and entrepreneurs fair access to bank credit. 

That piece of regulation favors the financing of “safe” basements where jobless kids can stay with their parents over “riskier” ventures that could provide the kids in the future the jobs, so that they had a chance to become responsible parents too.

That piece of regulations is a violation of that holy intergenerational bond Edmund Burke spoke about.

Carney also said: “Higher uncertainty has contributed to what psychologists call an affect heuristic amongst households, businesses and investors. Put simply, long after the original trigger becomes remote, perceptions endure, affecting risk perceptions and economic behaviour. Just like those who lived through the Great Depression, people appear more cautious about the future and more reluctant to take irreversible decisions. That means less willingness to put capital to work and, ultimately, lower growth.”

If any have suffered form “affect heuristic” that is the bank regulators. Mixing up ex ante perceptions with ex post possibilities, these decided on “more risk more capital – less risk less capital”, without: defining the purpose of banks “A ship in harbor is safe, but that is not what ships are for.” John A Shedd; or looking at what has caused bank crises in the past “May God defend me from my friends, I can defend myself from my enemies” Voltaire

Mark Carney also said “For two-and-a-half centuries, the prices of government bonds and the prices of equities tended to move together: the typical bull market entails rising equity prices and falling bond yields, with the reverse in bear markets. Since the mid-2000s, however, this pattern has reversed and bond yields have tended to fall along with equity prices”.

He is not able to connect that to the fact the risk weight given to sovereign debt is 0%, as compared to one of 100% for We the People… and that capital scarce banks therefore shed “riskier” assets in favor of public debt. As statist, Carney also ignores the fact that regulation has subsidized public borrowings, paid of course by negating credit opportunities to SMEs and entrepreneurs.

Monday, December 5, 2016

Here is the succinct but complete explanation of the subprime crisis. One, which apparently should not be told.

Just four factors explains it all, or at least 99.99%.

Securitization: The profits for those involved in securitization are a function of the betterment in risk perceptions and the duration of the underlying debts being securitized. The worse we put in the sausage – and the better it looks - the more money for us. Packaging a $300.000, 11%, 30 year mortgage, and selling it off for US$ 510.000 yielding 6% produces and immediate profit of $210.000 for those involved in the process.

Credit ratings: Too much power to measure risks was concentrated in the hands of some very few human fallible credit rating agencies.

Borrowers: As always there were many financially uneducated borrowers with needs and big dreams that were easy prey for strongly motivated salesmen, of the sort that can sell a lousy time-share to a very sophisticated banker. 

Capital requirements for banks. Basel II, June 2004, brought down the risk weight for residential mortgages from 50% to 35%. Additionally, it set a risk weight of only 20% for whatever was rated AAA to AA. The latter, given a basic 8%, translated into an effective 1.6% capital requirement, which meant bank equity could be leveraged 62.5 times to 1.

Clearly the temptations became too much to resist for all involved.

The banks, like the Europeans, thinking that if they could make a 1% net margin they could obtain returns on equity of over 60% per year, went nuts demanding more and more of these securities; and the mortgage producers and packagers were more than happy to oblige, signing up lousier and lousier mortgages and increasing the pressure on credit rating agencies.

Of course it had to end bad... and it did!

Can you image what would have happened if the craze had gone on one year more?

I have explained all the above in many shapes or form, for much more than a decade. Unfortunately it is an explanation that is not allowed to move forward, because it would put some serious question marks about the sanity of some of the big bank regulators.

Might I need to go on a hunger strike to get some answers from the Basel Committee and the Financial Stability Board?

Saturday, December 3, 2016

Must one go on a hunger strike to have the Basel Committee or FSB answer some very basic questions?

Before regulating banks did you ever define their purpose? I know we all want them to be safe but, as John Augustus Shedd said: “A ship in harbor is safe, but that is not what ships are for.” 

By allowing for different capital requirements based on ex ante perceived risks of assets, banks will be able to leverage their equity (and the support given by authorities) differently, which will cause quite different expected risk adjusted returns for different assets, than would have been the case in the absence of this regulation. Were you never concerned about how this would distort the allocation of bank credit to the real economy? 

Since ex ante perceived risk were already considered by bankers when deciding on the amounts of exposures and interest rates, when you decided that the perceived risk was also going to determine capital requirements, you doubled up on perceived risk. Don’t you know that any risk, even if perfectly perceived, causes the wrong actions if excessively considered? 

In the case of larger and more “sophisticated” banks, you allowed these to use their own internal risk models to determine capital requirements. Was it not naïve of you to believe banks would not naturally aim for lower capital requirements, in order to increase their expected risk adjusted returns on equity?

What’s perceived as safe can be leveraged into being utterly dangerous, only because of that perception; while what’s perceived as risky is automatically less dangerous, precisely because of that perception. Or as Voltaire said: “May God defend me from my friends, I can defend myself from my enemies”. In this respect can you explain the logic behind your standardized Basel II risk weights of 20% for what is AAA to AA rated, and 150% for what is rated below BB-? 

In the same vein what empirical research did you carry out to determine that what is perceived ex ante as risky has caused major bank crises? I ask because as far as I know these have always been caused by unexpected event, like natural disasters or devaluations, by fraudulent criminal behavior, or by excessive exposures to what ex ante was considered as safe but that ex post turned out to be very risky. 

A risk weight of 0% for the sovereign, and 100% for We the People clearly implies you believe government bureaucrats make better use of bank credit than the private sector. Are you really such statists? Did you never consider that such dramatic rearrangement of economic power needed approval by for instance Congress or Parliament… or even a referendum? 

Finally do you really believe that with such risk adverse regulations for banks, layered on top of banker’s own risk aversion, our economies would have developed as they did?

Tuesday, November 29, 2016

François Villeroy de Galhau, I don’t think you have earned the right to quote Ortega y Gasset

François Villeroy de Galhau, Governor of the Banque de France, when addressing The Asociación de Mercados Financieros Annual Financial Convention in Madrid on November 21, 2016 ends his “Europe facing a new political economy” by quoting José Ortega y Gasset, the famous Madrid-born philosopher:

“Life is a series of collisions with the future; it is not the sum of what we have been, but what we yearn to be”. 

Absolutely Mr Villeroy de Galhau. But what are we to say of bank regulators like you who with their risk weighted capital requirements, give banks great incentives to earn the highest risk adjusted returns on equity when refinancing the "safer" past and present, so as to make them stay away from any collision resulting from financing a "riskier" future.

Monday, November 28, 2016

Why such hullabaloo about Trump’s at view of everyone conflicts of interest, while ignoring the bank’s hidden ones?

We all know that Trump is going to be subject to so much scrutiny that his “conflicts of interest” might even suffer. 

But on the large banks’ outrageous conflicts of interest, namely being able to use their own models to partially determine the capital they need to hold, on that everyone keeps mum. Why?

The lower the risk is calculated, the lower is the capital requirements, the higher is the allowed leverage, and so the better are the banks perspectives on obtaining high risk adjusted returns on equity. If that’s not a mother of a conflict of interest what is?

The “Stockholm Statement” by thirteen economists, including four former Chief Economists of the World Bank, is shamefully lacking.

The Stockholm Statement is shamefully lacking.

That is foremost so because chief economists of the World Bank, the world’s premier development bank, should know that risk-taking is the oxygen of any development; and should know that when banks were subjected to Basel Committee’s regulations, a distorting risk aversion was introduced.

To allow banks to hold less capital and therefore to leverage more their equity with what is ex-ante perceived, decreed or concocted as safe, than with what ex ante is perceived as risky; which allows banks to earn higher risk adjusted returns on equity on what’s “safe” than on what’s “risky” stops banks from financing the riskier future and cause these to settle on refinancing the “safer” past and present.

To force banks to hold more capital when lending to those perceived as risky, is a sure way to deny the weaker the opportunities of accessing bank credit and is therefore a decree to increase inequality.

To even suggest that the risk weighted capital requirements for banks is compatible with “leaving it to the market to do the rest” is as senseless as it gets. To argue: “The trend towards unfettered markets of the last quarter century explains a range of outcomes the world is now living with, including financial crises”, is not wanting to see what happened. Financial crisis are never caused by excessive exposures to what is ex ante perceived as risky; these are always the cause of unexpected events, criminal behavior or excessive exposures to what was ex ante perceived, decreed or concocted as safe… like AAA rated securities… like sovereigns like Greece.

Had this regulation introduced with the Basel Accord in 1988 been in place earlier, the world would have developed much less. Now perhaps these thirteen economists think that would have been better.

1997 in an Op-Ed I wrote: “If we insist in maintaining a defeatist attitude which definitely does not represent a vision of growth for the future, we will most likely end up with the most reserved and solid banking sector in the world, adequately dressed in very conservative business suits, but presiding over the funeral of the economy. I would much prefer the regulators to put some blue jeans on and try to help to get the economy moving.” 

In April 2003, as an Executive Director of the World Bank I formally opined: "The Basel Committee dictates norms for the banking industry that might be of extreme importance for the world’s economic development. In its drive to impose more supervision and reduce vulnerabilities, there is a clear need for an external observer of stature to assure that there is an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth” 

Unfortunately no such external observer was ever present…. Worse the distortions these regulations produce in the allocation of bank credit to the real economy are not even discussed.

Friday, November 18, 2016

Jeb Hensarling asks: How we can make the economy work for working people? Here’s my answer:

Jeb Hensarling, the chairman of the Financial Services Committee asks: How we can make the economy work for working people

Here’s my answer:

Get rid of the risk-weighted capital requirements for banks!

These only distort the allocation of bank credit to the real economy.

These only help finance the “safe” basements where jobless kids can live with their parents but not the “risky” new job creation they would need to afford to become parents too. 

These stop banks from financing the risky future and make these only refinance the "safer" past and present.

Where would America, the Home of the Brave, have been if its banks had been subjected all the time to this type of regulatory risk aversion?

A ship in harbor is safe, but that is not what ships are for.” John A Shedd, 1850-1926

The risk weighting has de facto decreed inequality

God make us daring!

Besides it is all for nothing. Bank crisis are caused by unexpected events, criminal behavior and excessive exposures to what was ex ante perceived as very safe when placed on the banks’ balance sheets, but that ex post turned out to be very risky. Never ever are bank crisis the result from excessive exposures to what was ex ante perceived as risky. May God defend me from my friends, I can defend myself from my enemies” Voltaire

Now, if you are rightly concerned that getting rid of the risk weighting would initially create such bank capital shortages that it would put a serious squeeze on credit; then grandfather the current capital requirements for all their current assets, and apply a fixed percentage, like for instance 8%, on all new assets… including public debt, since a 0% risk weight for the Sovereign and 100% for We the People seems to me, I beg your pardon, an insult to your Founding Fathers.

Finally, if regulators absolutely must distort, so as to think they earn their salaries, may I suggest they use job-creation and environmental-sustainability ratings instead of credit ratings, which are anyhow already cleared for by banks.

Europe beware, to reward banks for less risky business models is way too risky and no way to build a future.

I now read that Valdis Dombrovskis, the EU’s financial-services chief said it’s important to make sure the rules continue to “reward banks with less risky business models” “Bank Regulators Face Santiago Showdown on Capital Overhaul” Bloomberg, November 17.

NO! That is precisely what is wrong with current risk weighted capital requirements for banks. It guarantees that safe-havens will become dangerously overpopulated against little bank equity; and that for the economy more productive though riskier bays, like SMEs, will remain equally dangerously unexplored.

It guarantees the building of many basements for jobless youth to stay with their parents and not the financing of the job creation that could allow those kids the possibility to afford being parents too.

It hinders the financing of the riskier future in order to refinance the “safer” present and past.

Risk-taking is the oxygen of all development. Where would Europe be if these regulations had been with us since banks' inception more than 600 years ago?

If banks cannot afford to immediately adjust their capital to larger capital requirements and so therefore credit to the economy would be affected, grandfather the current requirements for all existing assets, but then see to that all new bank assets are freed from the distortions the risk weighted capital requirements produce.

Should regulators stop banks from using their own risk models to set the capital requirements? Of course they should! That whole notion is about as silly as it gets. It is like allowing children to decide on the nutrition value of ice cream, chocolate cake, broccoli and spinach.

Any risk manager that has any idea of what he is doing, begins by identifying clearly the risks that one cannot afford not to take. The risk that banks take allocating credit as efficiently as possible to the real economy, is such a risk.

PS. Besides it would be so useful if regulators just looked at what has caused all major bank crisis in history; namely unexpected events, criminal behaviour and excessive exposures to what was ex ante perceived as very safe when placed on the banks’ balance sheets but that ex post turned out to be very risky. Never ever have bank crises resulted from excessive exposures to what was perceived as risky. Therefore the current Basel risk weights of 20% for AAA rated and 150% for the below BB- rated is as loony as it gets.

PS. And if regulators absolutely must distort, so as to feel they earn their salaries, may I suggest they use job-creation and environmental-sustainability ratings, instead of credit ratings that are anyhow cleared for by bankers.

PS. And frankly, is not 0% risk weight for the sovereign and 100% for We the People too statist, even for Europe?

Wednesday, November 16, 2016

Bank regulators, don’t try now to hide your responsibility for failures behind sophistications. It was pure hubristic ineptitude.

I refer to Andy Haldane’s “The Dappled World” 

Bank regulators don’t try now to sophisticate the reasons you all got it so very wrong. These were very simple.

You did not define the purpose of banks before regulating these.

You ignored to study why banks fail and kept to why bank assets fail, which of course is pas la meme chose.

You ignored that banks look to maximize their risk-adjusted returns on equity, before distorting the allocation of bank credit with your risk-weighted capital requirements for banks.

You ignored the monstrous systemic risks that putting so much decision power into the hands of so human fallible credit rating agencies implied.

You imposed you statist ideological preferences with the risk weights of 0% for the Sovereign, and 100% for We the People.

No! Anyone who has ever walked on main-street, and seen the difficulties those perceived as risky have in accessing bank credit would have understood how loony these regulations were. Frankly, you do not have to be a PhD for that 

Monday, November 14, 2016

Ms. Elizabeth Warren, the banking system is rigged; foremost in favor of the State and banks, and against the young.

Senator Elizabeth Warren, in remarks given to AFL-CIO council on November 10, while trying to explain what lay behind the election of Donald Trump as president said: “Working families across this country are deeply frustrated about an economy and a government that doesn’t work for them. Exit polling on Tuesday found that 72 percent of voters believe that, quote, ‘the American economy is rigged to advantage the rich and powerful.’ The polls also made clear that the economy was the top issue on voters’ minds. Americans are angry with a federal government that works for the rich and powerful and that leaves everyone else in the dirt.”

Yes, the American economy is rigged, but at least with respect to the bank system, not exactly in the way most believe it is. I explain.

For the purposes of setting the capital requirements for banks, regulators, the Basel Committee, have decided, among others, on the following risk weights:

The sovereign (the central government and its bureaucrats) = 0%
Those rated AAA to AA (the AAArisktocracy) = 20%
Houses = 35%
The not rated, like citizen’s and SMEs = 100%
Those rated as extremely risky, like below BB-, = 150%

A lower risk weight results in having to hold less capital (equity); 
That means bank can leverage their equity more; 
That results in banks earning higher risk adjusted returns on equity; 
That therefore means banks will lend much more to what has a low capital requirements; 

In this case that means banks will lend much more than they would otherwise have done, to what is perceived, decreed or concocted as safe; and much less than the would otherwise have done to what is ex ante perceived as risky.

And so Yes! The banking system is rigged.

First and foremost, rigged in favor of the State; suggesting that when government bureaucrats use bank credit they do so much more efficiently, and generate much less risk, than if similar credit is used by the private sector/We the People.

Then rigged in favour of the banks; because being allowed to make the highest risk adjusted returns on equity on what is perceived as safe, must be a dream come true for all those bankers, described by Mark Twain, as wanting to lend you the umbrella when the sun was out, and wanting it back as soon it looked it could rain

Rigged in favor of the AAArisktocracy; by believing that a few human fallible credit rating agencies will always get it right, and that credit ratings, based on an ex ante very low risk perception, guarantees a very low ex post risk.

Rigged in favour of those buying houses, for instance basements were unemployed youth can live with their parents.

It is rigged against We the (risky) People

It is rigged against SMEs and entrepreneurs; negating the “risky” credit opportunities, it is a major driver of inequality.

It is foremost rigged against the young; because it makes banks refinance more their parents “safer” past and present, than their “riskier” future.

And all that risk aversion... in the Home of the Brave. America would never ever have become what it is, with this senseless bank regulation. Risk-taking is the oxygen of all development. 

God make us daring!

Saturday, November 12, 2016

Olivier Blanchard agrees there is a need for more research on whether bank regulations have distorted

In the IMF’s Annual Research Conference during the final Economic Forum: Policy challenge after the Great Recession I had the chance to pose Olivier Blanchard a question session of Professor Lawrence Summers Mundell Fleming Lecture I had a chance the pose a question (1:01:10)

My Question: 

I might insist here briefly on a point: Why do you say that interest rates on public debt are low, when they are based on so much of regulatory subsidies? Add to the zero low rates of the public debt, all those costs that comes from not giving SMEs and entrepreneurs, millions of them, the chances for credit, only as a result of this distortions produced by risk weighted capital requirements for banks.

Olivier Blanchard answer: 

This is a theme that you have explored over the years. You are absolutely right that the answer is: if the very low safe rates is due to distortions, then the first order of business, should be to eliminate the distortions.

That’s true, if your right, of regulations, but it may be true of the lack of social insurance in some countries which leads people to basically be willing to save enormous amounts that they should not be saving, it could also be true because of missing markets. 

For all this reason you are absolutely right, step zero in what I say, lets make sure that we have removed all the distortions which we can, which affect r, so we have the right r. I take your point.

My afterthoughts: 

I sure appreciate Olivier Blanchard's acceptance of the relevance of my concerns, its been a long trip. In 2004 in a letter in the Financial Times I wrote “How many Basel propositions will it take before they start realizing the damage they are doing by favoring so much bank lending to the public sector?" 

And I hope the research on it starts now, not only by the IMF. It is long overdue. In fact the possible distortions should have been analyzed before these regulations were imposed.

PS. The day earlier I had posed Professor Lawrence Summers a similar question

I did not understand all Professor Lawrence Summers answered me at IMF, but he sure understood less of what I asked.

In the IMF’s Annual Research Conference at the end of Professor Lawrence Summers' Mundell Fleming Lecture I had a chance the pose a question (1:18:25)

Here is the short explanation for my question:

Suppose banks believe that a 10% return on equity to shareholder’s resulting from lending to the sovereign is, in terms of risk, equivalent to a 25% return derived from a diversified portfolio of loans to SMEs.

Then if banks held on average 10% in equity, meaning a leverage of 10 to 1, banks would have to earn about 1% in net margins on sovereigns and on average 2.5% to SMEs to produce those desired ROEs.

But, then suppose that banks were told by regulators that though they must hold the usual 10% of equity against SME loans, they were now allowed to lend to the sovereign holding only 5% in equity, meaning an authorized 20 to 1 leverage. Then banks could produce that 10% ROE on equity by obtaining only a .5% net margin on sovereign loans. That would clearly but downward pressure on the interest rates paid on public debt.

And in 1988, with the Basel Accord, the regulators decided that the risk weight for the sovereign was 0% and that of SMEs 100... meaning banks were allowed to leverage equity immensely more with public debt than with loans to the private sector.

My question: Professor Summers, today you showed a graph that showed the risk free rate going down over the last 30 years, the risk free rate based on the proxy of public debt of course. And Lord Turner also recently showed that same trend. And it started around 1989/90. Can that not have anything to do with the very clear evidence that in 1988 the Basel Accord decided that for purposes of the risk weighted capital requirements for banks, the risk weight of the public sector, of the sovereign was 0%, and the risk weight for us, we the people, 100% 

Professor Summers' answer: Could it have anything to do with it? Yes it could have something to do with it. 

Notice that your explanation is in the category of Ricardo Caballero’s explanation. Its in the category of something has happened that has shifted the relative demand for government bonds versus other things.

And my argument is that, if that were true, what you would expect to see as the major counterpart to the decline in government rates is a major increase in risk premiums. And the fact is that I think is closer to right, a better first approximation I believe, to assume that risk premiums have been relative constant, or not long term trending, and that real rates have declined, than it is to believe that risk premiums have been long term trending.

And therefore I prefer the saving and investment based explanations, rather than the asset specific explanations of the kind that Ricardo adduces, or of the kind you suggest.

My afterthoughts: 

How is it possible to hold that such in favor of the public sector distorting bank regulations, would not have “shifted the relative demand for government bonds versus other things”?

How is it possible, like Professor Summer does, to use the “artificially low public sector debt rates”, as a justification of putting more financial resources in hands of government bureaucrats, to build infrastructure, than in the hands of the private sector’s SMEs and entrepreneurs?

Saturday, November 5, 2016

To lower the real real-interests in order to stimulate the real economy, take away the too costly subsidies of public debt.

Would any serious economist discuss gas prices at the pump ignoring taxes? No!

Would any serious economist discuss milk prices ignoring various subsidies? No!

Then why have almost all serious economists been discussing low real interest rates on public debt ignoring regulatory subsidies? I have no idea!

In 1988, the Basel Accord, Basel I, for the purpose of setting the capital requirements for banks, decided that the risk weight of the sovereign was 0% and that of We the People 100%. 

That would hence mean that banks would be able to leverage much more their equity, and the value of any explicit or implicit government guarantees they received, with loans to the public sector than with loans to the private sector. 

That would hence mean banks could obtain higher risk-adjusted returns on equity when lending to the public sector than when lending to the private sector.

That would hence mean that the interest rates of bank loans to the public sector included a regulatory subsidy.

That would hence mean that the subsidies for the access to bank credit by the public sector was to be paid by taxing the private sector with more restricted or more expensive access to bank credit.

And that should hence have meant that in order to know the real real-rate on public debt, to the nominal rates, we would have to add the cost of the regulatory taxes paid by the private sector.

That has not been done! All references to the interest rates of public debt have been limited to using the nominal rates. That has led experts like Lawrence Summers, Lord Adair Turner, Martin Wolf and many other, to argue that the public sector should take advantage of extraordinary low rates in order to finance public investments, like in infrastructure.

That is very wrong! If we include the economic cost of restricting the access to bank credit over the decade and around the world, for many millions of SMEs and entrepreneurs, the current real real-interests rates on public debt could in fact be the highest ever.

So, if the Fed, ECB, BoE or any other central bank, really wants to lower the interests in order to stimulate the real economy, then they should begin by asking bank regulators to take away those so very costly subsidies of public debt.

Central bankers might start doing this, in the name of equality, since making it harder than necessary for “the risky” to access bank credit, can only help to increase inequality. 

If bank regulators get too anxious and nervous about this, central bankers can (gently) remind them that there has never ever been a major bank crises caused by excessive exposures to what was ex ante perceived as risky. 

But what if the central banker also wears the hat of bank regulator? Then he has a problem he needs to solve… maybe with the help of some outside counseling assistance?

Friday, November 4, 2016

To the moral hazard of government guarantees, you should add any regulatory distortion hazard.

Because of current risk weighted capital requirements for banks, banks are allowed to leverage any government guarantees more with assets ex ante perceived, decreed or concocted as safe, than with assets ex ante perceived as risky.

So when government guarantees are awarded when this regulation is imposed on banks, something which clearly distorts the allocation of bank credit to the real economy, then you have to increase the moral hazard with the regulatory distortion hazard.

Professor Summers, fixing potholes using 0% public debt will not fix America. Don’t put the cart before the horse.

Professor Larry Summers, and many others with him, promote the idea that the government in America (and other governments too) should take advantage of the extraordinarily low interest rates on public debt, in order to finance new infrastructure and the maintenance of old.

Briefly their calculation is as follows: If government takes on debt at 0% and invest it in infrastructure projects that renders a 5% economic return, then the government, with a 30% tax on that, will have earned a net 1.5%... and we can all live happily ever-after.

NO! First, even if the government nominally pays 0% on its debt, that does not mean that debt has a zero cost. To begin with we should have to add the cost of all those giving up (cheated out of) some long term decent earnings on their saving, in order to finance the government for free. But, even more importantly, those zero or low rates are not free and clear market rates, but rates that are non-transparently subsidized by regulations.

In 1988, with the Basel Accord, Basel I; for the purpose of calculating the risk weighted capital requirements for banks, the regulators decided that the risk-weight for the sovereign was 0%, while that of We the People was 100%. And those risk-weights are still in full force.

I cannot say how much of the low interest rates on public debts are explained by this regulatory distortion, but it sure has to be quite a lot.

I have lately seen Professor Summers, and Lord Adair Turner, showing these rates trending down for the last 30 years. Unfortunately for reasons that are beyond my grasp, they have not been able to see a connection between this and 1988’s bank regulations.

But I do know that piece of egregious regulation, introduced such distortions in the allocation of bank credit that, worldwide, millions of SMEs and entrepreneurs have been negated the opportunities   provided by access to bank credit. That is a real huge cost that should be added to the nominal 0% rate. In other words the rates on public debt are the nominal rates, plus the economic and human costs of the distortions.

Since because of this regulatory risk aversion (even in the Home of the Brave) the economies are stalling and falling. So in this respect one could argue that in reality, never ever before have the interest rates on public debt been as high.

Which also leads me to my second objection, that of “infrastructure projects rendering a 5% economic return”. The final real return of any infrastructure project is a function of how it meets the needs of the economy, and of the state of the economy. If regulatory distortions impede the growth of the economy, those infrastructure projects, even if perfectly carried out, even if financed at 0%, might really turn out to provide a negative return.

Professor Summer, let us, very carefully, get rid of those regulatory distortions so that the banks of America, and those of the world, can return to the normality that was so rudely interrupted by regulatory hubris and statism in 1988. That would allow infrastructure to be financed by governments out of real economic growth, something that would then certainly even justify having to pay much higher nominal interest rates than now.

Please don’t put the cart before the horse! Don’t refuse “the risky” the opportunities to access bank credit only because they are risky. Our economies were all built on risk-taking, even when some of it was not adequately reasoned.

To lay on regulatory risk aversion on top of bankers natural risk-aversion, is an insult to intelligence and human wisdom.

Thursday, November 3, 2016

Why has IMF kept silence on what was done to banks in 1988?

What happened?

Before 1988, for about 600 years, bank exposures were a function of the by bankers ex-ante perceived risks (bpr), risk premiums (rp) meaning interest rates, and bankers’ risk tolerance (brt) 

Pre 1988 bank exposures =ƒ(bpr, rp, brt)

Bank credit was then allocated to what produced banks the highest expected risk adjusted return on equity

But 1998, with the Basel Accord, risk weighted capital requirements were introduced. With that bank exposures became a function of the: by bankers ex-ante perceived risks (bpr), risk premiums (rp), bankers’ risk tolerance (brt), and regulatory capital requirements (rcc), this last itself a function of the by regulators ex-ante perceived (or decreed) risks (rpr) and the regulator’s risk tolerance (rrt)

After 1988 bank exposures = ƒ(bpr, rp, brt, rccƒ(rpr, rrt))

Bank credit was thereafter allocated to what produced banks the highest expected risk/capital-requirement adjusted return on equity

And of course banking changed dramatically, and the allocation of bank credit to the real economy became hugely distorted.

With Basel II of 2004, which introduced risk weighting within the private sector, and made the process much dependent on credit ratings, the distortions and the systemic risks were dramatically increased.

Fundamental mistakes:

1. Although hard to believe, bank regulators never defined what the purpose of banks is before regulating these. A ship in harbor is safe, but that is not what ships are for.” John A Shedd, 1850-1926

2. Although hard to believe, as the purported reason was to make banks safer, the regulators never researched what had caused bank crisis in the past; namely unexpected events, criminal doings and what was ex ante perceived as very safe but that ex post turned out very risky. What is perceived as very risky is, precisely because of that perception, what is least dangerous to the system. May God defend me from my friends, I can defend myself from my enemies” Voltaire

3. Any risk, even if perfectly perceived, causes the wrong actions if excessively considered; and here the regulators doubled down on ex ante perceived risks.

4. Ignoring risk-taking is the oxygen of development. For banks to take risks, albeit in smaller amounts on “risky” SMEs and entrepreneurs, is absolutely vital for the economy to move forward, in order not to stall and fall. Where would we be had these regulations been in place during the previous 600 years? In April 2003 as an Executive Director of the World Bank I stated: “The Basel Committee dictate norms for the banking industry… there is a clear need for an external observer of stature to assure that there is an adequate equilibrium between risk-avoidance and the risk- taking needed to sustain growth.” In fact the risk of excessive risk aversion was the theme of my first ever Op-Ed

5. Little understanding of systemic risks: In January 2003 I wrote in Financial Times:Everyone knows that, sooner or later, the ratings issued by the credit agencies are just a new breed of systemic errors, about to be propagated at modern speeds. Friends, as it is, the world is tough enough.”

6. Little understanding of fragility: In April 2003, as an ED of the World Bank I stated: “A mixture of thousand solutions, many of them inadequate, may lead to a flexible world that can bend with the storms. A world obsessed with Best Practices may calcify its structure and break with any small wind.”

7. Little understanding of pro-cyclicality: When times are good, credit-risks seem low, so the risk-weighted capital requirements allow banks to expand more than they should; and when times are bad, the credit risk are naturally perceived higher, and so the capital requirements force banks to contract credit, precisely when less bank credit austerity is needed.

8. Macro-imprudence: Prudential regulation helps failed banks to fail expediently. Macro-imprudent regulation impedes failed banks from failing… which builds uphuge mountains of combustible materials waiting for a Big Bang.

9. Overreliance on data and models: In October 2004 in a formal statement at the World Bank I warned: “Much of the world’s financial markets are currently being dangerously overstretched through an exaggerated reliance on intrinsically weak financial models that are based on very short series of statistical evidence and very doubtful volatility assumptions.


Statism: Basel Accord’s risk weights of 0% for “The (infallible) Sovereign” and 100% for “We the (risky) People” introduced runaway statism. Since then the proxies for risk-free rates have been subsidized. We have no idea what the current low interest rates on much sovereign debt would be if government bureaucracy bank borrowings were affected by a risk-weight similar to SMEs’. De facto those risk-weights imply that regulators believe public bureaucrats know better what to do with bank credit, than the private sector.

Crisis resulting from dangerous overpopulation of “safe” havens: The first crisis, that of 2008, resulted from excessive exposures to AAA rated securities (Basel II risk weight 20% = allowed leverage 62 to 1), sovereigns like Greece, and residential housing (Basel II risk weight 35% = allowed leverage 32 to 1)  

Stagnation: Banks have stopped financing the riskier future and basically keep to refinancing the safer past and present. As an example banks finance much more “safe” basements where jobless kids can stay with their parents, than the SMEs that could create the jobs that could allow the kids afford to also become parents. In short this regulation keeps Keynes' animal spirits caged.

Stimulus waste: Since credit will not flow were they could most be needed, much of the stimuli fiscal deficits, quantitative easing and low interest could produce, is wasted.

More inequality: The result of making it harder and more expensive for the “risky” weaker to access opportunities of bank credit for productive purposes.

Too Big Too Fail: Clearly minimalistic capital requirements, for so many assets, has served as a potent growth hormone for the TBTF banks.

Over indebtedness: By allowing ridiculously low capital requirements for assets perceived as safe, the regulators allowed banks to leverage too much their equity and the support they received from society (taxpayers). That facilitated the current generation to extract more borrowing capacity to sustain its own consumption than any other previous generation. That has left little borrowing capacity over for the future generations.

What to do?

To accept the problem exists!

To know neither Hollywood nor Bollywood, would allow new movies on the same theme to be produced by directors and scriptwriters responsible for such box-office flops as Basel I-II-III.

To understand that bank capital requirements would be better if based on ex-post risks of models based on ex-ante risk perceptions.

To know that if you absolutely must distort, it is better to do so based on some useful social purpose, like based on job-creation and environmental-sustainability ratings.

To understand that getting our banks and our economies out of the Basel mess is a very delicate process, which does not permit an ounce more of that technocrats’ hubris that caused it all.

IMF, will you keep on being silent on this?

Per Kurowski