October 22, 2016

I am a whistleblower on Basel Committee’s monstrous mistakes, but FT might not have seen my 2.375 letters either

Sir, Ben McLannahan discussing whistleblowers and the fake-account scandal at Wells Fargo writes: “One even wrote an email in exasperation to John Stumpf, the former chairman and chief executive. (He said he had not seen it.)” “Providing incentives for whistleblowers will improve bank culture” October 21.

Well I have been denouncing, for over a decade, among other with 2.375 letters to FT, this one not included, that the risk weighted capital requirements for banks concocted by the Basel Committee for Banking Supervision and supported by the Financial Stability Board, and not questioned by for instance IMF, is a dangerous monstrosity.

Not only does it distort the allocation of bank credit to the real economy, but it also does so for no good purpose at all, since major bank crises never result from excessive exposures to something that was perceived as risky when booked.

Perhaps one of these days its editor, and many of its columnists, will also argue they never saw these letters.

If someone who like me has argued consistently and extensively against these globally imposed regulations, cannot be helped by a Financial Times to at least obtain from the regulators clear and unequivocal the responses to his objections, then it could seem those regulators might also be using some very insidious pressures to silence those who “Without fear and without favour” are supposedly best equipped to give whistleblowers some voice.

@PerKurowski ©

October 21, 2016

Europe beware, Mario Draghi and his buddies are playing “she loves me - she loves me not” with your future

Sir, I refer to Claire Jones reporting on Mario Draghi’s difficulties on deciding what to do “to come up with a stimulus package that convinces markets the ECB is doing enough both to keep the fragile recovery on track and to keep hawks on his governing council onside”, “ECB has six weeks to update QE, says Draghi” October 21.

Mario Draghi was the former chair of the Financial Stability Board, and is the currently the President of the European Central Bank and chair of the Group of Governors and Heads of Supervision of the Basel Committee for Banking Supervision. No doubt that in the area of high-finance, Draghi is about as important as one can be… perhaps more important than one should be allowed to be.

Because Mario Draghi, though he might be a very knowledgeable technocrat, in the sense that he knows for instance that it can be quite risky for a bank to lend to an unrated SME, something with which all bankers would agree, is unfortunately not sufficiently wise to understand that what is for instance rated as super-duper safe AAA, is what can be truly dangerous for banks, precisely because bankers do also not think that to be dangerous.

And unfortunately Mario Draghi, like his regulatory technocrat buddies, seems also to have missed out on a Finance 101 course. That because seemingly he does not understand that when you allow banks to leverage more their equity, and the support these receive from society, with assets that are perceived safe than with assets perceived risky, banks will invest more than usual in what’s safe, because there is where it will obtain higher expected risk adjusted returns on equity. And the consequences of that are twofold, and both negative. First it leads to dangerously overpopulating the safe havens, and second, equally dangerous, especially for the real economy, to underexploring those risky bays where SMEs and entrepreneurs reside. 

As an example, the risk weight the Basel Committee has assigned to the financing of residential housing is 35%, while that for unrated SMEs is 100%. This causes banks to finance the basements where the kids can live with their parents, but not the necessary job creation required for the kids to be able to become themselves parents in the future.

It is truly shameful! Europe (and world) wake up!

@PerKurowski ©

In order to revive the pioneering spirit of America, start by kicking out dangerous risk adverse bank regulators

Sir, Gillian Tett writes: “The US used to be renowned for having a more flexible and mobile workforce than Europe; in previous centuries millions of people travelled in search of land, riches and jobs. But mobility has declined… [and] if mobility keeps falling, the sense of political polarisation and rage in [some] places will rise”, “The pioneering spirit America would do well to revive” October 21.

Ms Tett argues that this is all a bit counterintuitive since “the internet is supposed to have created a hyperconnected world that makes it easier to connect workers with far-flung jobs”.

Not necessarily, for instance we do not know how many can thanks to Internet be working somewhere else, without having to move. Also, much the same way internet can inform about existing job opportunities, it can make it much harder to sell those illusions of other green valleys that stimulated much mobility in the past.

As a possible countermeasure Tett advances that “The next president may also need a 21st-century version of the 1862 Homestead Act — which offered land to settlers who went west — and find new ways to encourage workers to relocate.”

Ms Tett should not forget that “land” to settlers is just a resource, just like bank credit is; and that we live in a world where mindless risk adverse regulators, with their risk weighted capital requirements, have de facto hindered credit mobility; telling the banks to stay where it seems safe, and not to go where it could be risky.

For the umpteenth time I quote from John Kenneth Galbraith’s “Money: whence it came, where it went”,1975:

“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] 

It was an arrangement which reputable bankers and merchants in the East viewed with extreme distaste… Men of economic wisdom, then as later expressing the views of the reputable business community, spoke of the anarchy of unstable banking… The men of wisdom missed the point. The anarchy served the frontier far better than a more orderly system that kept a tight hand on credit would have done…. what is called sound economics is very often what mirrors the needs of the respectfully affluent.”

Clearly, the Basel Committee and the Financial Stability Board represent Galbraith’s “men of economic wisdom… [who serve] the needs of the respectfully affluent”.

So, if Ms Tett really wants the pioneering spirit of America to revive, then she should start by wanting to also allow credit to move freely; condemning the dangerous mumbo-jumbo preaches of the Basel Committee and the Financial Stability Board. That would in essence mean using one single percentage capital requirement for all assets, no matter in which risk-land these assets reside.

Unfortunately Ms Tett (and you too Sir) has been steadfastly mum on the issue of the regulatory distortion of bank credit, no doubt defending (“without favor”) her choice of “wise men” with their affluent and mostly Davos settled constituency.

“Wise men”? To know that unrated SMEs are risky to banks, is of knowledgeable men; but to understand that AAA rated assets are dangerous to bank systems, is of wise men.

@PerKurowski ©

October 20, 2016

The low interest rates on public debt that underpins so many requests for public investment projects, are artificial

Sir, Stefan Gerlach writes: “there are many public investment projects that have a higher return than funding costs, given the low level of interest rates. In this case, the idea that undertaking the investment project will raise income and make the economy better able to weather a future storm is not a debatable proposition from economic theory, it is a tautology.” “Even good economic stewards should heed sound arguments” October 20.

“Low level of interest rates”? Yes, but totally artificial! Those are the result of QEs; and of risk-weighted capital requirements for banks that so much favor the sovereign (0% risk weight) over We the People (100% risk weight)

Much of that non-transparent regulatory subsidy of the sovereign is paid by millions of SMEs and entrepreneurs, by means of less and more expensive access to bank credit. Take those clothes off the Emperor and you would see quite a lot of his frightening nakedness.

Gerlach also writes: For anyone interested in economic history, it is hard not to think about how the management of the financial crisis will be assessed by future monetary historians.”

Indeed, and one question those historians will surely make is: After about 600 years of banking, why did regulators in 1988 with Basel I, and later much more in 2004 with Basel II, introduce risk weighted capital requirements that so dangerously distorted the allocation of bank credit to the real economy? 

Their answer must be… The regulators, in their mutual admiration club so prone to group thinking, had not the faintest idea about what they were doing. For a starter they never defined the purpose of banks before regulating these; and to make it worse, they never did empirical studies on what has caused previous bank crises, something which was never ever what was ex ante perceived as risky.

@PerKurowski ©

What is puzzling is that regulators, like Mark Carney, cannot see they might also be a source of huge systemic risk

Sir, Ed Crook, with respect to Mark Carney, the governor of BoE and the chair of FSB arguing last year that regulators need to address climate change promptly, quotes Daniel Yergin with: “It was puzzling that a central bank would choose to identify investment in this sector as a major systemic risk to the global financial system, when there are so many other more obvious and immediate risks” “Energy expert dismisses warnings of carbon bubble” October 20.

On occasions I myself have proposed slightly less capital requirements for banks based on environmental sustainability and job creation ratings, so that banks earn a little higher risk adjusted returns on lending when they are doing what many of us consider as social good. But I have always done that with much trepidation; as it clearly requires a lot of hubris to think you could intervene so without causing any unexpected negative consequences.

But the Basel Committee and FSB regulators suffer no such inhibitions. They have gladly gone ahead with imposing credit risk weighted capital requirements, all without the slightest consideration to how that could (and is) dangerously distort (for no purpose) the allocation of credit to the real economy.

In my homeland (Venezuela) we often refer to those who have been awarded power (or have given themselves powers) in order to engage in dangerous activities, as being monkeys with razorblades. That description applies perfectly well to regulators who are not eve aware of that their actions might in itself constitute the largest systemic risk for the financial system (and for the economy)
@PerKurowski ©

For UK to re-engineer its growth model, it needs to de-engineer its loony risk adverse bank regulation model

Sir, Alberto Gallo writes: “At the heart of Britain’s problems is its unbalanced growth model, centred on London and financial services, a lack of investment in sectors that boost productivity rather than asset prices, and the resulting inequality… Britain needs a plan to re-engineer its growth model” “UK must rebalance growth model to steer past Brexit iceberg” October 20

That is a very clear definition of the problem. Unfortunately, among the proposed solutions, Gallo leaves out what needs to happen with bank regulations.

In short, for the umpteenth time, the risk weighted capital requirements for banks hinder these from financing the riskier future, having them only refinancing the safer past. The risk weights of 0% the sovereign, 20% the AAArisktocracy, 35% residential housing and 100% unrated SMEs and entrepreneurs shouts out what is wrong… unfortunately too many, FT included, are blind or deaf.

Unless Britain eliminates the distortions in bank regulations that work against productivity it is doomed to like old soldiers to slowly fade away… living up, little by little, all its past economic achievements.

@PerKurowski ©

World Bank’s “Ease of doing business” rankings, ignores the regulatory distortion of bank credit

Sir, Rachel Sanderson writes: “Competitiveness has improved… Last year Italy climbed nine places in the World Bank’s “ease of doing business” rankings”, “Italy’s business chiefs buckle up for a shock as reform vote looms” October 20.

That World Bank report, great in many ways, with respect to “getting credit” does unfortunately omit considering whether bank regulations distort the access to bank credit or not.

And so the real main-street value of any recorded “ease of doing business” improvements can come to naught, if, for instance SMEs and entrepreneurs do not have fair access to bank credit; something which they don’t have in Italy, or in any other country that has been smitten by the Basel Committee’s dangerous and foolish risk aversion.

The pillar of current bank regulations is the risk weighted capital requirements. It allows banks to leverage their equity and the support they receive from society differently depending on the ex ante perceived risk. Less risk, more leverage, higher risk adjusted returns on equity.

So the following risk weights should suffice to understand what is going on… that is if you want to understand.

Risk weights: Sovereign 0%, AAArisktocracy 20%, residential housing 35% and the unrated “risky” SMEs and entrepreneurs, the fundamental drivers of the economy, 100%. What more could I say? Perhaps reminding anyone interested that no major bank crisis ever has been caused by excessive exposures to something that was ex ante perceived risky when booked.

Had these regulation been in place when banks originally began to operate in Italy, none of them, and neither the economies, could have developed as they have. 600 years of real banking and soon 30 years of loony Basel Committee reigned banking. Italia capisce?

@PerKurowski ©

October 19, 2016

Compared to the poor of Venezuela, PDVSA’s bondholders, as a group and over time, have benefitted way too much

Sir, Eric Platt and Robin Wigglesworth write that PDVSA’s Rafael Rodriguez, Mr del Pino’s chief of staff, appealing to the investors to take part in the proposed swap said: “We hope investors will support PDVSA in the same way that we have supported them for many years”, “Caracas piles on pressure for $5.3bn bond swap” October 19.

For the poor of Venezuela, who demonstratively might not have received more than 15 percent of their per capita share of Venezuela’s oil revenues, that is an insult. I don’t care one iota about these bondholders; as a group and over time they have benefitted way too much.

As an example, Elaine Moore and Simeon Kerr when recently reporting on an upcoming international bond issue of Saudi Arabia wrote: “a banker not involved in the (US$ 20bn) deal, estimates that Saudi Arabia will price at 150bp above US Treasuries for a five-year bond and 160 to 165 for 10-year debt”. “Saudi debt pitch focuses on youth and reform” October 18. Sir, compare that with what the land that advertises itself to have the largest oil reserves in the world, has to pay.

Sir, very high risk premiums paid by a sovereign debtor, might evidence that a government and its financiers, are in cahoots for some mutually benefitting corruption.

And please do not tell us PDVSA is not Venezuela, as like if Aramco is not Saudi Arabia.

@PerKurowski ©

The UK’s Financial Conduct Authority has got to be kidding, or it is just too dumb. Your choice Sir?

Sir, Caroline Binham writes: “Britain’s financial watchdog is clamping down on investment banks’ “misrepresentation” and league table inflation as part of efforts to stamp out conflicts of interest to ensure clients, particularly small companies, get a fair deal.” “UK regulator clamps down on banks’ moves to manipulate league tables” October 19.

It sounds important and seems correct, but also like a very bad joke. Here is “Britain’s financial watchdog”, one that gladly allows risk weighted capital requirements to be imposed on banks; that which curtails the access to bank credit of small companies, now coming out as a champion for the SMEs. It has got to be kidding, or it has to be dumb. Your choice Sir?

@PerKurowski ©

Mark Carney: Who should offset the credit distributional consequences of the risk/future adverse bank regulations?

Sir, Martin Wolf mentions that BoE’s Mark Carney, noted monetary policy has distributional consequences but “it is for broader government to offset them if they so choose”. “The unwise war against low interest rates” October 19.

The risk weighted capital requirements for banks has distributional consequences too, in this case with respect of bank credit.

For instance, a risk weight of 35% when financing residential housing, and a risk weight of 100% for loans to SMEs, helps the young to have more availability of basements in which to live with their parents, than perspectives of a new generation of jobs.

And the blatantly statist 0% risk weighting of the sovereign, skews the distribution of credit away from the private sector and towards government bureaucrats.

So the question is: Should we now try to add a new layer of non-transparent complications so as to try to offset those credit distributional consequences, or should we simply get rid of risk-weighted capital requirements altogether?

I clearly favor the latter option but, doing so, I have to continuously confront those who like Martin Wolf know, quite correctly, that a below BB- borrower is risky (150% risk weight) but, unfortunately, do not have the necessary wisdom to fathom that what’s AAA rated, and therefore only 20% risk weighted, is, or will be made by this, much more dangerous to bank systems.

Wolf also states: “Lower interest rates need not worsen pension deficits; that depends on what happens to the value of assets held by pension funds. Normally, lower interest rates should raise the latter. What would lower both real interest rates and asset prices is greater pessimism about economic prospects. Central banks do not cause such pessimism but try to offset it.”

That is so very wrong! The only moment when the value of assets held by pension funds is really important, is when these have to be sold in the market in order to access purchasing power for the pensioners. And with these risk weighted bank regulations that impede banks from financing the risky future, and have these only refinancing the safer past and present, you can bet that the future economy will not be strong enough to pay well for those assets.

Of course Wolf might think it is the bankers’ duty to overcome such regulations, but that would be to ignore completely the overriding objective of bankers which is to maximize the risk adjusted returns on equity (and their bonuses).

PS. On the issue of low interest rates, let me as a financial consultant with extensive main-street experience, remind you that few things stimulate projects to advance faster from plans into income generating realities, than high interest rates. Low interest rates feed a lot of project execution laziness into the active real economy.

@PerKurowski ©

October 18, 2016

Could it be current bank regulators are not held accountable because their mistakes are just too big to fathom?

Sir, Jonathan Ford with respect to Wells Fargo’s “misdemeanors” asks “why supposedly competent managers failed to join the dots”; and correctly states that “one reason why public confidence in Wall Street remains so low… [is that the] bosses are not held accountable” “If no bank is ‘too big to jail’, Wells Fargo bosses must face the music” October 17.

Now with respect to banks, their purpose and their stability, there are two very clear dots:

1. If you allow banks to leverage their equity, or the support they receive from society, more with some assets than with other, then you will distort the allocation of credit to the real economy.

2. What is dangerous for bank systems, is never what is ex ante perceived as risky, but always either some unexpected event, or the build-up of dangerous excessive exposures to something that ex ante was perceived as safe but that ex post turned out not to be.

So, if regulators impose capital requirements that allow banks to leverage more with assets ex ante perceived as safe, then I would hold that is clear evidence of them not being able to connect even the most basic dots. Should they not be held accountable? Of course they should, but they aren’t.

I fully agree with Ford’s opinion that even though “little money was taken” in Wells Fargo’s “misdeeds” being discussed “that doesn’t diminish the bank’s culpability”

But could it be though that some mistakes, like those committed by current bank regulators, are just so big they can’t even be discussed? If so, we, and foremost the next generations, are doomed.

@PerKurowski ©

With respect to realizing bank regulators do not know what they’re doing, FT has clearly not reached maturity.

Sir, Janan Ganesh writes: “Maturity is the realisation that adults do not know what they are doing. Grown-ups are not omniscient, just fallible humans trying their best in a difficult world.” “The markets hold more sway than May” October 18.

Indeed that is why in a letter you published in January 2003, before I became de facto censored by FT, I wrote: “Everyone knows that, sooner or later, the ratings issued by the [human fallible] credit agencies are just a new breed of systemic errors, about to be propagated at modern speeds.”

Here is the shorter version of the generally unknown lunacy of the current risk weighted capital requirements for banks:

1. If you allow banks to leverage their equity, or the support they receive from society, more with some assets than with other, then you will dengerously distort the allocation of credit to the real economy.

2. And all that distortion for nothing. What is dangerous for bank systems, is never what is ex ante perceived as risky, but always either some unexpected event, or the build-up of dangerous excessive exposures to something that ex ante was perceived as safe but that ex post turned out not to be.

You all in FT, grow up, mature, understand that current bank regulators haven’t the faintest on what they’re doing.

PS. Here again is a somewhat more extensive aide memoire on the monstrous mistakes of the current capital requirements for banks.

@PerKurowski Janan

Why is it so hard to understand that risks should not only be correctly perceived but also correctly considered?

Sir, Patrick Jenkins, discussing the Basel Committee’s push “to finalise another leg of post-crisis global financial reform” writes that “financial and economic stability is more important than a blinkered crackdown.”, “Basel Committee boss needs to reconsider hard line on reform” October 18.

What? “financial AND economic stability”? That’s a new one. Until now it has only been financial stability, which is why regulators (and journalists) have not cared to analyze how much current bank regulations distort the allocation of credit to the real economy. For instance Stefan Ingves, the chair of the Swedish Riksbank and of the Basel Committee, seems not to understand at all that the so much lower risk weight assigned to financing houses (35% in Basel II), when compared to the risk weight when financing SMEs (100%), has something to do with prices of houses going up and up, and the credits to SMEs going down and down.

Jenkins, on the possibility of part of the capital requirements to be based on the conduct of the banks, like misdeeds, argues: “The logic is flawed”, since “basing future capital demands on past fines duplicates the impact of a penalty”.

Indeed, but why Sir is it so hard for Jenkins, for the Basel Committee, for you and for all other in FT to understand that, basing capital requirements on ex ante perceived credit risks already cleared for by banks with interest rates and size of exposures, also “duplicates the impact” of perceived credit risks?

Is it really so hard to understand that any risk, even if perfectly perceived, causes faulty actions, if that risk is excessively considered?

@PerKurowski ©

FT: How much does the Basel Committee influence the property values in Europe?

Sir, I refer to FT Special Report on Property Europe October 18.

I wonder has anyone of the contributors to this report, or anyone else in FT for that matter, tried to figure out how much of the property values in Europe derives from the distortion produced by bank regulations?

Info: For the purpose of deciding the capital requirements of banks Basel II (and III) set a risk weight of 35% for when banks finance residential housing, and one of 100% for when banks finance the “risky” SMEs and entrepreneurs that are to help home buyers to find the jobs that will allow the house owners to pay their mortgages and the utilities.

Sure that has to mean something for the current and for the future value of properties in Europe. How much? I haven’t the faintest! Except that it’s a lot!

PS. In fact regulators make banks finance the “safe” basements where the young can live with their parents, not the new “risky” jobs they need Per Kurowski

@PerKurowski ©

October 17, 2016

How do politicians stand such failed technocrats as those in the Basel Committee and Financial Stability Board?

Sir, you quote BoE’s Mark Carney saying: “The objectives are what are set by the politicians. The policies are done by technocrats,” “Carney’s gentle reminder about BoE independence” October 17.

So let us assume that having banks perform the allocation of bank credit to the real economy as efficiently as possible, while at the same time ascertaining the stability of the banking sector, would be a reasonable objective set by the politicians. In fact I challenge you to find a politician who would dare to disagree with that objective.

But now let’s see what policies the technocrats, like Mark Carney, the current chairman of the G20s Financial Stability Board, and his colleagues on the Basel Committee have come up with.

They have imposed risk weighted capital requirements for banks that, allowing banks to leverage their equity and the implicit support these receive from society differently, based on ex ante perceived risks already cleared for, utterly distort the allocation of bank credit to the real economy.

And they designed that regulation based on the premise that what is ex ante perceived as risky is risky for the bank system, thereby completely ignoring all empirical evidences that clearly show that what’s really dangerous to the bank systems, is unexpected events and excessive exposures to what was ex ante perceived as safe but that ex post turned out to be very risky.

So the real question Sir would be: How do politician stand for such lousy technocrats?

@PerKurowski ©

October 15, 2016

Let’s see if Ms Tett’s recent enlightenment will now allow her to see the monstrosities of current bank regulations

Sir, Gilian Tett writes: “when the 2008 financial crisis hit, I decided that the only way for a country to avoid a massive banking crisis was to have regular, small bank failures. Frequent, tiny failures are perhaps the only thing that really stop regulators and bankers from getting too complacent.” “A vision of life through a dirty lens”, October 15.

In 2003, as an ED of the World Bank, in a workshop for regulators I argued:

“There is a thesis that holds that the old agricultural traditions of burning a little each year, thereby getting rid of some of the combustible materials, was much wiser than today’s no burning at all, that only allows for the buildup of more incendiary materials, thereby guaranteeing disaster and scorched earth, when fire finally breaks out, as it does, sooner or later.

Therefore a regulation that regulates less, but is more active and trigger-happy, and treats a bank failure as something normal, as it should be, could be a much more effective regulation. The avoidance of a crisis, by any means, might strangely lead us to the one and only bank, therefore setting us up for the mother of all moral hazards—just to proceed later to the mother of all bank crises.”

It would seem there is some coincidence between what I said then and with what Ms Tett later opines.

Yet, over the last decade, in about a hundred of letters commenting on articles by Ms Tett, I have warned her, and you Sir, about the horrendous distortions that the risk weighted capital requirements for banks produce in the allocation of credit to the real economy; and of that all that distortion fulfilled no stability purpose at all.

But Ms Tett, and you Sir, has steadfastly refused to even acknowledge the problem. Perhaps it is my fault. Perhaps my arguments need to be presented with much more ego stroking than what I thought necessary when communicated with experienced and famous journalists/columnists, or with newspapers, especially one that proclaims “Without fear and without favour”.

So I am curious now to see if Ms Tett’s self declared enlightening experience at some “bars in Hamilton County”, will now allow her to apply what she learnt in the anthropology classes at university, in order to allow her to clean up her glasses on the monstrosities of current bank regulations.

@PerKurowski ©

I would never receive an Ig Nobel. The research I propose would cause no laughs, only tears

Sir, it was with great interest I read Tim Harford’s discussion on the Ig Nobel price “In praise of ridiculous research” October 15.

I immediately thought of researching: why regulators did not define the purpose of banks before regulating these; why regulators did no empirical research on what causes bank crises before imposing credit risk weighted capital requirements for banks; why regulators never considered that allowing banks to leverage differently their capital, and the support they received from society base on the perceived risk of assets, would distort the allocation of bank credit to the real economy; why regulators did not understand that further reducing the opportunity of those who are perceived as risky to access to bank credit, could only increase inequality… and so on.

That research sure sounds ridiculous, can't be!, but in fact it "might actually tell us something about the world".

But then I entered into Ig Nobel’ site “Improbable.com” and read: “ Improbable research is research that makes people laugh and then think”

Clearly I would not qualify. These regulatory failings have and are producing too much suffering, and so the research I propose would never elicit laughs, only tears.

@PerKurowski ©

Elizabeth Warren, as a member of United States Senate Committee on Banking, might not perform entirely her own duties

Sir, Barney Jopson reports that Senator Elizabeth Warren is requesting the replacement of Mary Jo White as Chair of the Security and Exchange Commission “Warren wants SEC head fired for ‘undermining’ administration” October 15.

I have no opinion on how Mary Jo White has been performing her duties at the SEC but, the United States Senate Committee on Banking, Housing, and Urban Affairs, of which Ms Warren is a standing member, is lacking carrying out in its own responsibilities.

I hold that since to this date I have not seen any effort on part of that committee to ascertain if, and if so how much, the risk weighted capital requirements distort the allocation of bank credit.

This is not a minor issue. For a starter it could ask bank regulators for a full explanation of the risk weights of 0% when financing the sovereign (the King), 20% the AAArisktocracy, 35% housing and 100% “We the People” like SMEs and entrepreneurs, those with the best chances of generating the future jobs our grandchildren need. That regulatory credit risk aversion, layered on top of whatever risk aversion the bankers’ themselves can harbor, sounds as anathema as can be to the whole notion of the Land of the Free and the Home of the Brave.

Besides, the discrimination in access to bank credit that those risk weights produce, violates directly the spirit of the Equal Credit Opportunity Act (Regulation B). In that respect the committee should also ask the Consumer Financial Protection Bureau, CFPB, what it is doing about this.

With regulations, to favor banks lending to the “safer” past and present, over lending to the “riskier” future, is a clear violation of that holy social inter-generational bond that Edmund Burke spoke about.

To top it up, those risk weighted capital requirements do not serve one iota for making the banking system safer. All major bank crises result either from unexpected events or from excessive exposures to something erroneously perceived as safe, never ever because of excessive exposures to something ex ante perceived as risky.

PS. Elizabeth Warren, in as much as she classifies herself as a progressive, could also be interested in how these regulations decree inequality.

@PerKurowski ©

October 14, 2016

Was there not some secretarial mix-up with this year’s Nobel prices to Dylan and Santos?

Sir I refer to Ludovic Hunter-Tilney’s “Dylan is a deserving Nobel laureate” October 14.

Absolutely (I belong to those of the 60s who are currently living out their 60s). Yet I must ask: could there have been some mix-up with this years Nobel prices?

I mean could not the Peace one have been intended for the “...how many times must the cannon balls fly” Bob Dylan, while the Literature one was for Colombia’s Juan Manuel Santos, for his 297 pages long fiction book on peace?

@PerKurowski ©

Who is able to measure how much risk weighted capital requirements for banks distort the real economy?

Sir, Gillian Tett quotes Axel Weber, former head of the Bundesbank, now chairman of UBS with “I don’t think a single trader can tell you what the appropriate price of an asset he buys is, if you take out all this central bank intervention” “Investors are ill equipped for our unfathomable future” October 14.

And much less can anyone know what the appropriate price of an asset he buys is, if you take out all the distortions the risk weighting of the capital requirements for banks produce. Just look at houses. How could anyone believe their prices would be the same as now, if bankers were required to hold as much capital when financing houses than when financing SMEs and entrepreneurs?

Sovereigns being risk weighted at 0%, while We the People at 100%, is one of the strongest statist statements ever, and it has been allowed to go unnoticed for way too long.

With central bankers’ QEs there is at least some transparency… but I guess Sir that, with respect to negative interests, no one knows either how to really measure their impact… it does really seem to be a huge leap of faith into the unknown.

@PerKurowski ©

Sir, just between us, could it be that not so deep down Martin Wolf is just another statist activist?

Sir, Martin Wolf writes: “The financial crisis, and the stagnant living standards it bequeathed, has clearly undermined the legitimacy of the free-market approach.” “Activist May calls an end to Thatcherism” October 14.

Wolf knows very well, among other because I have explained it to him in literarily hundreds of letters, that current bank regulations, with their risk weighted capital requirements tilted in favor of the sovereign (0% risk weight) and other “safes” like the AAArisktocracy (20%), and against “We the People” (100%); is something completely anathema to a free-market approach. In fact it sounds much like pure statism to me.

Just look at how the financing of houses has been favored when compared to for instance the financing of SMEs and entrepreneurs that could create the new jobs our youth will need. Has that anything to do with free-markets? No wonder more and more grandchildren will have to live, with their parents, in their grandparents’ basements.

Wolf says not a word about getting rid of the regulatory distortions of the allocation of bank credit to the real economy, and has instead been proposing the government to take the advantage of low interest rates to build more infrastructure. He gives not a thought on the possibility that those low rates for the sovereign, are in much paid by citizens that will have to give up their dreams because they will lack the opportunity to access bank credit.

And this does not even touch on how central banks, with their QEs monetary policy interventions, almost completely favor the credits to sovereigns.

Sir, just between us, could it be that Martin Wolf is also just another statist activist?

The west did not lose the world; it unwittingly gave up the world, in a process that began in London, 2 September 1986

Sir, Philip Stephens puts forward the argument that “The global financial crash of 2007-08 cruelly exposed the weaknesses of liberal capitalism” is one of the causes for “How the west has lost the world” October 14.

Nonsense! Liberal capitalism, and much of the willingness of the west to dare to hang on to its position in the world, was abandoned the day bank regulators decided that the risk weight for sovereigns was 0% while that of We the People 100%; and the day they foolishly decided to base the capital requirements for banks, on ex ante perceived risks, as if these risk were not already cleared for by banks.

“On September 2, 1986, the fine cutlery was laid once again at the Bank of England governor’s official residence at New Change… The occasion was an impromptu visit from Paul Volcker… When the Fed chairman sat down with Governor Robin Leigh-Pemberton and three senior BoE officials, the topic he raised was bank capital… the momentum it galvanized… produced an unanticipated breakthrough of a fully articulated, common bank capital adequacy regime for the United States and United Kingdom. This in turn catalyzed one of the 1980’s most remarkable achievements – the first worldwide protocol on the definitions, framework, and minimum standards for the capital adequacy of international active banks… They literally wiped the blackboard clean, then explored designing a new risk-weighted capital adequacy for both countries…”

The Basel Committee’s risk weighting introduced a regulatory risk aversion that, had it been in place before, would never ever have allowed the west to become the leading west. To top it up, it distorted the allocation of bank credit to the real economy, for nothing, since what never ever causes major bank crises, is what is perceived as risky. These always result from unexpected events or excessive exposures to something that was erroneously perceived ex ante as very safe, or if really safe, made risky by receiving too much credit. The global financial crash of 2007-08 was a direct result of these capital requirements.

Sir, our grandchildren are going to look back with a lot of sadness to that day and ask themselves, how could our grandfathers have done this to us? Didn’t they know they themselves did well only because their parents had dared to take the risks the future needs? Why did they only settle for having their banks refinance the safer past and present?

And Sir, if you are still around, they are going to ask you: why did not papers like the Financial Times speak about this for many decades?

@PerKurowski ©

October 13, 2016

We would appreciate Google’s DeepMind (or IBM’s Watson) giving the Basel Committee some tips on intelligent thinking

Sir, I refer to Clive Cookson’s “DeepMind overcomes memory block to bring thinking computers a step closer”, October 13.

Here again we read about so much research going on in the world of artificial intelligence. Though clearly still a lot needs to be done, the current advances could perhaps suffice in order to give some good tips to some humans who do not seem to be able to get their thinking quite right.

Yes! You’ve guessed it Sir. I am indeed referring to the Basel Committee of Banking Supervision and their risk weighted capital requirements for banks. Perhaps it would be easier for the regulators to hear out some observations on how to regulate banks, if it came from an impressive “differentiable neural computer” with AI capability, and not from a simple non-expert human like me.

So, if Google’s DeepMind (or IBM’s Watson) were able to only convey the importance of first defining clearly the purpose of banks before regulating these; and second to do some empirical research on why bank systems fail, that could be extremely helpful for the banks, for the real economy, and of course for the future of our grandchildren.

Then regulators, swallowing their pride, could perhaps, with luck, understand both that the main social purpose of banks is to allocate credit efficiently to the real economy; and that no major bank crises have ever resulted from excessive exposures to what was ex ante perceived as very risky, as these have always resulted from unexpected events, or from excessive exposure to what was ex ante considered very safe, but that ex post turned out to be very risky.

That could help to free us all from our banks being guided by dumb risk-weighted capital requirements… more ex ante perceived risk more capital – less risk less capital.

Not only do these cause our banks to misallocate credit to the real economy, like no credit to “risky” SMEs or entrepreneurs; but also to make our bank system more unstable by pushing the build-up of exposures to what is perceived, decreed or concocted as “very safe”, without requiring sufficient capital to cover for the unexpected events.

PS. DeepMind, or you Watson, if you would also care to explain this to those in the Financial Times, that would be doubly appreciated. I have tried to do so with literarily thousands of letters, but still no luck… I guess I am not as impressive as you are.

@PerKurowski ©

October 12, 2016

Lord Turner, peer to peer lending P2P, stands no chance of satisfying the needs banks were instructed not to fulfill

Sir, Ruth Gillbe reports in FT’s Adviser that Lord Adair Turner now opines "peer-to-peer lenders … might be able to do credit underwriting as well as established banks”. “Lord Turner u-turns on P2P mis-selling” October 12.

No, let us hope they can do it much better, and for that a prerequisite is for the scheming and hubris filled bank regulation technocrats, to stay out of their way.

Let us be clear, the P2P lending is taking off, somewhat, much because regulators, such like former chairman of the Financial Services Authority Lord Turner, with their risk weighted capital requirements, gave banks incentives to go only to where it was perceived, decreed or concocted as “safe”, and stay away from what was perceived as “risky”

Sir let us hope (pray) these regulators wake up and stop distorting the allocation of bank credit; since just with P2Ps it will not be enough to get our economies going again.

Chances of that are slim though. Can you imagine a Lord Adair Turner bowing humbly and asking for forgiveness, like a failed Japanese executive could do? 

@PerKurowski ©

Could BoE’s bank regulation risk weights for the infallible UK sovereign also have to go negative; from 0% to -20%?

Sir, Martin Wolf writes that “The government will learn about the limits of sovereignty in an open economy” “The markets teach May a harsh lesson” October 12.

What a surprise? I thought that someone like Wolf, who seems to agree with the concept expressed by the Basel Committee of a 0% risk weight for the sovereign, and a 100% risk weight for We the People, would not doubt the powers of the infallible sovereign this way.

Jest aside, an “Open Market” does not currently exist. In such market regulators would not be able to distort the allocation of bank credit as they do.

A very nervous Wolf writes: If “the inflows of capital needed to finance the UK's huge external deficit… ceased… Then the currency might collapse. Yields on gilts might also jump”

Calm! Take it easy Mr Wolf. The neo-independent BoE could then declare that the risk weight for the infallible sovereign of UK should also turn negative, and so be lowered from 0% to minus 20%. See… problem fixed!

To discuss economy, in a world in which bank credit is being so distorted, and so few care about it, makes me sometimes feel as I have fallen down Alice’s Rabbit-Hole. I hope, for my grandchildren’s sake, I wake up to find its all been a nightmare.

@PerKurowski ©

Free Greece from regulatory shackles that make banks finance more the safer past & present than the riskier tomorrow

Sir, when commenting on the tensions between a “eurogroup” of ministers and the IMF about how to solve the problem called Greece you, as you should, clearly argue in favor of some additional relief of that debt “overhang that can only depress confidence”, “The IMF should stay in the Greek rescue squad”. October 12.

The problem though is that even if all Greece’s debt was condoned, but bank regulations stayed the same, that nation would just repeat its and most other countries’ recent mistakes.

Sir, nothing expresses a more depressed confidence in tomorrow as Basel’s risk-weighted capital requirements for banks. If Greece, and all the rest, is not freed from it, its banks have no chance of allocating credit so as to achieve a sturdy and sustainable growth. And besides if such growth does not happen, the banks’ own stability is also endangered.

That Europe, IMF, and the rest of regulators, do still seem to be unaware of what nasty effects their current bank regulations produce, is just amazing. Or perhaps they are all aware of it, but, with a little help from their friends, like FT, are just circling their wagons in order to defend their little mutual admiration club of technocrats.

There should be claw-back clauses for failed regulators and blind journalists (and editors) too!

@PerKurowski ©

October 11, 2016

FT, where’s the real hurdle? In PDVSA’s debt swap, or in PDVSA and Venezuela’s government?

Sir, Eric Platt and Jessica Dye write: “Analysts and bankers remain optimistic that a deal will be clinched, as a default would cut both Venezuela’s and PDVSA’s credit lines with lenders and deepen the country’s recession.” “PDVSA debt swap plan hits hurdle” October 11.

Really? Could it not be so that helping to finance one of the demonstratively most inept governments ever could only deepen and prolong a recession that, right after a huge oil boom, in a country that states it holds the largest oil reserves in the world, has its citizens starving and without access to medicines?

Venezuela is in utter disorder, and its people in utter despair, and still its government sells gas at less than US$ 4 cents a gallon, thereby allowing some to smuggle it out and make juicy profits. That, no matter how you look at it, is a de facto economic crime against humanity.

So “T Rowe Price owned $274m worth of the 2017 bonds”. Does T Rowe Price really think that its clients, though they might make huge speculative profits in the short term, are truly benefitted long term by financing an entity as mismanaged as T Rowe Price knows PDVSA is? Would T Rowe Price’s investors have liked it if Venezuelans had financed a PDUSA and thereby helped keep a hypothetical authoritarian regime in power? When is what is being financed going to be an issue? Or is it really that you can finance anything at all, as longs as the risk premiums are juicy?

Sir, to be clear, I am not writing this solely in “opposition” to the current Venezuela government. For decades, long before the Chavez years, I have been opposed to odious debts, odious credits and odious borrowings… anywhere.

PS. I am supposing no one would dare to expose such naiveté as arguing that lending to PDVSA is distinct from lending to the Venezuela government.

@PerKurowski ©

There is already an unknown and hidden, odiously regressive, hugely distorting, levy on financial transactions

Sir, Gregory Meyer reports on levies on financial transactions that have been proposed in the US by Democratic politicians “US markets braced for trading tax grab” October 11.

One can easily understand the political appeal of such taxes, but also that all these could have unexpected consequences, many quite contrarian to the initial objectives.

That said, let me remind you of the financial sector’s “risk-weighted capital requirements for banks” tax; essentially based on assigning to the Sovereign a 0% risk weight and to We the People one of 100%.

That tax allows governments to collect revenues through the not so transparent channel of having more and cheaper access to bank credit. Unfortunately most of that tax is not paid by the rich and wealthy, but by the not wealthy SMEs and entrepreneurs, by means of lesser and more expensive access to bank credit.

Not only is it an immensely regressive tax, the AAArisktocracy is risk-weighted at only 20%, but, as an “unexpected that should have been expected consequence”, it also ends up causing stagnation that diminishes government ordinary tax revenues.

Even worse, that tax stimulates banks into creating excessive exposures to what has always been more dangerous to the stability of the sector, namely what has ex ante been perceived as very safe, but that ex post could turn out to be very risky.

Sir, compared to this tax, all other financial transactions taxes proposed, seems almost irrelevant.

@PerKurowski ©

October 10, 2016

Let a Universal Basic Income empower and help make something reasonable, or even really good, out of the gig economy

Sir, Sarah O’Connor writes that “A fierce debate has broken out this year about the dangers and opportunities of a world where more workers are cobbling together an income through independent “gigs” rather than relying on traditional employee jobs.” “At least fifth of European and US workers in ‘gig economy’” October 10.

Come what may, I am sure that both the debate, and the reality of the “gig economy”, would be quite different depending on whether a Universal Basic Income exists or not.

Again when I mention UBI it is always with special emphasis on the “Basic”

Again when I mention UBI it is always paid with real money, no funny inflationary money.

Again when I mention UBI, I know that the redistribution profiteers are going to be very pissed off.

@PerKurowski ©

No “regulatory arbitrage” distorts more than regulators’ dumb and arbitrary risk weighted capital requirements for banks

Sir, Lawrence Summers writes: “The focus of international economic co-operation more generally needs to shift from opportunities for capital to better outcomes for labour. [That] will require substantially enhanced cooperation with respect to what might be thought of the as the dark side of capital mobility — money laundering, regulatory arbitrage, and tax avoidance and evasion.” “Voters sour on traditional economic policy” October 10.

No! The darkest side of capital mobility is how the Basel Committee’s risk weighted capital requirements for banks is distorting the allocation of bank credit to the real economy. Compared to that the damages caused by “money laundering, regulatory arbitrage, and tax avoidance and evasion” are peanuts.

And Summers also holds that “Recessions come intermittently and unpredictably. Containing them generally requires 5 percentage points of rate cutting”

That might apply to normal recessions, but when these have resulted from insane bank regulations, no rate cutting will help in a sustainable way, unless you get rid of the distortions.

It is also amazing to see how experts can lose contact with their inner common sense and, for instance, come to believe that the very risky below BB- rated assets are more dangerous to the banking systems than the AAA rated ones.

By the way there is nothing "traditional" about such regulatory stupidity... it just tracks back to 1988, Basel I.

PS. Here again is an aide memoire that explains some of the regulatory monstrosities.

@PerKurowski ©

It is way overdue FT stops thinking of Brexit solely as a disastrous defeat, and starts exploring its opportunities

Sir, I refer to Wolfgang Münchau’s “The shock that will shift a nation’s business model” October 10.

Indeed it is long way overdue that at least some of you in FT stop the crying and begin thinking about Brexit not as an unqualified defeat/disaster, but as an opportunity.

But let me be clear. When Münchau mentions the need for “a shift in the direction of the UK economy away from transactional capitalism towards a more inclusive version of a free-market economy”, that begins precisely by throwing out the Basel Committee’s risk weighted capital requirements for banks.

That single piece of regulation, which turned banks away from maximizing returns on equity by means of banking, into doing so by means of capital (equity) minimization; and all based on avoiding ex ante perceived, decreed or concocted risks, has been about as damaging to the real economy as anything I can think of.

But Sir, to recognize that after ignoring the literally thousands of letter I have sent you on that subject, would of course require FT to eat loads of humble pie. Are you without fear and without favour enough to do that?

@PerKurowski ©

Do we also need the possibility of clawbacks or prison to concentrate the minds of bank regulators?

Sir, Harvey Clark Greisman, when discussing Gillian Tett’s “Clawbacks emerge as a vital weapon in finance”, September 30, argues: “The only penalty that will concentrate bankers’ minds is prison”, October 10.

And what about regulators? If ever submitted to public shaming, could that suffice? 

How do we keep them from doing such insane things as regulating banks before clearly defining the purpose of the banks? 

How do we keep them from imposing capital requirements in order to make banks safe without one single empirical study on what has caused major bank crises in the past?

How do we keep them foremost concerned with doing no harm?

How do we keep them from committing the list of horrendous mistakes contained in the following aide memoire?

@PerKurowski ©

Ask European SMEs and entrepreneurs if they believe Europe is overbanked?

Sir, I refer to Claire Jones’ and Martin Arnold’s “Bankers signal alarm over Eurozone lenders” October 10.

If were an SME or an entrepreneur, not being able to access the opportunity of the bank credit I need for me to have a chance to fulfill my dreams, I would be furious and desperate if hearing Sergio Ermotti, chief executive of UBS say “Europe is in a huge overcapacity situation, with a combination of private sector and public sector banks and quasi-public sector banks that have been allowed to compete”. 

Gary Cohn, president and chief operating officer of Goldman Sachs is also quoted with, in comparison to Europe and elsewhere with that the US banking sector was “in the best shape ever”. Nonsense, the real strength of any banking sector is a 100% function of the strength of the real economy they depend upon; and few would hold that the US and world economy “in the best shape ever”. That type of affirmation can only come from someone who believes the real economy should be serving the banks, and not caring one iota for need of the banks serving the real economy.

And Nigel Vooght, global head of financial services at PwC, the consultancy is quoted with”: “Banks need to wake up and start to react, because they are an integral part of society, but they don’t have a divine right to be here . . . All the banks are trying to switch from an interest rate-based model to a fee-based model.”

I totally disagree. Banks have, thanks to regulators, not been pursuing “an interest rate-based model” but an interest rate-based capital minimization model. If they are to be an integral part of society, switching from interest rates to fees will just not cut it. Banks need to realize that their fundamental role is to allocate credit efficiently as possible to the real economy, and that’s just not possible using different capital requirements based on ex ante perceived credit risks. 

@PerKurowski ©

October 09, 2016

Let robots make us an offer we can’t refuse, for us to allow them to supplant us; perhaps a Universal Basic Income?

Sir, Simon Kuper writes about “How to cope when robots take your job” October 9.

In an Op-Ed I wrote in Venezuela 2012 (before I got censored there too) titled “We need worthy and decent unemployments” I wrote: “What politician does not speak up for the need to create decent and well paid jobs for young people? But, if that's not possible, and the economy is not able to deliver that on its own ... What on earth do we do?” 

And I followed that up with “The power of a nation, and the productivity of its economy, which so far has depended primarily on the quality of its employees may, in the future, also depend on the quality of its unemployed, as a minimum in the sense of these not interrupting those working.”

And so perhaps not only journalists but all other who end up unemployed because of robots too, should require those employing robots to pay a out a Universal Basic Income, as a quid-pro-quo for us allowing these to supplant us. Or if they have better ideas, let the robots themselves make us an offer we can’t refuse.

Ideally that could allow many to operate on the fringe margins of earnings, allowing them to keep busy with what they most like to do.

For journalists the alternative could be to get really creative so as to obtain some ad income from a story that goes viral. Sadly, in that case, the temptations of sacrificing truth in order to gain virality might prove to hard to resist… as we already see happening more and more, here and there and everywhere.

@PerKurowski ©

I would not shed tears for the Basel Committee for Banking Supervision’s demise. Neither would millions of SMEs.

Sir, Caroline Binham and Jim Brunsden, with help of Laura Noonan, report that the Basel Committee for Banking Supervision is introducing reforms that include a contentious “output floor” that would limit banks’ ability to use their own internal models to assess risk. “In many cases this will effectively raise the amount of capital that banks have to hold” “Basel group warns of call for lenders to ramp up capital” October 8.

What do they mean with “in many cases”? How can anyone believe all banks authorized to use internal models do not use these to minimize the capital they need to hold …so that they can maximize their returns on equity?

Sadly, what is really contentious with all this, is how on earth we ended up with such infantile regulators.

Anyhow the authors report these reforms are creating some discord between the US and Europe; to such an extent it “tests the viability and purpose of the Basel group, founded 41 years ago to harmonise banking rules around the world.”

Sir, if that would signify the end of the Basel Committee, you know I will not shed a tear. Neither would the millions of SMEs and entrepreneurs who over the years have been denied fair access to bank credit, if they finally came to realize that was a direct consequence of Basel’s regulatory discrimination. 

Knowledgeable bank regulators know below BB- rated assets are risky. Wise ones know what’s AAA rated is dangerous. The world is overdosing on information and knowledge and it sorely needs more wisdom.

PS: Here is an aide memoire on the regulatory monstrosity of the risk weighted capital requirements for banks.

@PerKurowski ©

October 08, 2016

Current central bankers are just as lost as Greenspan and friends were lost before 2008, for exactly the same reason

Sir, Sebastian Mallaby when discussing the “alarming froth” in asset prices like shares, bonds and houses, due to “extraordinarily loose monetary policy”, but yet producing “low growth and low inflation” writes: “A … troubling echo concerns the role of regulation. If financiers seem to be taking too much risk, today’s doctrine holds that regulation should restrain them.” “Bubbly finance and low inflation cause alarm” October 8.

NO! NO! NO! Today’s regulations hold that banks should be taking on too much safety. Banks are not allowed to build up dangerous exposures to what is perceived as “risky”, like for example the below BB- rated, which has been assigned a risk weight of 150%; but banks are sure allowed to leverage immensely their capital, and the support they receive from society, with assets rated AAA to AA, risk weighted a mere 20%.

And, if the banks are big and “sophisticated” enough, then they are even allowed to use their own risk models even if, by definition, banks are always interested in minimizing their capital requirements so as to allow them to maximize their expected returns on equity.

There must be something in the air that stops expert central bankers from reaching out to their inner common sense and be able to understand how loony current bank regulations are.

The risk-weighting completely distort the allocation of bank credit to the real economy, making banks ignore their vital role in financing the “riskier” future, and having them to concentrate solely in refinancing the “safer” past. That dooms the world to gloom and doom or as they prefer to call it, to secular stagnation.

And all for nothing! Major bank crises never ever result from excessive exposures to what is ex ante perceived as risky; these always result from unexpected events or from excessive exposures to what was ex ante erroneously thought to be very safe.

@PerKurowski ©