January 18, 2018

Why do FT reporters refuse to implicate regulators and their risk weighted capital requirements for banks in the 2007-08 crisis?

Sir, Patrick Jenkins writes: “As a correspondent in Frankfurt in the early 2000s, I saw first-hand how a sector that had grown fat on government-supported AAA credit ratings, turned hubristic. The situation was at its worst — and most dangerous — after the EU pressured Berlin to end the government guarantee regime in 2005. That ruling prompted the banks to raise three years’ worth of money in the bond markets within a matter of months. It gave them vast investment resources to deploy just at the time when Wall Street and the City of London were aggressively pushing complex collateralised debt obligations underpinned by sub-prime mortgages and other nominally safe, but ultimately toxic, products to anyone that would buy them”, “The role of dumb money in Carillion’s crash”, January 18.

Amazing! Jenkins does not mention the fact that in June 2004, with Basel II, the Basel Committee approved a risk weight of only 20% for all private sector debt rated AAA to AA. That, with a basic capital requirement of 8%, meant banks needed to hold only 1.6% in capital against what was so rated; which meant the banks could leverage a mind-blowing 62.5 times with such assets.

It was pure regulatory lunacy! And the same loony regulators are still at it. How FT’s journalists and experts can keep so mum on the role of dumb and irresponsible regulations escapes me.

Jenkins refers to “complex collateralised debt obligations underpinned by sub-prime mortgages and other nominally safe” What a BS. These were AAA rated securities, that was what the market and bankers saw.

In January 2003 the Financial Times published a letter I wrote and that ended with: “Everyone knows that, sooner or later, the ratings issued by the credit agencies are just a new breed of systemic error to be propagated at modern speeds. Friends, please consider that the world is tough enough as it is.”

PS. FT, Jenkins, do yourself a favor. Go to all banks that had any involvement with Carillion and carefully research how much capital they held against exposures to it, before the blow-up. And ask to have a look at their equity requirements’ minimizing sophisticated risk-models, or at any “superficial credit analysis” … and don’t just naively believe anything they tell you.


January 17, 2018

The risk weighted capital requirements for banks close way too many development doors.

Sir, Martin Wolf referring to the World Bank’s latest Global Economic Prospects writes: “A slowdown in the potential rate of growth is affecting many developing countries. This is not only the result of demographic change, but also of a weakening in productivity growth. They need to tackle this urgently.” “Recovery is a chance for the emerging world” January 17.

Sir, during my two years as an Executive Director of the World Bank, and with respect to the Basel Committees’ bank regulations, I continuously argued for the need to maintain “an adequate equilibrium between risk-avoidance and the risk-taking needed to sustain growth.”

At the High level Dialogue on Financing for developing I presented a document titled “Are Basel bank regulations good for development?” which I answered with a clear NO!

In 2009 Martin Wolf, in his Economic Forum allowed me to publish “Free us from the imprudent risk aversion and give us some prudent risk-taking”.

And in hundreds sites more, among other with over 2600 letters to FT, I have argued about the horrible mistakes of the risk weighted capital requirements for banks present, not just for developing countries but also for developed ones.

The distortion these produce in the allocation of bank credit in favor or what is perceived or decreed as safe, sovereigns, AAA rated and mortgages, has impeded millions of “risky” entrepreneurs around the world to gain access to bank credit, thereby hindering much new productivity.

And those regulations will not bring us stability, much the contrary.

So the first thing to do to allow what Wolf wants, “greater entrepreneurial effort, more competition, higher investment and faster improvements in productivity”, is the elimination of risk weighted capital requirements for banks.” But Martin Wolf will most probably not agree, because how could he?

Sir, and as I have told you umpteenth times those regulations will not bring us stability, much the contrary.

PS. Look for instance at houses. What would the price of a house be if there was no financing available to purchase these? Of the current price of houses how much is represented by the intrinsic value of the house, and how much is a reflection of all one-way-or-another subsidized financing allocated to that sector? The sad truth is that our society has ended up financing the financing of houses. When all that low risk weighted mortgaging comes home to roost in a subprime unproductive economy, it will be hellish.


January 13, 2018

Parent regulators, not even aware they were the ones blowing the bubbles, shamelessly put all the blame on their toddler banks when these burst.

Sir, Tim Harford writes: “As any toddler can attest, it is not an easy thing to catch a bubble before it bursts” “Forever blowing bubblemania” January 13.

That is entirely true. But though we should not expect our toddlers to know it, parents are fully aware that the bubbles their dearest are chasing, were blown up by them, in the clear expectation that these would burst, or delightfully disappear in the skies.

Harford concludes in that “It’s very easy to scoff at past bubbles; it is not so easy to know how to react when one may — or may not — be surrounded by one”

Not entirely true, because that should not excuse the case of parents not even being aware they’re blowing bubbles.

In the western world, regulators, for instance, by allowing banks to leverage their equity so much when financing residential houses, are, no doubt about it, blowing up a house credit bubble that will surely blow up in our face… even though we cannot exactly know when that will happen.

When with Basel II in 2004 regulators allowed banks to leverage a mindboggling 62.5 times their capital, only because an AAA to AA rating was present, it should have been clear to them that they were blowing a bubble. Seemingly they did not. Worse, when then the AAA rated securities backed with subprime mortgages exploded in their face, they should have been able to put two and two together, but no, they put all the blame on the banks, the toddlers in this case. Even to the extent of describing the excessive bank exposures to AAA rated assets, or to sovereigns like Greece who with a 0% risk weight they had decreed infallible, as an irresponsible excessive risk-taking by bankers. They should be ashamed!

PS. Like Harford’s senior colleague I was also very skeptical about Amazon’s valuation. In April 1999 I wrote in an Op-Ed that Amazon had “joined the rank and files of ‘tulipomanias’” Yes, I admit, it is now worth much more than it ever was at that time. That said, and though Amazon is now way more than about books, I still suspect that, long term, because of: “‘shopping agents’ will permit clients to quickly compare one company’s prices to those of its competition, which would seem to presage an eventual fierce price wars, would create an environment that is not exactly the breeding ground for profits that back the market valuations we are now observing”.

But then I also assumed institutional “efforts aimed at prohibiting any monopolistic controls of the Web”, and in this perhaps I could have been way to naïve.


January 12, 2018

How would I privatize a public service? Always making sure that who owns and manages it, are neighbors I can hold accountable.

Sir, I refer to Martin Wolf’s discussion on the subject of privatized or not public services. “Nationalisation is the wrong answer to a real question” December 12.

I was a very active participant, wearing many different hats, in many of the privatizations that took place in my Venezuela, during its privatization influenza.

Like Wolf I much favour the private over the public sector managing these services but, looking back, the number one requirement I would make when privatizing, would be to require the private owners of any such privatized public services, to live within the community, and have their affiliation to the public service transparently identified all the time. Like being able to call over the fence: “Hey Bill, what happened last night when the lights went out”, “Hey Bill, can’t you find a way to stop it from being so expensive?”

I felt in the air the immediate difference between a private electrical services company held by a family living in Caracas, who wanted to make profits but also to be seen as good public servants, and that same company when it passed into the hands of absentee owners.

It was day and night! The new investors loaded up the old conservative run company with debt, took most of their skin out of the game paying themselves huge dividends and other services, and left the poor users having to serve that debt.

Of course, then came Hugo Chávez and put it all in the hands of the government, and so it went from a bit bad to plain horrible.


January 10, 2018

The financial-elite’s reluctance to ask bank regulators for clear explanations, seriously threatens the west’s liberal democracy and global order

Sir, Martin Wolf asks and answers: “What has created sharp (and usually unexpected) slowdowns? The answers have been financial crises, inflation shocks and wars” “The world economy hums as politics sour” January 10.

Indeed, but currently our economies are also suffering a slow but steady state slowdown as a consequence of the insane risk weighted capital requirements for banks, which were created in the name of making banks more stable. It all boils down to the following:

If a “safe” AAA rated offered a correct risk adjusted net interest margin to a bank, a loan to it could, according to the Basel Committee’s Basel II of 2002, be leveraged 62.5 times but, if that correct risk adjusted net interest margin was offered by a “risky” unrated entrepreneur or an SME, then a loan to these could only be leveraged 12.5 times.

As a direct result bank credit has been used to finance “safer” present consumption; to inflate values of mostly existing assets; and way too little to finance “riskier” future production.

In summary it amounts to having placed a reverse mortgage on our past and present economy, in order to extract all of its value now, not caring one iota about tomorrow, and much less about that holy social intergenerational contract Edmund Burke spoke about.

But Wolf could argue that this is evidently not true because: “Yet the world economy is humming, at least by the standards of the past decade. According to consensus forecasts, optimism about prospects for this year’s growth has improved substantially for the US, eurozone, Japan and Russia”

Sir, it’s all a debt financed economic growth. Like a family having a great Christmas by racking up debt on their credit cards. How much of the enormous recent growth of debt everywhere has gone to finance future builders like entrepreneurs and SMEs? The answer is surely a totally insignificant fraction.

Wolf here anew identifies threats: “The election of Donald Trump, a bellicose nationalist with limited commitment to the norms of liberal democracy, threatens to shatter the coherence of the west. Authoritarianism is resurgent and confidence in democratic institutions in decline almost everywhere.”

Sir, sincerely, what is all that compared to the fact that the world’s financial elites, either because it is not in their interests, or because lacking self confidence they are afraid they might have overlooked something, do not have the gut to firmly ask regulators: “Why do you want banks to hold more capital against what has been made innocous by being perceived risky, than against what is dangerous because it is perceived safe?”, and not accepting any flimsy nonsensical answer veiled in sophisticated voodoo technicalities.

Martin Wolf has moderated numerous important conferences on financial regulations, but not one has he dared to ask that simple question. Could it just be because he is scared he would then not be invited again as a moderator? Or is it that he just doesn’t get it.

And Sir, you have really not been living up to your motto either. Shame on you!

PS. And all that risk adverse regulations for nothing, since, as I have told Wolf and FT time after time, major bank crisis, like that of 2007/08, never ever result from excessive exposures to what is ex ante perceived as risky.


January 09, 2018

If AI was allowed to have a crack at the weights used by current risk weighted capital requirements for banks, the regulators would surely have a lot of explaining to do.

Sir, John Thornhill writes that he saw an artificial intelligence program crack in 12 minutes and 50 seconds the mindbendingly complex Enigma code used by the Germans during the second world war” “Competent computers still cannot comprehend” January 9.

I wish AI would also be asked to suggest some weights for the risk weighted capital requirements for banks.

For instance in Basel II the standardized risk weight assigned to something rated AAA, and therefore perceived as very safe, something to which banks could build up dangerous exposures, is 20%; while the risk weight for something rated below BB-, and therefore perceived to be very risky, and therefore banker won’t touch it with a ten feet pole, is 150%.

I would love to see for instance Mario Draghi’s, Mark Carney’s, and Stefan Ingves’ faces, if artificial intelligence, smilingly, came up with weights indicating a quite inverse relation between perceived risks and real dangers to a banking system.


January 08, 2018

The worst problem with the dangerously growing debt is what it has not financed

Sir, Pascal Blanque and Amin Rajan write: “for central banks, global debt is like the sword of Damocles — an ever-present danger. It stands at about 330 per cent of annual economic output, up from 225 per cent in 2008… No one knows all the cracks into which excess liquidity has seeped — or what risks are being stored up”, “Beware the butterfly: global economies are on borrowed time” January 7.

Sir, if central bankers are only now waking up to this fact, then you must agree with that we are in much bigger problems that we thought.

Central bankers, lacking in character and not wanting to live up to their own responsibilities, dared not do anything but to push the 2007/08 crisis cart down the road, with their QEs and low interest rates. For someone who argued back in 2006 the benefits of a hard landing, that is bad enough.

But it’s so much worse than that. Blanque and Rajan argue that “Debt means consumption brought forward while low rates mean the survival of zombie borrowers and companies… High debt is not intrinsically bad so long as it is used to fund investments that deliver profits or create financial assets worth more than the debt. Data on this score are hard to come by.”

And there lies the fundamental problem. Because of risk weighted capital requirements for banks, bank credit has been used to finance “safer” present consumption; to inflate values of mostly existing assets; and way too little to finance “riskier” future production. It amounts to having placed a reverse mortgage on our past and present economy, in order to extract all of its value now, not caring one iota about tomorrow, and much less about that holy social intergenerational contract Edmund Burke spoke about.

It is clear the experts Blanque and Rajan have yet not understood what happened as they write: “The origins of the current worries predate the 2008 crisis which was caused when lending standards went from responsible to reckless: the siphoning of money into dodgy ventures such as subprime mortgages, covenant-light loans or sovereign lending based on creative accounting.”

The truth is that without truly reckless regulatory standards, those which allowed banks to leverage over 62.5 time to 1 with securities rated by human fallible rating agencies AAA; and, at least in Europe, allowing banks to lend to a 0% risk weighted sovereign like Greece against no capital at all, nothing of the above would have happened.

What to do? In my mind, in order to extricate the world of this problem, we need first to rid us completely of the credit distorting risk weighted capital requirements; and second, to be able to manage the transition to for instance a 10% capital requirements against all assets, including sovereigns, without freezing the whole credit machinery, perhaps bank creditors would have to accept, in partial payment of their credits, negotiable non redeemable common fully voting shares issued by the banks. If that helps to bring back undistorted bank vitality, it might be the best shares to have ever.

PS. Blanque and Rajan reference “S&P 500 corporates… stashing cash reserves outside the US.” What cash? Treasurers have not stacked away cash under corporate mattresses. Those surpluses are all already invested in assets, of all sorts, and which could suffer losses just like any other assets.


January 06, 2018

What if workplace distractions were considered part of consumption instead of part production?

Sir, Tim Harford, who has blocked me on Twitter writes: “Bank of England’s unofficial blog…compared plunging productivity with the soaring shipments of smartphones. Typical productivity growth in advanced economies had hovered steadily around 1 per cent a year for several decades, but has on average been negative since 2007. That was the year the iPhone started to ship.” “Computers are making generalists of us all”, December 6.

That iPhone and many of its close or distant cousins, cause a lot of distractions. If that time distracted was classified not as time of production but as time of consumption, and outputs remain fairly the same, would that not point at much higher productivity and much higher real salaries?

PS. Harford writes here also a lot about Power Point presentations. Here my long ago take on it


January 05, 2018

It’s not the role of regulators and central banks to help governments fund their operations, behind the back of citizens

Sir, Kate Allen writes that “euro-area financial institutions” have reduced their holdings of public debt “17 per cent in the past two years [but] the ECB made nearly €1.5tn of cumulative net purchases of eurozone public sector bonds through its quantitative easing programme — effectively replacing the purchasing role that banks had played. “Post-crisis reforms force European governments to curtail size of debt sales” January 5.

It all forms part of the same statist subsidizing of public debt. 

What would sovereign rates be if banks had to hold the same capital against sovereign debt than against loans to citizens; and if ECB had not purchased “eurozone public sector bonds through its quantitative easing programme”? The answer would have to be rates much higher, which would send quite different risk-free-rate signals.

In 1988, with Basel Accord, statist regulators, with their 0% risk weighted bank capital requirements, began subsidizing immensely government borrowings. When the 2007/08 crisis came along, central banks, perhaps in order to hide own their regulatory failures, with their quantitative easing purchases generated, wittingly or not, new sovereign debt subsidies.

This has dramatically changed the economical relations between governments and private sectors. It amounts to statist hanky-panky behind the backs of citizens. Since besides needing servicing it consumes, for nothing really special, sovereign indebtedness space that could be urgently needed tomorrow, it might become deemed as high treason by future generations. Where this is going to end is anyone’s guess, but it sure won’t be pretty.


January 04, 2018

Philip Augar, the ‘banking crisis of 2008’ did not dent at all Milton Friedman’s ideas that “sowed the seed of shareholder value”

Sir, Philip Augar quotes Milton Friedman with: “that business is not concerned ‘merely’ with profit but also with promoting desirable ‘social’ ends . . . They are — or would be if they or anyone else took them seriously — preaching pure and unadulterated socialism….” “to make as much money as possible” for the owners, “while conforming to the basic rules of society”, “A call for boards to overturn the status quo” January 4.

And he follows up with “This sowed the seed of shareholder value... It took the banking crisis of 2008 and the ripple effect of financial disaster to expose the flaws of the theory”

What is Augar talking about? Banks, in order to make the highest risk adjusted profits, just followed the “basic rules of society”, in this case set by their regulators who, with their risk weighted capital requirements for banks told them: “Go out and make your biggest risk adjusted profits on what is perceived or decreed as safe”

And that is precisely what banks did, initially making huge profits, but also creating dangerously excessive exposures to “the safe” like AAA rated securities and loans to sovereigns who had been assigned a 0% risk weight, like Greece; which exploded.

I cannot understand how Augar can argue that has dented Milton Friedman’s thesis. If anything it clearly demonstrates the dangers of having some very few define and impose “the basic rules of society”.

He opines “boards need to develop a mindset that challenges rather than seeks to justify the status quo” That is correct, but does that not include papers like the Financial Times too?

Sir, why has FT not dared to challenge the status quo by for instance demanding regulators to give a straight simple answer, not disguised in incomprehensible technicalities, to the question of “Why do you want banks to hold more capital against what has been made innocous by being perceived risky, than against what is dangerous because it is perceived safe”?


If you really want banks to make green investments, allow bank to hold less capital against these than for instance against residential mortgages.

Sir, Suleika Reiners, Senior Policy Officer for Financial Reform, Institute for Financial Services, Germany writes: “banks need more equity, not less, in order to fulfil their key responsibility — namely to cushion risk, including for green investment. Lending for long-term endeavours such as large-scale renewable energy projects particularly deserves high-risk weightings” “Banks need more equity to boost green investment”, January 4.

Boy, has she got it all upside down. I have nothing against higher capital requirements for banks, unless these are imposed so irresponsibly so that the while bank credit machinery freezes. But, in order for banks to really boost green investment, they should be allowed to hold less capital against these investments than against other assets, so that they can earn a higher risk adjusted return on it.

Just look at how much they are financing residential housing, only because that’s perceived safe by regulator safe, and who therefore allow banks to hold little capital against the mortgages.

Reitners refers to “a study by the University of Cambridge in association with the United Nations Environment Programme Finance Initiative [that] has proved that stricter equity requirements are an insignificant factor in influencing the bank’s pricing of the loan or its willingness to lend.”

I have not read that study but, if those are the results, I am sure it contains major design flaws.

Sir, you refusal to discuss the distortions produced by risk weighted capital requirements, perhaps so as not to disfavour your bank friends, is partly to blame for the continuation of misconceptions as those expressed here by Suleika Reiners.

I don’t like the idea of distorting the allocation of bank credit to the real economy but, if we have to do it, let that at least be in pursuit of higher objectives than a simple risk avoidance, which will anyhow not isolate us from bank crises.


January 03, 2018

In terms of causing the undoing of the west’s liberal democracy and global order, Trump (until now) is nothing compared to the Basel Committee

Sir, Martin Wolf holds that: “political developments have fractured the west as an ideologically coherent entity” “Global disorder and the fate of the west”, January 3.

I argue that much more than recent political developments the west, as we knew it, at least as I thought of it, was fractured in 1988 when regulators, with the Basel Accord, came up with risk weighted capital requirements for banks.

The following were Basel II’s capital requirements for banks on exposures to sovereigns according to their credit ratings: AAA to AA = 0%; A+ to A = 1.6%; BBB+ to BBB- = 4%; BB+ to B- = 8%; Below B- = 12%; Unrated = 8%.

What have that regulation to do with “A liberal democracy [where] the participants recognise the legitimacy of other participants common…[and] rests on a neutral rule of law”?

That someone like Walter Wriston could argue, "Countries don't go bankrupt," does not mean that some sovereigns have the right to declare themselves infallible. That was never part of any (recent) global order… nor was that those citizens who perceived as safe were already so more favored than those perceived as risky when accessing bank credit, would gain additional advantages by generating lower capital requirements for banks.

The development of the west like all development does required a lot of risk-taking. The day regulators layered on their purposeless risk aversion on top of already risk adverse banks… they doomed the west to a standstill, a “relative decline”, which, with time, will turn into a fall unless we can stop that dangerous nonsense. God make us daring!

Sir, what Trump, until now at least, might be doing to cause the undoing of the west’s global order is chicken shit when compared to what the Basel Committee has done. Martin Wolf does not think so because he considers it the duty of bankers to do what is right and ignore the incentives they are given to provide a high risk-adjusted return on equity to their shareholders.

And talking about populism, is not “We have risk weighted the banks’ capital for you so that you can now sleep calm” pure outrageous technocratic populism?


January 02, 2018

The windows for poverty reduction will shrink dramatically, as robots and automation help bring back to developed countries the jobs lost to poorer ones.

Sir, Ben Bland writes: “Automation in Bangladesh may not make sense because you still have to ship but, if you make in the US, it makes more sense because there’s no [import] duty, no shipping, you’re closer to the customer and there are shorter lead times,” said Mr Rajan. “March of the robots stalls as clothes maker Crystal backs human workers” January 2.

What can I say? Should those robots working in the US share a moment of silence for those poor Bangladesh workers they will be substituting for?


$1m in capital for one New York City taxi medallion; only $16.000 for a bank to make a $1m loan to an AAA rated. Crazy!

Alistair Gray informs: “the value of the collateral, the medallions, has collapsed. New York City medallions were worth about $1m four years ago but some are now for sale for as little as $250,000” “Uber’s rise fuels financial crisis for taxi lenders” January 2.

$1m for “New York City licences, known as medallions, issued by the authorities to collect passengers”.

Sir, $1m for a New York City medallion, if that’s not a prime example of crony statism what is? Can there be any question of why Uber was needed? If you have to service a capital investment of this size, how high must the tariffs be and how much of these can be reasonably left to compensate the taxi drivers?

Compare this taxi driving capital requirement to that of banks according to Basel II. As payment for the benefit of regulators telling the world banks were regulated, and issuing various explicit or implicit deposit guarantees, banks needed to hold: 

1.6%, $16.000 in capital when lending $1.000.000 to an AAA rated client.

2.8%, $28.000 in capital when holding $1.000.000 in residential mortgages.

Max 8%, $80.000 in capital, for financing New York City medallions

PS. http://perkurowski.blogspot.com/2016/04/here-are-17-reasons-for-why-i-believe.html


When bank regulators allowed banks to earn higher returns on equity by avoiding the “risky”, they violated a fundamental social contract

Sir, you write “Unemployment rates are low in the UK and US, but many of the new jobs are more precarious than the old ones they replaced… [so] the US and EU need to do more to encourage investment, and to deter anti-competitive behaviour and, as important, encourage competitive pressure on complacent incumbents.” “A better deal between business and society” January 2.

If one allowed banks to leverage more, and thereby obtain higher risk adjusted returns on equity when lending to what is perceived safe, than when lending to what is perceived risky, it would require ignorance, or total lack of concern, to believe banks will finance as much as usual small unrated companies and new entreprenuers.

But that is what regulators with their risk weighted capital requirements did and so it should be no surprise that “Despite low financing costs, private investment — the vital seed for long-term growth — remains insipid.” I am not talking about an “out-of-date regulatory models” that could be reformed, but about a fundamentally mistaken regulatory model.

You want “A better social contract… built on the idea of a humane, mutually beneficial interdependence between” employers and employees. Sir, who could argue against that? There’s always room for that.

But, how many times have I begged you to put the weight of the Financial Times behind asking the regulators: “Why do you want banks to hold more capital against what has been made innocous by being perceived risky, than against what is dangerous because it is perceived safe?”

But for some internal reasons of your own, perhaps even a petty one, you have refused to do so. In my book, just like when regulators regulated banks without caring about the purpose of these violated a social contract, you also violate your social responsibility as journalists by not intermediating opinions between your readers and those officially responsible for the decisions being questioned.


December 30, 2017

Sadly, banks must now to take on board rules that were not adjusted to what caused the crisis

Sir, Martin Arnold, your Banking Editor writes: “In the coming year, much of the alphabet soup of post-crisis financial regulation will be completed — including Basel III, IFRS 9 and Mifid II — giving the industry the most clarity for almost a decade on the rule book it must follow.” “Lenders take on board rules of a post-crisis world” December 30.

We are soon three decades after regulators in 1988 with Basel I, concocted risk weighted capital requirements for banks, and 13 years after they put these on steroids with Basel II’s risk weights of 0% for sovereigns, 20% for AAA rated, and 35% for residential mortgages. That caused irresistible temptations for banks to create excessive exposures to these “safe” assets, which resulted in the 2007/08 crisis. And yet there is almost no discussion about that monstrous regulatory mistake.

So the risk weighting is still part of the regulations; and therefore the 0% risk weighted bank exposures to sovereings keeps growing and growing; as well as is the disortion of bank credit in favor of the “safer” present and against the “riskier” future. 

In this respect if I were to title something of this sort at this moment it would be more in line of “Lenders take on board rules that have not been adjusted to the crisis and therefore guarantee a world with even larger bank crises”

The irresponsibility and lack of transparency evidenced by the members of the Basel Committee is amazing. The lack willingness of media, like the Financial Times, to pose some simple questions to these regulators, is just as incomprehensible. 

When the next bank crisis, or the next excessive exposure to something perceived as very safe blows up in our face, how will your bank editor then explain his silence on this?

PS. I could not find the link to Martin Arnold's piece.


To apply the Socratic method successfully requires students to be somewhat interested in the questions.

Sir, with respect to Lucy Kellaway’s "End of Term Diary” (December 23), David Parker writes: “It’s the teacher’s job to facilitate and motivate. Show students the beauty of things. And, teach by the Socratic method. Ask a question. If the student doesn’t understand, ask another question. Keeping asking. When they understand, they’ve learned” “Teach by the Socratic method — keep asking” December 30.

I have tried to apply the Socratic method during years trying to make Financial Times understand the mistakes of risk weighted capital requirements for banks. Among the questions:

Why do regulators require banks to hold more capital against what has been made innocous by being perceived as risky, than against what has become dangerous by being perceived as very safe?

Why did regulators not define the purpose of banks before regulating these?

Why did bankers use as input for their risk weighted capital requirements for banks the intrinsic risks of bank assets and not the risk of those assets for the banks?

Why do regulators not understand that allowing banks to leverage differently with different assets will distort the allocation of bank credit? And, if they understood that, who gave them the right to distort? Etc. 

But FT shows no interest in these questions… so I have to find another method… any idea Lucy Kellaway?


Current risk weighted capital requirements for banks are a stand out example of “garbage in garbage out”

Sir, when discussing artificial intelligence and “how much power should be ceded to the machines” you mention: First. “the need to overcome limitations in machine learning techniques”; Second. “garbage in, garbage out…the need for better quality control”; and Third. “the need to develop a clear and transparent governance structure for AI”, “The paradox in ceding powers of decision to AI” December 30.

Sir, human intelligence is quite often in need of all that too.

When bank regulators used intrinsic risks of bank assets as inputs for developing their risk weighted capital requirement, they could not produce anything but garbage out. What they should have used is unexpected events or the risk those assets could pose to our bank system, namely the risk that bankers would not be able to adequately manage perceived risks.

And little evidences the need for a transparent governance structure for human intelligence too, as current regulators refusal to answer the very basic questions: “Why do you require banks to hold more capital against assets made innocous by being perceived as risky than against assets becoming dangerous by being perceived as safe?”.

Humans must also also overcome some technical limitations: An Explanatory Note by the Basel Committee on the Basel II IRB (internal ratings-based) Risk Weight Functions” expresses: “The model [is] portfolio invariant and so the capital required for any given loan does only depend on the risk of that loan and must not depend on the portfolio it is added to.”

And the explicit reason for that mindboggling simplification is: “This characteristic has been deemed vital in order to make the new IRB framework applicable to a wider range of countries and institutions. Taking into account the actual portfolio composition when determining capital for each loan - as is done in more advanced credit portfolio models - would have been a too complex task for most banks and supervisors alike.”

Sir, finally, I would add a fourth requirement, namely to make sure artificial intelligence is kept free from that excessive hubris and besserwisserism that too often affect humans. Like that which kept regulators from even having to define the purpose or banks before regulating these,


December 29, 2017

Favoring government borrowings with quantitative easing and statist capital requirements for banks, dooms the sovereign to default.

Sir, Michael Hasenstab writes about how as a result of the US Federal Reserve’s “$3.6tn Federal reserve money-printing exercise [that] has financed approximately 20 per cent of the government’s net borrowing per year since 2008…and cutting interest rates to record lows” has distorted “the price of money, along with key metrics for valuing both financial and real investments” “Fed risks a sizeable hangover as it begins ‘the great unwind’” December 29.

Correct, but to really understand the magnitude of the distortions, we also must include those produced by the risk weighted capital requirements for banks... like the 0% risk weighting of sovereigns.

Allowing banks to hold different levels of capital against different assets means the risk-adjusted returns on bank equity are not solely cleared by markets but also by regulations. If one now decides that was a truly bad idea that dangerously distorts the allocation of credit to the real economy…how do you work yourself out of this hole?

For a starter, let us suppose you shoot for banks having to maintain 10% in capital against all assets, including sovereign then: how much additional capital need banks to have, or how much sovereign assets need banks to shed from their balance sheets? Either figure is bound to be mindboggling.

To be able to do so without freezing up the whole bank credit machinery, would perhaps require settling an important part of all bank credits, with some unredeemable negotiable bank shares.

Upsetting? No doubt, but the real costs of keeping going down that pro sovereign distorted route is domed to be filled with sovereign defaults.

Hasenstab begins with “In response to the global financial crisis, the US Federal Reserve took extreme but necessary measures to protect the American economy from collapse.” That is the conventional truth, I am not sure it is the whole truth and nothing but the truth. Sir, in August 2006 you published a letter I wrote titled “Long-term benefits of a hard landing” It would have hurt, not doubt, but I sincerely believe we would all have been breathing easier now had not the Fed protected the American and the world economy so much… and of course regulators having corrected what brought us that crisis to begin with… namely the so credit allocation distorting risk weighted capital requirements for banks.


Financial liberalism died when the Basel Committee establishment concocted the risk weighted capital requirements for banks

Sir, Joe Zammit-Lucia writes: “True liberals have always understood the need for continual reform as stagnating systems inevitably get progressively captured by powerful interests. Liberalism dies when it becomes the Establishment, itself captured by vested interests and an apologia for the status quo” “True liberals understand the need for reform” December 29.

What better example of that than when the regulatory establishment, gathered in the mutual admiration club of the Basel Committee decided to protect with lower capital requirements for banks the lending to the safer status quo than any lending to a riskier future.

Bankers loved it, because that allowed them to fulfill their wet dreams of being able to achieve the highest risk adjusted returns on equity on what is perceived as safe; and lower capital requirements naturally opened up much more space for their own bonuses.

Regulators, dumb enough to take ex ante perceived risks to represent real ex post dangers love it, because they think they are making banks safer.

And the world stagnates because of that risk aversion, and turns statist as regulators risk-weighted sovereigns with a 0%, thereby subsidizing public borrowings.


What if we in writing had to authorize phone companies to listen to our calls, in order to have access to phones?

Brooke Masters writes: “when I link our Amazon Echo speaker to my son’s Spotify account, I have no idea whether I am violating one of the thousands of terms and conditions he agreed to with his account. Furthermore, does that act give Amazon the right to send him advertisements based on the songs we play?” “Take ownership of the sharing economy” December 29.

She is absolutely right. The rights we seem to have to give up in order to gain access to social media and alike, though defined in small letters in thousands of unreadable pages, is one of the most undefined issues of our time.

Some questions:

Should the marginal cost for social media owners to access, and waste, so much of our limited attention span, be zero?

Should we be able to copyright our own preferences so that we at least can have something to negotiate with?

How much can we allow being distracted during working hours before our employer has the right to deduct our salaries paid?

How will such working hours distractions be accounted for in employment statistics?

How is all this free or very cheap consumption paid by used attention spans be accounted for, for instance in GNP figures?

Should social media owners be allowed to impose their own rules or should that not be subject to some kind of a special arbitration panel?

How our global differences be managed? Does a government that interferes with its citizens’ rights of access to social media have access to other web sites of other nations?


December 27, 2017

Bank regulators, imposing irresponsible insane rules, are prime destroyers of the rational liberal rules-based world order

Sir, Martin Sandbu writes of “opponents of the liberal, rules-based world order built up over 70 years” and that “The anti-liberal front’s undisputed leader, is the US under President Trump”, “The battles of ideology for our age”, December 27.

Sir, forget it, whatever President Trump might have done until now with respect to breaking down a rules-based world order, is nothing when compared to the damage bank regulators have done when trying to impose their own petit committee concocted regulatory rules on the world.

What they did, namely to allow banks to leverage more with assets perceived as safe than with assets perceived as risky; something which allows banks to earn higher risk adjusted returns on equity on assets perceived as safe, is something absolutely irresponsibly insane.

First, because that distorts the allocation of bank credit with serious consequences for the real economy, like favoring “safe” financing of houses over “risky” financing of “risky” entrepreneurs; which results in many basements for the young to live with their parents but few jobs for them to afford their own upstairs.

Second, by decreeing the risk-weight of the sovereign to be 0%, while that of the citizens on which that sovereign depends were weighted 100%, they effectively, 1988, one year before the fall of the Berlin wall, introduced through the backdoor, a mechanism to provide the financing to sustain (for some time) runaway statism.

Third, because since major bank crisis never ever result from excessive exposures to what was ex ante perceived as risky, it all serves absolutely no stability purpose at all.

Sir, if the “liberal internationalist camp working to defend a multilateral system of collaborative rules-based governance for economic openness to mutual advantage” is to go anywhere, that must begin by forcing bank regulators to satisfactorily respond the very straightforward question of: Why do you require banks to hold more capital against what has been made innocous by being perceived as risky than against what’s made dangerous by being perceived as safe?

Sandbu correctly argues: “In a global battle of ideas, liberals must show urgently that the existing order can be made to work for everyone”. But, injecting quantitative easing liquidity and low interest assistance, while such distorting regulations are in place, guarantees these will not be made to work for everyone, but only for those already in possession of safe assets, like the parents’ houses.


December 26, 2017

The distraction factor forces us to redefine entirely our concepts of working hours and real salaries

Sir, I refer to Sarah O’Connor discussion of “bureaucratic limits on working hours” “Symbolic victories over Brussels will not help Britain’s workers”, December 27.

But, when we read in Bank of England’s BankUnderground blog that “we check our phones 150 times per day, or roughly once every 6½ mins; and that the average smartphone user spends around 2½ hours each day on his or her phone; and that we are distracted nearly 50% of the time,” then of course we have reasons to suspect that all our usual thinking about working hours, or even about real salaries, have entered into a completely new dimension and are up for major revisions.

Sir, never ever did we chat around the coffee machine that much in our days… or did you?

December 24, 2017

Many children incapable of helping their parents during their old days will one day rightly blame our bank regulators’ insane risk aversion for that

Sir, Bronwen Maddox writes about the possible need to “force more people to use the equity in their houses to pay for care” and that “In these discussions, how to tax inheritance has attracted more political attention, not least because the prescriptions are simpler and chime with the debate about inequality”, “An ageing population and the end of inheritance” December 23.

Are the prescriptions for taxing inheritance really simpler than using your assets to pay for some of your own services? I don’t think so. To pay for your own social care services with assets of your own, fits perfectly with the standard norms and realities of our economy and our society. But, eroding the right to bequeath wealth to your children constitutes a direct attack on one of the most important drivers of the economy that could have dangerous consequences for all.

One of the least studied, or clearer yet conveniently ignored topics, is what could happen if you redistribute wealth, be it by wealth or inheritance taxes; not only in terms of what I consider is its very limited potential to provide temporal relief to poverty or inequality, but also in terms of how it could negatively affect the future economy. The lack of such discussions on this has possibly to do with not fitting the agenda of those creating envy and hate in order to achieve their own particular small and temporary goals.

Let me briefly hint at the following:

If a $450 million Leonardo Da Vinci “Salvator Mundi” had to be sold at the death of his owner to pay for all inheritance taxes it will not fetch $450 million. This because who would feel stimulated to pay a sort of voluntary tax, freezing that amount of purchase power on a wall or in a storage room, if that painting cannot be bequeathed to heirs, and just be taken away upon death?

And what would happen to all private owned houses and apartments, if upon the death of their owners who made sacrifices paying for these, they would just fall into a government pool of houses, with their users to be nominated by some few house redistributionists? What would happen to the incentives to save in order to buy, maintain and make homes beautiful?

And, if all shares and bonds were taxed to be placed in a mutual government pot… would that not signify heaven for statism fanatics and redistribution profiteers, and hell for all the rest of our children and grandchildren?

Sir, of course “the dream of bequeathing assets to the next generation is fading in the face of social care costs” that results from having more elder and fewer younger. But the lesser earnings of the young also cause that fading. Those regulators who with their insane capital requirements had banks abandoning financing the “risky” future, in favor of refinancing the “safer” past and present, will not be kindly remembered by the too many children incapable to take care of their parents’ old days.

PS. What is a reverse mortgage but a way to squeeze the most out of the present for the present? Whether it is done to satisfy an urgent need or only in order to anticipate some unnecessary consumption is not something irrelevant.


December 23, 2017

Imposing on banks risk aversion more suitable to older than younger, regulators violated Edmund Burke’s holy intergenerational social contract

Vanessa Houlder when writing about Richard Thaler’s ‘nudge’ theory and how our hatred of losses affects risk taking mentions: “Investing in a portfolio tilted towards equities makes sense for the young, although — given that share prices can drop dramatically — the proportion should be reduced as people near retirement, according to Thaler.” “Be lazy, the first rule of investing” December 23.

Sir, that refers precisely to something on which I have written to you hundred of letters over the years.

Regulators, with their risk-weighted capital requirements, by allowing banks to hold less capital against what is perceived as “safe”, like mortgages, than against what is perceived as “risky”, like loans to entrepreneurs, they allow banks to earn higher risk adjusted returns on what’s perceived safe than on what’s perceived risky.

With it regulators top up the natural risk aversion of bankers with their own one, and by there doom banks to primarily work in the interest of the older and against those of the young. That, phrased in Edmund Burke’s terms, is a shameful breach of the holy intergenerational social contract that should guide our lives. How our society has managed to turn a blind eye on this makes me, a grandfather, very disappointed and sad.

But all that risk aversion is also so totally useless. Major bank crisis never ever result from excessive exposures to what has ex ante been perceived as risky; but always because of unexpected events or excessive exposures to what was perceived, decreed or concocted as safe but then turned out to be risky, like AAA rated securities backed by mortgages awarded to the subprime sector and loans to sovereigns like Greece.

PS. It would be great if Vanessa Houlder could ask Richard Thaler why he thinks regulators want banks to hold more capital against what perceived as risky is made innocous than against what is perceived as safe is therefore intrinsically more dangerous? My own explanation is that they mistook the ex ante perceived risk of bank assets for being the ex post risks for banks.


December 22, 2017

Ex ante expected real rates of return and ex post real rates of return are apples and oranges

Gillian Tett referring to “The Rate of Return on Everything, 1870-2015” authored by Oscar Jorda, Katharina Knoll, Dmitry Kuvshinov, Moritz Schularick and Alan Taylor writes: “real rates are very low today compared with the peacetime years in the 20th century. But real returns on bonds and bills were much lower during the first and second world wars, tumbling to about minus 4 per cent (compared with 3 per cent for bonds in 2015, and zero for bills).” "Take the very long view on asset prices", December 22.

Sir, we cannot know the ex post real rates of return for bonds yet, and it must be very hard to gauge the ex ante expected real rates of return during the first and second world. Therefore it is not clear to me whether Ms. Tett refers in both cases to ex ante expected real rates or to ex post finally obtained real rates? If not she is comparing apples to oranges. Frankly, no matter how high patriotic willingness to contribute with war efforts could stimulate lending to it, I truly doubt investors accepted ex ante a minus 4 per cent real rate offer… so they must have expected a much lower inflation rate.

Sir, there is a lot of confusing ex post with ex ante going on. For instance, the Basel Committee regulators, when setting their risk weighted capital requirements for banks, used the ex ante perceived risk of bank assets as proxies for the ex post risks to banks… a horrible mistake that distorted the allocation of bank credit and that has not been corrected during soon 30 years.

PS. And now having read the paper I must also observe that risk free rates, and rates of returns on what is considered by regulators a safe assets, like houses, must be separated into those before the risk weighted capital requirement for banks and those thereafter, since the regulatory subsidy to the “safe” again makes apples and oranges of these.


December 20, 2017

Major bank crisis, are they most likely to result from excessive exposures to what’s perceived risky than for what’s perceived safe?

Izabella Kaminska ends her fun “Festive inefficiencies would be missed in Big Tech’s perfect world” of December 20 with “Since inefficiency has a way of popping up no matter what we do, it is human experience that should be prioritised before all else.”

Sir, let me phrase some questions:

How long could it take for a bank system to suffer a major crisis because of excessive exposures to what is perceived risky?

How long could it take for a bank system to suffer a major crisis because of excessive exposures to what is perceived safe?

Do our bank regulators care at all about human experiences when they require banks to hold more capital against what is perceived as risky than for what is perceived as safe?

Sir, do you really care about what human experiences teaches us?


Here are some actions we should take in order to reduce the threat inequality poses to our democracies.

Sir, the discussions about growing inequality, that tend too often to concentrate on either income or wealth inequality expressed solely as a linear function of monetary terms, are dangerously simplified. Once some basic and non-basic wants have been met, loading up some extra millions does not produce the same amount of marginal benefits per dollar.

But of course for those who do not have the income to satisfy their needs and basic wants inequality matters, a lot. And so more important than worrying about inequality, is to worry about how increase the incomes of those earning less. 

Sometimes the lower incomes for some can have to do with some few other earning unjustifiably or even incorrectly too much, but most often it has little to do with that.

But the redistribution profiteers want to hear nothing of that sort. They prefer to feed envy, with for instance their so frequent mentions of how few wealthy posses more wealth than a billion or so of the poor. That of course can only increase the threat inequality signifies to our democracies that Martin Wolf lays out well in his “Inequality is a threat to our democracies” December 20.

Going from “a stable plutocracy, which manages to keep the mass of the people divided and docile” to the “emergence of a dictator, who rides to power on the back of a faux opposition to just such elites” is what sadly happened in my Venezuela.

What can we do?

When Wolf writes “The market value of the work of relatively unskilled people in high-income countries seems very unlikely to rise” we could for instance see what role risk weighted capital requirements for banks play:

In terms of equality what’s the difference between someone owning a home and someone renting a similar one?

Not much, that is unless the value of the house owned increased a lot and, as a consequence, rents also increase, sometimes more than what the renter can compensate with increased salaries.

That’s what happens when banks are allowed to hold residential mortgages against much less capital than when for instance lending to entrepreneurs; and as a consequence earn higher risk adjusted returns on equity with mortgages than when financing entrepreneurs; which mean banks will make the financing of house purchase abnormally available; which means house prices will go up… until

That is also what happens when central banks inject liquidity that benefits mainly the owner of assets; “now your house is worth more so take out a new loan against it” is not an offer that one renting will hear. 

When Wolf refers to “a desire to enjoy some degree of social harmony and the material abundance of modern economies, [being a] reasons to believe the wealthy might be prepared to share their abundance.” We should be careful of promising more than what could be obtained, because much of that abundance is not easily converted into effective purchase power or transferable income to others; for instance when some wealthy, by means of what could classify as a voluntary tax, decides to freeze on a wall, or in a storage room $450m of his purchase power, in a Leonardo Da Vinci “Salvator Mundi” how do you efficiently reverse that? Of course what’s important here is not the buyer’s paid $450 million but to where the $450million received are going.

Sir, I believe the following actions would go a long way to “ensure the survival of liberal democracy”

2. A monthly Universal Basic Income (UBI) that is sufficient to help you get out of bed but not so large as to permit you to stay in bed. 

3. A Revenue Neutral Carbon Tax that helps fund the UBI and aligns the incentives for saving the environment and reducing inequality. 

5. Have Facebook, Google and alike pay a minimum fee into the UBI fund for any advertising that they send to us on the web. That would also help us to make sure they do not waste so much of our very scarce attention span.


December 19, 2017

Our best hope for a decent and affordable adult social care must be minimizing the intermediaries’ takes, whether these are private or public

Sir, Diane Coyle when discussing the possibilities and need for organizing for instance adult social care, and thereto taking advantage of new methods to connect demand and supply and as exemplified by Uber, expresses concern for “the treatment and status of workers in platform public services (although it is not as if these are high-status jobs at present)” “Algorithms can deliver public services, too” December 19.

What’s missing though in that good analysis, is not having contemplating additional tech advances. For example Uber wants to buy self driven cars, in order to get the complications of human drives out of their way, but without realizing that consumers might at one point take direct contact with those cars, in order to get Uber out of the way.

The same will happen for workers in public services, though of course the increased demand for adult social care should help to keep up the demand for many of them. But, even in this case who knows? If you think of yourself as an older person soiled with your own feces, what’s currently is delicate referred to as an “accident”, who would you feel most comfortable with cleaning you, a not too human 1st class robot or a human? 

Sir, the way our generation, and governments have gone on a debt binge, to anticipate current consumption, there will come a time for a reckoning. If we do not find ways to minimize the intermediaries’ take, we will not afford the basic services we need and want.

Of course intermediaries are workers too… and that is why even for them we need to create decent and worthy unemployments.


December 18, 2017

When banks can leverage more their equity financing “safe” built houses than financing “risky” job creation, too many young are doomed to live unemployed in our basements

Sir, Bill Mendenhall in a letter of December 18, “Lord Turner got there first on productive credit” mentions a report by Jim Pickard “Labour looks at making mortgage lending harder for banks” December 12. Pickard’s report was not in FT’s US edition.

Pickard wrote: “Shadow chancellor John McDonnell is considering making mortgage lending more onerous for banks in an effort to push them to lend more to smaller companies…The proposals were set out in “Financing Investment”, a report commissioned by the Labour leadership and written by GFC Economics.

According to GFC, British banks are “diverting resources” away from vital industries and instead focusing on unproductive lending, such as consumer credit borrowing.

The paper argues that the Prudential Regulation Authority, the BoE’s City regulator, should use existing powers to make banks hold relatively more capital against their mortgage lending. The report’s authors say this would be an “incentive to boost SME lending growth”.

The GFC report also claims that the BoE’s Financial Policy Committee “makes no distinction between unproductive and productive lending” to companies, arguing that the banking sector “should be geared towards stimulating productive investment”.

The report calls for the FPC to use existing powers to vary the risk weights on banks’ exposures to residential property, commercial property and other segments of the economy.

The report acknowledges that such interventions would be seen by critics as risky measures that could “impede the smooth functioning of markets” and distort the efficient allocation of capital. But it warns that “financial stability risks will emerge if an economy loses its competitiveness”.

Sir, you must be aware that this includes much of what I have written to you in thousands of letters, for more than a decades, and that you have decided to ignore.

But, if that report acknowledges that “to vary the risk weights on banks’ exposures to residential property, commercial property and other segments of the economy… would be seen by critics as risky measures that could ‘impede the smooth functioning of markets’’, why does it not then question the distortion the current existing differences in risk weights cause?

Pickard also mentions that the report warn that “financial stability risks will emerge if an economy loses its competitiveness”. No doubt! Banks cannot be the sole triumphant survivors in an economy that is losing strength.

And when now Mendenhall writes that “Lord Turner got there first on productive credit” because in his 2015 book Between Debt and the Devil he pointed out that “the banking sector’s decades-long switch away from lending to businesses towards mortgage lending only serves to inflate asset prices, which leads to property bubbles”, that does not mean that Lord Turner really understood or understands what has happened.

In June 2010, during a conference at the Brooking Institute in Washington DC, I asked Lord Turner “Do you really think the banks will perform better their societal capital allocation role if regulators allow them to have much lower capital requirements when lending to the consolidated sectors than when lending to the developing?

To that Lord Turner (partially) responded: "we try to develop risk weights which are truly related to the underlying risks. And the fact is that on the whole lending to small and medium enterprises does show up as having both a higher expected loss but also a greater variance of loss. And, of course, capital is there to absorb unexpected loss or either variance of loss rather than the expected loss.”

Pure BS! With that Lord Turner evidences he ignores that banks already clear for the higher risks when lending, so that when also clearing for it in the capital, the whole credit allocation process gets distorted… and banks end up lending more to build “safe” downstairs for our children to live in with their parents, and lending less to “risky” entrepreneurs who could get them the jobs to afford buying their own “upstairs” 

No, Lord Turner is just one of those too many regulators that want banks to hold the most capital against what is perceived as risky, while in fact it is when something perceived as safe turns out to be risky, that we would most like that to be the case.