Monday, July 26, 2010

The Gameboy regulators of Basel

Looking at how they try to control for risk by appointing credit rating agencies as risk-surveyors and then concocting some risk-weights to determine the capital requirements, it should be clear that we have fallen into the hands of a first generation of Nintendo-Gameboy-players’ type of regulators who believe life, risk and who knows perhaps even love can be controlled by just pushing some buttons.

When is the world going to speak out and say that it has had enough of this infantile approach to bank regulation? If we don´t speak out we´re doomed.

Wednesday, July 21, 2010

Dodd-Frank Act… legislative surrealism!

The Dodd-Frank Act signed today seems to me a surrealistic piece of legislation. 

Though the United States in June 2004 formally committed to implementing the Basel II bank regulations; and though the SEC in April 2004 delegated supervision decisions to the Basel Committee, surrealistically, there is not one single mention of these regulations, or of the Basel Committee for Banking Supervision, in all 848 pages of the Dodd-Frank Act. And this though the Act makes reference to foreign organizations like the Extractive Industry Transparency Review (EITI). It would seem like someone somewhere, has been playing some dirty tricks on someone.

PS. (Dated later) And it does not mention the fact that risk-weighted capital requirements for banks, in the home of the brave, does seem to be quite un-American. What do you mean regulators about discriminating against "the risky", those who are already being discriminated by the banks because they are perceived as risky?

The fact that the distortions in the allocation of bank credit caused by the risk-weighted capital requirements had not been understood, much less accepted, made it impossible for the Dodd-Frank Act to really serve its purpose... in many ways... by opening discussions on so many other fronts and thereby distracting the attention from what most urgently matters, only made it worse.

PS. Homeland Security. Bad regulations could be used as a lethal weapon of terrorism

PS. The complaint I presented to the Consumer Financial Protection Bureau

Thursday, July 1, 2010

The Basel Committee makes small businesses and entrepreneurs pay much more for their bank credit

When compared to a regulatory system with equal bank capital requirements for all type of assets, the Basel system that imposes different requirements based on some arbitrary risk-weights related to credit ratings, implies that a small business needs to pay about 2 percent (200 basis points) more in interest rates in order to stay competitive when accessing bank credit.

Suppose a bank feels that the normal risk premium should be .5 percent for an AAA rated company and 4 percent for a small business. If the bank was required to have 8 percent for both assets and could therefore leverage itself 12.5 to 1, then the expected before credit loss margin on bank equity for the AAAs would be 6.25% and for the small business 50%, a difference of 43.75%.

But, since the bank is allowed by Basel to hold only 1.6 percent against AAA rated assets, which implies permitting a leverage of 62.5 to 1, the previous margin 6.25% margin for AAA assets becomes a whopping 31.25%, which now implies a difference in the margins on equity of only 18.75% when compared to that generated by the small businesses.

In order to restore the initial required competitive margin difference of 43.75, now only 18.75% the small businesses will have to generate for the banks an additional gross margin of 25 percent, which, divided by the 12.5 to 1 leverage allowed for their class of assets, comes out to be the additional 2 percent in interest rate referred to.

Of course a complete analysis would require considering many other dynamic factors, but those would only help to fog the basic truth that our regulators are discriminating against those the banks are most supposed to serve.

What will it take for the regulator to understand that this is no minor problem, especially when so much of any job recovery lies in the hands of small businesses and entrepreneurs?

What will it take for the regulator to understand and admit that the regulatory discrimination in favor of the AAAs caused the current financial crisis?