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Banks and Basel III - blackmail or chainmail?

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by Robert McDowell


Will the various new so-called “Basel III” rules make the world safer from financial crises? There should not be a short answer to such a complex question – but my answer is yes, and no, not much either way, and, looking back, taking the metaphor of New Orleans sea defences and levees, higher equity in banks core capital reserves means the same as adding only inches to the height of ‘sea defences’. Protecting the financial system is a systemic challenge; individual breaches in flood defenses may be contained or lead to general failure.

Erecting barriers, by setting global prudential standards, to prevent calamity is the job of the Basel Committee on Banking Supervision (BCBS), to mitigate, prevent or postpone, another Credit Crunch, its job is to agree techniques, laws, rules and guidelines to resist a 1/25 tidal surge or the 1/100 that some say defined the Credit Crunch.

But, what do we think of bankers’ response to new safety rules? They sound like road drivers opposing lower speed limits.

The banks publicly resent being told to increase reserve ratios. It is the same reaction if government asked the private sector to build and pay for sea defenses. The banks’ lobbyists such as the BBA and IIF warn gloomily of a probable £1 trillion less lending in the UK alone over the next decade - maybe €7 trillion less lending across the EU.

Our inglorious banks have, it seems, regained a bold-faced confidence sufficiently to complain loudly about new prudential rules, as if these ingrates* have superior information to warn us not to kill the Golden Goose**, and as if everyone else will trust that judgement and believe the banks?

But, is it realistic to suppose that excessive fear of another financial crisis and mistrust of banks by regulators and taxpayers could lead to borrowers and the economy paying a big penalty for higher equity-capital reserve ratios?

Alongside the new capital rules, the Basel Committee also published two papers on economic impact that media commentators and banks’ lobbyists, appear not to have read? These assessments are more sanguine and define it as a (very) “conservative” view to assume all the impact of Basel III will be borne by higher customer borrowing costs and reduced lending.

The Committee agreed higher equity capital ratios (announced 12th September) to oblige banks to hold more to absorb the inevitable losses of a recession. The changes are intended to mitigate and or postpone the next “financial crisis”. More equity means shareholders will bear the losses, as they have done so already in the Credit Crunch?

Reserves are ratios to loans and investments net of collateral after risk adjustments. New rules require twice as much equity reserve as before, but with years to get there, by when the USA and UK will probably be in recession again? Higher “capital buffers” are also imposed, but only in the proportions that national supervisory regulators are already demanding.

Bankers’ bleat that capital hikes mean higher customer costs, less lending, and will only jeopardize recovery. But, by the time the ratios kick in we’ll be past recovery and into the next boom. Bankers, it seems, don’t want us to see the many ways they can generate more “own capital”, including via higher profit-retention and paying smaller bonuses!

The BIS paper on macro-impacts finds that for each 1% increase in the capital ratio loan costs could maximally rise by 13bp, and for every 1% higher liquidity reserves loan margins rise 25bp, assuming RWA is unchanged. This falls to 14bp or less if RWA falls by shifting the risk diversity to less risky assets without any fall in gross assets. If banks adjust their expected return on equity from 15% to 10%, then each 1% increase in capital ratio is recovered by a 7bp rise in loan margin, well within what can also be achieved by cost-cutting or other relatively painless measures.

BIS is very clear: “Banks have various options to adjust to changes in required capital and liquidity requirements other than increasing loan rates, including by reducing ROE, reducing operating expenses and increasing non-interest sources of income. Each of them could cut the costs of meeting the requirements. For example, on average across countries, a 4% reduction in operating expenses, or a 2 % fall in ROE, is sufficient to absorb a 1% increase in the capital/RWA ratio. In practice, banks are likely to follow a combination of strategies.”

Cost of borrowing by banks should reflect the riskiness of banks. If banks are safer because of new rules then the risk spread banks pay to borrow should fall. But, if bankers don’t rediscover prudence, alongside a humbler piece of the pie, as governments anxious to balance their budgets exit from bank-aid measures, then the banks will have to pay more to borrow funding gap finance and to attract and retain deposits.

Let’s not forget that the Credit Crunch was caused by funding gap finance cost (risk spreads) becoming uneconomic, too high to ensure positive corporate lending margins. Why, because banks lost credibility and it is not at all clear that they can presume to have that back now, not while ratings agencies keep so many banks on the bottom-most rungs of unsecured credit grades.

The rates borrowers are charged should be dictated more in future by competition and demand than by banks seeking again the super profits of the years before 2008, and in Europe especially if cross-border lending is to recover and grow? Banks may accommodate higher reserve ratios by requiring more collateral and by exercising other risk mitigations including diversifying better across all economic sectors and by changed business models. Banks in trade-deficit countries are biased to property lending and in export-surplus countries to industrial trade.

In the years up to 2007, banks grew faster than underlying economies, earning dispro-portionately high profits, 25% - 50% of all profits of publicly quoted companies, which should be unsustainable. Shouldn’t they adjust to more realistic or reasonable profit targets?

The new rules are a cornerstone of the G20 response, a global effort to ensure stable international banking. The rules redefine “core tier one capital”, a measure of a bank’s solvency, plus sufficient liquidity to survive a short-run crisis with less dependence on short-term borrowing. The new ratios would not have saved the banks that crashed in the credit crunch but are a step in that direction to take some pressure off future government budgets.

Dame Angela Knight, chief executive and spokesperson of the BBA, was almost entirely negative about the announcements. She warned that banks have no choice except higher loan margins that will “suck money out of the economy” – by which she means the non-financial economy - as if banks’ profits, bonuses, and speculation can’t do that already. German banks made similar objections, and others too.
Three major UK banks have threatened to domicile themselves elsewhere if the UK government and its Banking Commission decide to split retail from investment banking - Paris and Frankfurt are offering lower tax to induce UK banks to move! Is this further evidence of a return to confident arrogance, of which resisting new capital ratios are shots across the bows of the regulators?

The threats are poor thanks for Government and Bank of England’s heroic roles as lenders of last resort in baling underwater banks. All banks were helped by state aid packages. Banks that did not require direct aid, or not as much as others, yet benefited massively from the help given to others. When Lehman Brothers collapsed, for example, among a host of emergency measures there was $2.5 trillion alone in temporary liquidity by the Fed, BoE and ECB to resolve failed money market trades.

Dame Angela (for the BBA) wants the new rules carefully handled to avoid “prolonging the downturn”. The banks got eight years, a long time in banking. She says, “The consequence is that inevitably the cost of credit – the price the borrower pays for money – will rise. The cheap money era is over.” Surely, a fun remark when the central bank rates continue negative in real terms. A lobbyist for bankers, the IIF used similarly dramatic language to persuade the Basel committee to dilute its reforms. Do bankers think we, politicians and taxpayers, learned nothing about how banks operate, or about how blinkered, self-serving, solipsic and short-termist their thinking can be?

The job of bank risk regulators can seem like herding cats!

The WSJ’s David Weidner wrote: “Judging by their hokey scare tactics, you'd think the act of raising capital requirements during an eight-year span was the final blow to capitalism. But it's not. Basel III is a compromise tilted toward an international banking community that's woefully undercapitalized and vulnerable to breakdowns.

In truth, banks have far flexibility and head-room than their lobbyists want us to see. The public was not fond of banks before the crisis and now views them with mistrust, hatred, and derision. What other industry can prosper when so unpopular?

Banks do not have to make their customers pay; bankers can reduce their own bonus levels for a start, or perhaps regulators should do so – they now have that power! Banks’ pretence that certain people will only work for guaranteed bonuses, as for example for managers of ‘prime services’ to lend to hedge funds. Remarkably, it is so hard to lend them money this requires $5m guranteed bonuses?

Saving losses, what risk managers do, is never so generously incentivized, not remotely so? It is like paying football midfielders thirty times what the goalie gets, and strikers and team manager fifty times as much!

Privately, bankers, regulators, and most everyone else know that “incentivising” star players by handing them bonuses in excess of either group profit or loss damages credibility, solvency and shareholders. Fiduciary prudence is replaced by something else, poorly understood or defined except to call it ‘daylight bank robbery’ or ‘greed’. That is the dominant political and general voting public’s view. Are they wrong?

As someone who enjoys a spendthrift life on high-fees, I understand that heady culture that I am also part of, if better looking than Dick Fuld and freer than Bernie Madoff. Ah sure, wouldn’t we all be somewhat poorer for not having outrageously super-rich like us to gawk at, demonize and blame – but not if the consequence are distorted values that risk our whole economy! Martin Wolf in the FT wrote, “withdrawing incentives for reckless behaviour is not a cost to society; it is costly to the beneficiaries. The latter must not be confused with the former.”

Banks may reduce the capital they have committed to proprietary trading, to speculation, to profit from markets beyond lending to them. Banks may cash in realizable profits and sell non-core assets. Over the years banks can generate internal capital without upping borrowing costs of households and small firms. UK banks would do well to lend more to small firms who employ 40% of all jobs but only get 1.5% of non-financial loans – in the USA 10% and in Germany 19%. Banks can tap equity and bond markets for capital and retain more of net earnings before bonuses. When will they tell shareholders how much bonus is performance related or guaranteed?

The lobbying by IIF used the difficulties of Europe’s local savings banks such as in Germany and Spain, resulted in all banks getting a suspiciously long time to build new reserves, from 2013 to 2019. By then, all current top execs will have retired, rich, and we’ll be in the next recession when government again has to reflate the economy without help from banks!

Rather than scaremongering, bankers should grow up and recognise their priority is to rebuild moral authority and trust by customers, taxpayers and others, not least shareholders, show willingness to adapt their business models and pay themselves less. Scare-mongering fools no-one except the gullible of whom there are precious few left for banks to rely on for support today?

The banking lobbyists’ churlish failure to apologize or acknowledge that they must mend their ways and change how they do business and what is realistic and reasonable risk-based profit only does more damage to the recovery, not of the economy only, but that banks need to make to recover customer and taxpayer trust and loyalty, real self-belief and fiduciary responsibility, including in macro-prudential terms, i.e. real banking professionalism – or maybe I’m just old-fashioned, a grumpy old banker well past my sell-by-date?

*Note: Ingrate, n. One who receives a benefit from another, or is otherwise an object of charity -Devil’s Dictionary.
**Note: Reminding us of, from “The madness of Crowds”, about the inventor of modern bonds, John Law, “he understood the monetary question better than any man of his day; and if his system fell with a crash so tremendous, it was not so much his fault as that of the people amongst whom he had erected it. He did not calculate upon the avaricious frenzy of a whole nation; he did not see that confidence, like mistrust, could be increased almost ad infinitum, and that hope was as extravagant as fear. How was he to foretell that the French people, like the man in the fable who killed in frantic eagerness the fine goose he bought to lay golden eggs?” (Charles Mackay writing in 1841)


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