Another take on the political fight over regulating compensation in the financial industry, this time from Shumeet Banerji at Booz+Hamilton:
…plans to limit compensation will not work, because they do not address the core problem: the disconnect among bank capital, risks (borne by both banks and society), and compensation structures (particularly the way traders are paid).
…the system is ripe for change. The solution lies not in aggregate, rules-based regulation, but in a microeconomic reassessment, within each bank, of how…to interweave the ways risk is taken, capital is allocated, and people are paid. There are probably several self-regulating and self-correcting mechanisms that banks and regulators could put in place right now. Two simplified examples…illustrate the point.
The first is “paying on the trade.” Instead of paying commissions based on a “mark-to-market” estimate of the value of a position, as most banks do now, base them on the actual profit made when a deal is consummated and the position is liquidated. There would be no need to further reserve against the downside because the risk of the deal would be fully internalized. The second is to require each institution to reserve enough capital to account for the downside risk of the asset that has been purchased, including the value of the share of the putative profit that has been paid out in bonuses.
Either of these solutions would tie compensation and capital directly to the risk and leverage in each contract, rather than setting up crude aggregate standards that don’t take into account the characteristics of a particular trade. Instead of shifting the burden of judgment to regulators, this approach would better harmonize individual and institutional incentives. And when bankers have reason to pay attention to the true economics of their deals, rather than to the impact on their bonuses alone, they might find themselves making better deals — and thus reclaiming the reputation they have lost.
Sounds nice — adjust the institutional frameworks by setting up a “granular”, trade-level approach to regulation that will make banks better stewards of shareholder, depositor, and taxpayer capital. But if the last two decades are any indication, it’s a pipe dream. Here’s the scariest part of Banerjee’s proposition (emphasis added):
…one proposal would set in place a maximum leverage ratio: borrowed funds should not exceed some value, such as 25 times equity. In principle, limiting leverage seems like a good idea, but no aggregate rule can possibly apply to the wide variety of banks, trades, and risk profiles. Such a rule would trump good judgment by skilled risk takers. And a billion dollars worth of investment capital, operating within a regulatory leverage cap, could still be deployed and lost in a million lousy trades.
We’ll make very clear where we stand on this issue:
- Leverage caps are the best and only way to manage systemic financial risk. It was the “competitive” lifting of caps by regulators in Europe and the U.S. that helped get the world into this mess.
- Any given trade has a winning and losing side. A precious few might have enough skill to win persistently, but trading involves a great deal of luck and provides limited social benefits (talk about crowding out…). Luck should not be leveraged!
- There is absolutely no reason, however skilled an individual trader might think themselves, to allow them to leverage their capital many times over.
- The performance of 99% of professional risk takers in 2007-2008 sucked, primarily because traders and risk management departments look myopically at their own books; they are not equipped to monitor systemic leverage and fragility, and the risks that their burgeoning trade books pose to the underlying payments system itself. Sucking and institutional blind spots should not be leveraged!
- A 25x cap on leverage still looks generous, and it’s absolutely fair game for the public to have a debate over what the caps on financial leverage should be.
The fact that we’re talking about proposals as timid as 25x — a level which has still managed to get the global financial system into plenty of trouble in recent decades — is damning evidence of regulatory capture. As William Buiter put it:
The Fed, unlike the ECB and the Bank of England, is also a banking sector regulator and supervisor. This gives it an informational advantage. The downside to the Fed’s position is the risk of regulatory capture. I believe that what I call ‘cognitive regulatory capture’ of the Fed by Wall Street has occurred during the past two decades. The net result is that both as regards macroeconomic stability and as regards future financial stability, the Fed has performed worse during this crisis than the ECB and the Bank of England.
Future regulation will have to be base on size and leverage of institutions. It will have to be universal (applying to all leveraged institutions above a certain size), uniform, countercyclical and global.
Financial crises will always be with us.
Given the timidity of a 25x cap on leverage, we’ll revisit the mathematics of leverage once more. At 25x, a financial entity can acquire (create) $25 of assets for every $1 of equity (which according to balance sheet mechanics, means it takes on liabilities of $24). Because liabilities are senior to equity (liabilities have to be serviced from either operating cash flows or equity), a $1 loss on those assets — i.e., a decline of only 4% — wipes out all equity (or “capital”, in banking lingo). At a leverage ratio of 10:1, the loss on assets would have to be at least 10% to wipe out an entity’s capital. We know from history that financial assets in the aggregate can lose 4%, or even 10%, often in short order. The risks posed to the financial system’s solvency by high leverage should be painfully obvious (and as John Geanakoplos and others have pointed out, leverage tends to be increased and decreased by the banking sector in a very procyclical fashion).
We applaud Banerjee for trying to integrate compensation issues with systemic ones, but it’s extremely speculative to think that the deep seated human behaviors associated with outsized risk taking are going to change due to a shift in compensation practices. Leverage, commitments, and systemic fragility must be the center piece of any new financial regulations, otherwise it will be back to the future - probably within five years, almost certainly within ten.
In fact, if you want to see over-leveraged “skilled risk takers” in action, take a look at gold, which seems ready to go parabolic as traders jump alongside central bank buyers — who historically happen to be the ultimate contrary indicators in gold markets. When the fever breaks — and admittedly, there could still be plenty of ‘parabola’ to ‘trace’ before that happens – it won’t be pretty. Momentum lemmings should not be leveraged!!! Unfortunately, they still are…

URLs:
http://www.strategy-business.com/article/00007?pg=all
http://www.nber.org/~wbuiter/NAcrisis.pdf
http://www.arts.cornell.edu/econ/CAE/conferences/John%20Geanakoplos.pap.pdf
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