More than half a decade has passed since the start of the financial crisis. So it is worth investigating if the elite policy economists that advise governments and that dominate policy discussions rely on more robust models of reality than the generation that dominated discussion prior to the crisis (allowing that some of the same faces keep recurring, phoenix-like, from the firestorms they helped generate). In order to explore this question, I look at an influential document whose conclusions I largely endorse—so that I can focus purely on the arguments, assumptions, and evidential practices. I have picked Anat Admati and her collaborators’ “Fallacies, Irrelevant Facts, and Myths in the Discussion of Capital Regulation,” because Admati and Hellwig (one of the co-authors) are the authors of the widely read (2013) The Bankers’ New Clothes. The paper (“Fallacies, Irrelevant,” etc.) beautifully exposes a lot of special pleading by bankers and their advocates and offers sensible policy advice (to simplify: banks need a lot more true equity) based on the straightforward insight (again to simplify) that bankers’ costs are not necessarily social cost. (It does so in the kind of language any regular reader of a newspaper can understand.) Better capitalized bank should, all things being equal, reduce “systemic risks.” Along the way it correctly criticizes one of the most important and simultaneously regressive policy scandals of our time: government subsidies on bank debt which encourage excessive risk-taking and basically make poor people subsidize the life-styles of relatively wealthy folk for little, if any, social benefit. In addition, Admati et al. correctly criticize the bank rules (associated with the more recent, so-called Basle agreements) that allow banks to rely on (i) their internal evaluation of their risks by way of (ii) “risk weighted assets”—a metric primarily designed to encourage banks to buy government bonds and keep creating mortgages on real estate. It turns out, however, as we will see below that they are more critical of (ii) than (i). [In fact, their criticism of (ii) echoes The Bankers’ New Clothes.]
Okay, let me get to my criticism(s): when it suits them in their piece, Admati et al. assume without argument that (a) capital markets function properly (despite providing evidence to the contrary) and (b) that banks actually know how to estimate the risks of their loan-book just fine. So, for example, when responding to the concern that economic growth/activity may be harmed (at least in the short-run, transition period) by the demand for higher equity – the easiest way to get there is to deleverage, that is to reduce the loan book --, they argue that “as long as the bank is currently solvent…the bank should be able to raise the desired capital quickly and efficiently through, for example, a rights offerings. Indeed, the inability to raise the capital needed…provides definitive evidence of the bank’s solvency,” (emphasis in original).
Now, the quoted claim in the previous paragraph is undoubtedly true in theory, but in practice it is by no means obvious for (1) there is considerable uncertainty about bank balance sheets – nobody really believes the accountants [recall]; some banks are so complex that it is doubtful anybody understands the underlying health of the bank at any given time-and nobody has access to relevant data to price accurately systemic risk. So, (1) can create conditions in which it very hard for otherwise solvent banks to raise equity. The converse is possible, too: (2) as long as governments maintain a fairly implicit guaranty for those banks that are purportedly too big to fail, their equity can be priced attractively enough to short term speculators. The upshot of (1-2) is that there is no reason to believe that equity markets will either provide the right signal about bank solvency or supply banks with the relevant equity. (It does not follow, of course, that equity markets won’t supply the needed equity. It’s just that no compelling argument has been given.)
There is a related problem: throughout the piece, (c) they assume that shareholders “will require a lower expected return to be willing to invest in a better capitalized bank.” That is, they assume that markets accurately understand/price risks and, thereby, adjust expected returns adequately (e.g. “in a market in which risk is priced correctly, and increase in the amount of equity financing lowers the required return on equity in a way that, absent subsidies to bank debt and other frictions, would leave the total funding costs of the bank the same.”) Now, let’s stipulate that when stated as a coarse-grained fact of the market’s ability to evaluate relative riskiness of stocks and bonds (etc.) this is undeniable true. But what we have learned during the last decade is that markets are quite capable of exhibiting lack of fine-grained discrimination among assets—this happens during a bubble as much as it happens during a crash. It’s quite possible this is due to misaligned incentives (taxes, subsidies, guarantees, bad compensation plans, etc.) and failed regulation, but it is downright silly to rely on models that do not just assume these sources of friction away in the context of policy, but also are too fine-grained (they have high degree of exactitude, but no reason to believe they are accurate).
At one point in their paper, they recognize the severity of the issue:
Finally, the assumptions underlying the Modigliani-Miller analysis are the very same assumptions that underlie the quantitative models that bank use to manage their risks, in particular, the risks in their trading books. Anyone who questions the empirical validity and relevance of an analysis that is based on these assumptions is implicitly questioning the reliability of these quantitative models and their adequacy for the uses to which they are put – including that of determining required capital under the model-based approach for market risks. If we cannot count on markets to correctly price risk and adjust for even the most basic consequences of changes in leverage, then the discussion of capital regulation should be far more encompassing than the current debate.
To be clear, I love Modigliani-Miller—it is elegant, and a very useful model to help one think about balance sheets and taxation; it originates in the golden age of mathematical economics. But it does not follow that the underlying assumptions (no arbitrage, efficient markets, and – worst of all – the treatment of uncertainty as randomness) are robust in the real world (multiple Nobel prizes to the contrary). As I have repeatedly argued, these assumptions encourage market participants to take controlled bets on outcomes rather than recognizing that they have no firm grip on underlying distributions (and, thus, modalities).
Oddly, the whole quoted paragraph is intended as a rhetorical flourish; they do not propose a more encompassing approach to capital regulation. This is really astounding: one would think that after the collapse of LTCM, Bear Stearns, Lehman, ING, RBS, ABN Amro, the whole Irish banking industry, and a long list of other banks (including mortgage banks), some humility about the banks’ ability to “manage” their risks would be in order.
To wrap up: my criticism does not target the policies advocated by Admati. I have no expertise to offer better proposals. Moreover, her piece is required reading for anybody that wants to learn how different governmental policies (taxes, regulations, accounting standards, subsidies, etc.) impact different stake-holders in banks and, thereby, different political agents in society. It really exposes lots of myths, and its underlying moral stance – dismay at liberal democracies’ persistence at encouraging socially wasteful efforts in finance – is admirable. But let’s hope that somewhere there are freshly minted PhDs in economics that will provide a path to more robust models; it’s been enough time since the crash for young minds to start afresh.
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