Shadow Banking: Goldman’s derivative exposure 25K% of assets in ‘08, 33K% in ‘09
levy.org
levy.org
If you have the line items, you have everything. Without that you have to rely on high level financial statements and the opinions of bank examiners or other regulators. And as Lehman, Madoff, Enron and other cases show, it means you have nothing.
It is time for banks, who operate a public trust, to offer continuous (lagged) line item disclosure to enable crowdsourcing of risk analysis. The markets are running on the informational equivalent of fumes. No wonder they sputter.
I call this Real Transparency. It is no more intrusive than the fact that I can find out how much you paid for your house and how much you borrowed to buy it. Information like this is necessary for the functioning of a proper market and price system. These are worth preserving more than the privileges of banks.
Real Transparency is the kind of regulatory reform that would make a difference. Not the kind which gives power hungry regulators more information to ignore.
I read (probably in the Economist) that a regime like this is already in operation in New Zealand or Australia (if memory serves me right).
Much of what we finance is based on a mental model the future that might not be true. Consider a mortgage. If your house burns down then you still owe the payment.
So the financial industry invented "fire insurance" for the counter-party risk of derivatives, called CDOs. But they too are blamed for the crisis.
The fact is, any set of financial products/buyers/sellers will converge upon a non-worst-case view of the future, and the price of risk will adjust accordingly. Any line you draw in the sand (such as for capital adequacy requirements) is simply an estimate about how risky the future is... and notably it's still a gamble that the future will occur at or above some point in a probability distribution.
Fear mongers do exist, but they only thrive in a low information environment, such as a panic. If banks and other companies provided, or were compelled to provide better ongoing information, they wouldn't be exposed to rumors in the first place. They probably wouldn't see their stocks overinflated either, due to the actions of legitimate short sellers.
A "panic" is just the price decreasing version of a bubble...
My main complaint is that investors are information-starved and our public policy is to blame. All this outrage about people gaming the system is a distraction. We need to fix the system, starting with the banks.
- remove capital adequacy requirements as they (like a paper seatbelt) create a false sense of security. Firms should compete on the basis of soundness as well as other characteristics.
- pass a law outlawing bank bailouts.
- remove restrictions on non-accredited investors, short-selling, derivatives/options trading.
- Increase disclosure requirements for financial institutions.
- Create a new financial statement called "Statement of Risk Exposure" which is a list of the firms' assets in terms of risk. If an asset is on a debt owed by another firm, then that firm's risk statement could be copied and inserted inline, recursively.
Your other measures are interesting. I would keep capital adequacy but seize the bank before capital went to zero. That would improve incentives a bit.
The key thing is to claw back the economic rents that bankers have been handed. Most of these rents are connected to information that bankers have and we don't. This can be changed, but not with the help of today's regulators who are still in thrall to the banking industry despite their statements to the contrary.
The book "Just get out of the way" (http://www.amazon.com/Just-Get-Out-Way-Government/dp/1930865...) has some interesting ideas on how to apply the lessons of now-developed nations to developing ones: Don't copy the bloated institutions the rich world has now, but get inspired by what made them great in the first place. Often these were simpler policies. (Of course this also applicable to developed economies, again.)
The author also advocates ridding banks of any (even implicit) government guarantees, to make customers look out for their money instead of relying on glorified ponzi schemes. (Which banks are in a lot of developing countries.)
Please don't use the terms interchangeably.