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November 15, 2008

Comments

Don the libertarian Democrat

I just read through it, and it seemed to be simply a statement of the kind of world we'd like to live in. There didn't seem to be anything to argue with, because there weren't any specifics. What was the point? Why not just say we'll try and do things better in the future?

Per Kurowski

Let me share with you from my Voice and Noise my personal experience as an Executive Director of the World Bank 2002-2004 with these “Statements” or “Communiqués” as they are more elegantly called

“The Annual Meetings Development Committee Communiqué

I must confess that I do not really understand how it gets produced. We sort of start out by pitching out a lot of issues to ourselves and then we go over to the other side and bat the balls back for about eleven continuous hours just so that we can later have a chance of fielding them again in our Board meetings six months later. It is hard to tell whether we are in a virtuous or a vicious circle or, if at the end of the day when we get some issues out of the loop, it is because we have adequately exhausted these issues or because they have just exhausted us.

Nonetheless in this unpleasantly volatile world we might find comfort in the thought that our communiqués provide an inspiring source of stability—as they always read the same.

Any readers who do not understand what I am talking about should not worry. The preparation of communiqués is like one of those strange initiation rites impossible to describe to anyone not part of them … and to most who are part of it.”

Cheers

Per Kurowski

But on a more serious note let me question it when they say:

“Regulators must ensure that their actions support market discipline, avoid potentially adverse impacts on other countries, including regulatory arbitrage…”

What more discipline could they want than having imposed on the markets as a Governess Fraulein Credit Rating Agencies and that later turned out to be so crazy as to guide them to the subprime swamplands? Do they really believe that finding a better qualified Mary Poppins, or a Maria will do it? Scary! Why don’t they leave the banks alone so that they learn to depend on themselves instead of following as a herd any agency that no matter how good it gets, is bound to take them, and us, sooner or later, over a cliff?

“Adverse impacts on other countries”? Like when the supposed global good of a credit rating agency turned into a global bad and caused a German bank that had never awarded a mortgage in Germany to be the first casualty of this subprime mortgage having followed the AAA signs looking for high risk-weighted returns in California?

“including regulatory arbitrage? Are we now finally to get rid of the current “minimum capital requirements for banks” that has created such a damaging and useless regulatory arbitrage on risk…whatever that now is?

Barkley Rosser

The statment does call for the development of "colleges of supervisors" (that is, of regulators). In the near term this may be the most realistic approach to moving towards international coordination of regulation, and had begun more informally already. This involves how a specific multinational enterprise, particularly a financial one, is regulated, with the regulators from the main nations the enterprise operates in meeting together to coordinate their regulation of that specific enterprise. To the extent this can be done, this is a good thing.

The main problem with this will be to coordinate to shut down the loophole escape hatch sorts of places such as the Cayman Islands. This will involve the G-20+ countries forbidding their own financial institutions from dealing with any entity operating in environments that do not enforce internationally accepted financial standards.

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