How, if at all, Should Credit Rating Agencies (CRAs) be Regulated?

The role of credit ratings agencies (CRAs) is to forecast the probability that the issuer of a debt liability will default on the due repayment (its probability of default, PD). In this respect, CRAs are one of a large set of institutions and people who seek to forecast certain aspects of the future. As a generality, the only, or at any rate the most important, requisite of a forecast is its accuracy. So long as the forecast is accurate, it is largely beside the point how the forecaster behaves otherwise, whether they lead a blameless life, or alternatively are rude to their parents, beat their children or cheat on their spouses, etc. Moreover, in the case of CRAs, (unlike the Delphic oracle), the forecast is not only relatively clear in content, (though we shall consider later how it could, and should, be made even clearer), but also the status of the event being forecast, i.e. whether the issuer defaults, or not, on due repayment, is also relatively clear – and any remaining fuzziness often becomes subject to a legal decision. So the forecasting activities of CRAs should be susceptible to ex post accountability. Compare forecast with out-turn; assess and publish the comparative accuracy of the various CRAs' and leave competition to do the rest. We shall review what extra steps need to be taken to enhance such ex post accountability, comparing forecast with outcome, and comment briefly on how, perhaps, to enhance competition

Richard Sidney Sayers (1908–1989)

Richard Sayers’s greatest strength was as an economic historian of institutional changes within the British financial system, especially relating to the Bank of England, for which he became the second official historian covering the years 1891-1944; but also writing the histories of Lloyds and Gilletts, and a wider study entitled Financial Policy, 1939-45. Nevertheless, he is best known for two other contributions. First, his textbook, Modern Banking, remained required reading on this subject for all British undergraduates from 1937 until the early 1970s; second, he played the major role in the domestic monetary analysis of the Radcliffe Report (1959). This latter role was often not well received, and his historical and institutional approach to the subject began to be treated as unfashionable and outdated, so that Sayers, always a lone introvert, had a somewhat sad end to his lif

Goodhart's law and machine learning: a structural perspective

We develop a simple structural model to illustrate how penalized regressions generate Goodhart bias when training data are clean but covariates are manipulated at known cost by future agents. With quadratic (extremely steep) manipulation costs, bias is proportional to Ridge (Lasso) penalization. If costs depend on absolute or percentage manipulation, the following algorithm yields manipulation-proof prediction: Within training data, evaluate candidate coefficients at their respective incentive-compatible manipulation configuration. We derive analytical coefficient adjustments: slopes (intercept) shift downward if costs depend on percentage (absolute) manipulation. Statisticians ignoring manipulation costs select socially suboptimal penalization. Model averaging reduces these manipulation costs

Richard Sidney Sayers (1908–1989)

Richard Sayers’s greatest strength was as an economic historian of institutional changes within the British financial system, especially relating to the Bank of England, for which he became the second official historian covering the years 1891-1944; but also writing the histories of Lloyds and Gilletts, and a wider study entitled Financial Policy, 1939-45. Nevertheless, he is best known for two other contributions. First, his textbook, Modern Banking, remained required reading on this subject for all British undergraduates from 1937 until the early 1970s; second, he played the major role in the domestic monetary analysis of the Radcliffe Report (1959). This latter role was often not well received, and his historical and institutional approach to the subject began to be treated as unfashionable and outdated, so that Sayers, always a lone introvert, had a somewhat sad end to his lif

The great Covid cash surge - digitalisation hasn't dented cash's safe haven role

There is a debate about the effect of the extremely low, or even negative, interest rate regime on bank profitability. On the one hand it raises demand and thereby adds to bank profits, while on the other hand it lowers net interest margins, especially at the Zero Lower Bound. In this paper we review whether the prior paper by Altavilla, Boucinha and Peydro (2018) on this question for the Eurozone can be generalized to other monetary blocs, i.e. USA and UK. While our findings have some similarity with their earlier work, we are more concerned about the possible negative effects of this regime, not only on bank profitability but also on bank credit extension more widely

Lender of Last Resort and moral hazard

In this paper we revisit the Lender of Last Resort (LOLR) function of the central bank and the associated moral hazard incentives. We argue that, from an economic perspective, the strict application of penalties to the operation of LOLR actions can make that instrument unworkable. Instead, we suggest that both penalties and publication should only be applied after such LOLR had been in place for a time. Normative frameworks ought to be adjusted in this regard

A note on the differences between European and international methodologies of banking regulation and supervision

Although monetary policy is the main tool for central banking in order to control inflation/deflation, micro- and macroprudential instruments are also essential for crisis management. In this paper, we aim to clarify the differences between European and international banking methodologies. The European approach as represented by the European Banking Union, is based on a harder legalistic approach, whereas the international approach implemented by the Basel Committee on Banking Supervision has a soft-law methodology. We propose two comparative standpoints: “uniformity” versus “diversity”, and a “legislative” versus "principle-based” approach