Culture and conduct in question

Stuff’s new, apparently Canadian, journalist Kate MacNamara is doing a pretty good job of keeping up the pressure on the Governor of the Reserve Bank, Adrian Orr.  It is hard to believe a New Zealand journalist would have done so –  one column perhaps, but not three in a week.  Then again, I’m pretty sure we’ve never had a Reserve Bank Governor behaving in quite such an egregious and unacceptably poor way –  not as a single lapse of judgement either, but as a sustained pattern of behaviour.  Sadly, the conduct of the Board (and the Minister?) in such matters, of which more below, is all too typical of the New Zealand establishment.

MacNamara’s latest (“Orr’s culture and conduct in question”) was in the Sunday Star-Times yesterday.   She frames the issue as one of whether the desired end (a stronger banking system) justifies the means (Orr’s conduct).  I’m not sure that is the best way to frame the issue, but here is her take

In December, the Reserve Bank released its boosted capital reserves proposal and asked all interested parties to make submissions.

It would be an open process, the bank said, welcoming all views. But that characterisation was soon at odds with the governor’s behaviour.

Numerous parties involved in the submission process described a pattern of behaviour by Orr of belittling and berating those who disagreed with him.

Orr has penned his critics letters and threatened to broadcast them. He has confronted submitters on the sidelines of industry conferences. Sometimes he called them up at odd hours to tear a strip off them for their views.

And that is before starting on the not-particularly-robust analysis in support of the Governor’s proposal  –  for a huge increase in bank capital ratios, after years when the Bank assured us the system was sound and robust – that the Bank has, only slowly, been rolling out.  Cost-benefit analysis anyone?  Only after he has made his final decision –  for which there are no rights of appeal –  the Governor tells us.

As MacNamara notes, Orr wields an extraordinary level of power in this area –  unparalleled, as far as I know, anywhere in the advanced world.  He can wheel up a proposal, working to no very well defined parliamentary mandate, has only to jump through process hoops around consultation, and then makes the final decision all by himself.  There are no substantive appeals allowed, and the Minister of Finance cannot overrule him (though could, if he chose, bring other pressures to bear).

One of my criticisms of the Governor is that he doesn’t stay in his lane, and sounds off on all manner of highly political issues in pursuit of his personal ideological agendas (in ways we’d find quite unacceptable if other senior independent figures –  the Police Commissioner, the Chief Justice eg – were to do it).  Sadly, that has become quite common –  especially around climate change – among central bankers globally, and Mark Carney (Governor of the Bank of England) has made pretty clear his personal views on Brexit.  As MacNamara notes, apparently

To provide a little context, Orr was recently compared in his outspokenness to Bank of Engand governor Mark Carney.

Paul Waldie covers Carney in London as the European correspondent for Canada’s Globe and Mail newspaper. Carney was previously governor of the Bank of Canada.

Carney has been criticised for playing politics in his estimations of the cost of Brexit in the United Kingdom.

But Waldie is emphatic. “He’s never rude. He’s never personal. He doesn’t hit back at his critics. He’s cool-headed.”

Carney provides no precedent for phoning adversaries after hours, neither blasting them from the lectern or on the sidelines of industry meetings and events.

He gives serious thoughtful speeches as well.

MacNamara concludes

On the contrary, Orr appears to be unrivalled among central bankers in the developed world for the tempestuous and personally directed venting of his views.

I’ve watched, and participated in, central banking for a long time, and that would be my view too.  MacNamara introduces another overseas expert on such matters.

Annelise Riles of Northwestern University’s Buffett Institute for Global Affairs, who’s studied the behaviour of central bankers and has even written a book about them, couldn’t think of a single comparator in contemporary times.

Central banks certainly use many channels to communicate with banks, she said. And it’s not uncommon for central bankers to let banks know how they feel.

“But berating them publicly is just not seen very much,” she said. And though private exchanges are less visible, she couldn’t think of any examples of bald incivility or hostility.

Central bank heads often aren’t even close to saints  (just think back a few years to the way Graeme Wheeler and his top team –  including the current Dep Governor – were used in a not-at-all subtle attempt to shut down criticism from the BNZ’s Stephen Toplis), but nonetheless Orr’s sustained pattern of conduct seems to stand out.  Perhaps the only “defence” one might make of it is that what you see is what you get –  he has always been known for these sorts of tendencies.  He can behave fine when he is on top in an unquestioned way, but put him under any sort of pressure and he isn’t someone to conduct himself with dignity, civility, and respect.

I haven’t had particularly bad experiences of Orr’s personal conduct myself. I had quite a bit to do with him in his two earlier stints in the Reserve Bank, but when he was Chief Economist I was in the Financial Markets Department and when he was head of financial markets and bank supervision I was in the Economics Department.  I saw shonky analysis in support of questionable policies, and didn’t have much time for his divisive style (which, remarkably, he owned up to in a farewell speech when he left the Bank the first time).  But I was left some mix of underwhelmed and bemused  –  at this extremely ambitious, outgoing, sometimes amusing, opportunistic, but not fundamentally serious person –  rather than having any particular sense of personal grievance.  When he was appointed Governor I wrote a couple of posts (one here) that I still think read as a pretty balanced treatment, if generous with the benefit of hindsight.

Others have had a much stronger view.  This comment was left on my Saturday post by Geof Mortlock, who worked directly under Adrian during both of Orr’s previous Reserve Bank stints.

None of what we are seeing with Adrian Orr surprises me in the least. It is precisely what I had expected when he was appointed as governor. The problems so clearly revealed now for all to see were very much evident to me and many others when Orr was deputy governor and head of financial stability in the period 2003 to 2007.  He created a sense of panic when there was no need for it. He engaged aggressively with Australian banks when mature, adult dialogue would have been far more effective and appropriate. He facilitated and abetted an aggressive and petulant fight with APRA, RBA and Aussie Treasury over trans-Tasman regulatory issues rather than seeking to resolve them in a considered, intelligent manner. He engaged aggressively with staff and routinely bullied them. He created a deep level of stress in the RBNZ among staff that contributed to the departure of some key people. I can attest to what it was like working with him. I and others departed the RBNZ because of the severe impact he had on morale and because of concerns over mismanagement of issues and because of the appalling culture that he and others created in the RBNZ. Bollard presided over much of this, either unaware or unconcerned, and did nothing to address the matter from what I could see.

Now that Orr is governor, his unsuitability for the job is evident for any impartial observer to see. The lack of judgement, unsuitable temperament, lack of maturity, inadequate knowledge of the issues and a serious failure to intelligently addressthe policy issues are all obvious to anyone who cares to look at his performance.

Sadly, the RBNZ Board seems to lack the competence or mettle to do anything about it. Its recent annual report was a pathetic effort at exercising meaningful scrutiny over Orr. Even more sadly we seem to have a minister of finance who is asleep at the wheel and either turning a blind eye to Orr’s appalling incompetence in handling the tasks entrusted to him or who is happy to see Orr playing an overtly political role that is totally inappropriate for someone holding office as governor.

It is time that the people with authority over Orr did something about his conduct, statements and handling of policy issues. The RBNZ’s credibility is at stake. And serious policy outcomes are under threat. Robertson and the Board need to take action to address the Orr problem.

Ah, the Board.  They got us into this mess.   Assuming they followed the provisions of the Act (and didn’t just take guidance from Grant Robertson) they are the one’s responsible for his appointment as Governor.  They don’t have many other specific powers, but they have an overarching responsibility to keep under “constant review” the performance of (a) the Bank, and (b) specifically, the Governor in whom most of the powers of the Bank are still personally vested.    If the Board isn’t satisfied they must advise the Minister in writing, and may go so far as to recommend the dismissal of the Governor.  (Regardless of the views of the Board, the Minister may also recommend dismissal of the Governor is satisfied that the Governor has not “adequately discharged” the responsibilities of his office.)

Last week I suggested that one omission from the first MacNamara article was any sign of having approached the Board.  I didn’t expect she’d get much if she asked, but what the chair said was likely to be telling, even if he simply stonewalled.   Anyway, for this week’s article MacNamara went to the chair, the economist academic (and Vice-Chancellor of Waikato) Neil Quigley and sought comment.  This is what she got.

Orr’s chequered behaviour is not something on which the Reserve Bank chairman, Neil Quigley, is prepared to act.

“I have not received a formal complaint from any party about the governor’s interaction with them,” he said. “The Board has full confidence in Adrian Orr’s leadership.”

Some people will argue that Quigley had little choice but to express full confidence (for a corporate board you back the incumbent until you sack him or her).  I don’t agree with that take, given that the Reserve Bank’s Board is explicitly set up as a monitoring and accountability body, with its own public reporting responsibilities etc separate from those of the Bank.     It isn’t an executive body.

But what startled me wasn’t the formulaic “full confidence” line  so much as the rest of the comment.  Here is how Eric Crampton phrased his response to Quigley’s comments

eric orr.png

Quite.   Of course, Orr doesn’t have much power over some people who have been badly treated by him –  for example, the academic Martien Lubberink –  but the general point, that one is dealing a very powerful man here, is well made.  How did the Board so diminish its own sense of its role that the only thing they’d be interested in is a “formal complaint”?  And why would they suppose anyone would bother them when the Board –  under Quigley and his predecessors (think of the Toplis business or the OCR leak) –  has a long record of really only acting as fronts for successive Governors (even on rare occasions when something approaching a “formal complaint” has been made).    It is almost like a climate in which everyone knows there has been, say, a culture of sexual harrassment in an organisation, perhaps starting from the top, but no one quite has the courage to lodge a formal complaint –  the fact that “everyone knows” something should still put a Board on notice that there is something to get to the bottom of, something that needs addressing.   Quigley and his colleagues surely are reading the newspapers and other commentary and they should be keeping an ear open on the cocktail party circuits etc they no doubt frequent. It is their job –  “constant review”, not simply responding to a “formal complaint”, whatever one of those might be in this context.

That is what serious people doing the Reserve Bank Board job would be doing.  But, of course, no one –  with the possible exception of the Governor –  has any confidence in the Board to do its job.  It is why the government has made an in-principle decision to remove that role from them, but in the meantime perhaps they do a public service in demonstrating just what a pointless useless entity there are.  I gather the Board has its monthly meeting on Friday,  It is time for a rethink, and for beginning to finally take seriously the growing concerns about the Governor, not waiting for “formal complaints” Perhaps Quigley’s comment could even perhaps spur a few people to consider lodging ‘formal complaints” –  not necessarily because as individuals they can’t cope with a rude bully, but because we should expect much better standards of behaviour from powerful public figures.

The whole episode –  the bank capital review –  has been characterised by poor process, poor substance, and astonishingly poor conduct, all of which are the Governor’s personal responsibility.  He needs to be called to account –  and not just by a journalist and a few specialist commentators –  by those formally charged with doing the job (Board and Minister), but also by his own senior managers (eg he has a deputy governor with a secure statutory position and earning $600000 per annum), decent people who must be getting increasingly uncomfortable with the boss’s style.   Apart from anything else, it is simply a shocking model for up and coming central bankers and financial system regulators.  People are shaped, for good and ill, by those who lead the organisations they are part of.   Rigour, detachment, courtesy, openness, gravitas, judiciousness and so on are the sorts of qualities we should expect to find in a Reserve Bank Governor.  Not one of them seems to characterise the incumbent.  It isn’t a single lapse of judgement, but a systematic pattern of  the sort of culture and conduct that should alarm anyone who cares about good governance and high-quality policymaking in New Zealand.

Portrait of a strongman

It didn’t seem like the best weekend for Reserve Bank Governor Adrian Orr.

First, there was Radio New Zealand’s Insight documentary on the Governor’s bank capital plans, and other possible new regulatory burdens.  I was impressed with the huge amount of time and energy that was put into the programme, although inevitably there are limitations in what a programme designed for a mainstream Sunday morning audience can deal with.     In some ways, the best public service now would be if Radio New Zealand and/or the Reserve Bank agreed to release the full interview Guyon Espiner did with the Governor –  we were told it was an hour long, but no more than five minutes would have been used in the programme (I presume this was par for the course on Espiner’s background work, as I did an interview with him that went for perhaps 40+ minutes).

In commenting on the substance of the programme one then has to be a bit careful.  The selection of quotes and the framing is Espiner’s (and I did notice a couple of small errors) and although he is a responsible senior journalist, the way he presented material isn’t necessarily the way the Governor himself might have chosen to.  Then again, the Governor has plenty of communications media open to him and after 18 months in the job still hasn’t given a speech about financial regulation topics, for which he personally has huge personal policy freedom.

But as RNZ presented the Governor’s arguments, they were less than impressive.  They seemed to be playing distraction more than engaging with what should be the core issues.  Not once, at least according to my notes, did he engage on the possible costs and distortions his proposals would introduce (whatever the possible benefits). Not once, for example, did he engage with how comparable his proposals are to the regime that will apply in Australia to the respective banking groups (hint, Orr’s are much more onerous).

Instead, we got irrelevancies.  The Governor decreed that banks were earning too much money in New Zealand.  Not only that, in his tree god and garden imagery, the (Australian) banks were “darkening the garden”, such that the market was not as competitive as it should be.  Perhaps there is something to those arguments, but they are simply not the Governor’s job and should be irrelevant considerations in proposing to exercise regulatory powers under the Reserve Bank Act (directed to promoting the soundness and efficiency of the financial system).  We have a Commerce Act, there are powers now for the Minister of Commerce or the Commerce Commission to initiate a market study.  But that has nothing at all to do with the Reserve Bank, the prudential regulator, not the competition authority.

Orr came a little closer to his own ground, and to respectable arguments, when he suggested that existing capital (and leverage) ratios were just too low, and thus that banks were “too risky”.  That might have been a touch more persuasive if, for example, he’d engaged with the standalone credit ratings of the banks operating here, or talked about the differences between a strongly-diversified big bank and an individual borrower (instead he tried to imply that the risks, and hence appropriate capital, were much the same).  There was the rather weak claim that “at times” housing crises have led to banking crises, but no attempt to unpack that claim, or to engage with the repeated stress tests his own institutions has done this decade.  Let alone, to consider the experiences of banking system like our own (or Australia’s or Canada’s or Norway’s) that with floating exchange rates and governments out of the housing finance market have proved resilient over many decades.

Instead we got another attempt at distraction, suggesting that the New Zealand experience in 2008/09 was really rather a close-run thing.  He knows it wasn’t so. He knows that the issues the New Zealand banks (and their parents) faced in 2008/09 were about liquidity, not about credit quality or loan losses.  There had been a degree of complacency among the banks about liquidity in the 00s –  I recall one discussion with the head of risk at a major bank in about 2006 who simply could not conceive of a world in which funding liquidity markets would dry up almost completely.   But liquidity is a different issue than loan losses –  which were modest in a fairly deep recession after a period of very rapid credit growth – and even the liquidity/funding issues New Zealand banks faced never threatened to bring any of them down.  And the Bank addressed the funding/liquidity issues almost a decade ago, with much more stringent policy requirements.    And risk-weighted capital ratios are already higher than they were going into the last recession  –  partly under regulatory pressure, partly market pressure  –  a recession when (to repeat) the loan losses were pretty modest and not at all threatening.

Then we had more rhetoric about how the Bank was not going to “keep falsely subsidising bank businesses”, although the nature of any such “subsidy” was never clear given (a) the resilience of banks to the Reserve Bank’s own stress tests, and (b) the central place the Bank has long argued OBR should have in handling any bank failures in New Zealand.   But it probably sounded good.  And then he fell back on attempts to exaggerate the costs of financial crises, with talk of “generations of lost employment opportunities”, mental health failures, and vague allusions to various “challenges” of the world right now –  the Brexit, Trump duo again I suppose – being down to insufficient bank capital.    Evidence and sustained argumentation would help –  if not on a short radio programme then, for example, in speeches and robust consultative documents and –  perish the thought –  upfront cost/benefit analyses (as distinct from the ex post one they might eventually show us).

There was some discussion of dairy lending.  As the Governor fairly noted there had been some fairly aggressive and unwise lending to that sector over the last 15 years (in the early part of that period the impression was that the offshore parents had little real idea of what the subsidiaries were doing in that sector).  Dairy farm economics doesn’t look as it once did, for various market and (actual/proposed) regulatory reasons, so no doubt there isn’t the same bank risk appetite there once was.  But it is quite unconvincing for the Governor to try to pretend his capital proposals won’t exacerbate pressures in that sector, or in other sectors where specific hard-to-extract and manage  knowledge/experience is key to good lending.  Big corporates, for example, who can simply turn to banks not affected by the Governor’s proposal (overseas-based banks, and even the parents of the NZ locally-incorporated banks).  I doubt credit supply will be too adversely affected for residential mortgage finance either.  But for other sectors, including dairy, who does the Governor expect to step into the gap?  Wasn’t he talking (see above) about insufficient competition?  Won’t these proposals weaken that competition, especially as all the locally-owned banks are themselves capital constrained?

The Governor also tried to claim that the Bank’s existing capital rules had somehow “caused” the banks to run into problems on dairy lending, citing differences in risk weights used by various banks for apparently similar lending.   Even to the extent there is an issue there, it is worth remembering that (a) by far the biggest increases in dairy lending occurred (last decade) before the advanced models approach came into effect, and (b) good banks get things wrong from time to time, and none of the actual or stress-tested dairy losses pose any threat to systemic stability.  The Governor’s numbers tell him so.   We want banks to lose money from time to time –  were they not doing so the Governor (on another day, another trope) would probably be complaining about them taking insufficient risk, holding back opportunities etc.

And then, of course, there was the cavalier line I wrote about on Friday: the Governor in essence telling the banks that if they don’t like his rules (and him as prosecutor, judge and jury in his own case) they can just take their money and go.  I wrote about this  irresponsible line on Friday.

Perhaps we should see his talk –  all it appears to be at present – about banning people from serving on both the boards of parent and New Zealand subsidiary at the same time, as all part of that same mentality of suspicion of Australian banks.  The Governor shows little or no sign of appreciating the value New Zealand, and New Zealanders, get from having banks that are part of much larger banking groups, from a country with a track record of a stable and well-managed banking system.  He talks a lot about the standalone capacity of New Zealand subsidiaries in a crisis, but very little about the benefits of integrated banking operations in more normal circumstances (ie at least 99 per cent of the time).  He seems to be hankering for the Australian banks to sell down their shareholding in the New Zealand subsidiaries –  acting as, in effect, an agent for NZX and the New Zealand funds management industry – while showing no sign of recognising that a more arms-length New Zealand operation might also be one less well-placed to receive parental support if something ever does go wrong.

All in all, I just wasn’t persuaded that Orr was even trying to make a serious sustained analytical case for the specific policy he is pursuing.  Playing distraction seemed to be more the style.  (Perhaps I’m wrong and the tape of the full interview would no doubt tell us more.)  That, after all, is the problem with the regime: at least formally, under the law, having dreamed up this proposal all by himself, the only person he actually has to convince of its merits is….himself (final decisionmaker).

Oh, and I almost forgot to mention Auckland University economics professor Robert MacCulloch’s comments.  He highlighted the “sheer lack of raw intellectual firepower” at the Bank, and claimed that neither the Board nor the senior management were really up to the job.  I probably wouldn’t have put it quite that strongly –  there are still able people but in the Board’s case they seem to have no interest in doing anything other than covering for the Governor, and in the staff’s case, personal self-protection –  with a Governor who does not welcome challenge –  is a deterrent to people speaking up even if they have (a) stayed on, and (b) disagreed.      The Bank has lost a lot of good people this year, for various reasons, but few would have had much involvement in the bank capital issues.  MacCulloch’s other comments resonated more strongly with me: there is no history of extreme fragility in the New Zealand banking system (“rather the opposite in 2008”) and that the Governor’s style is undermining confidende in the Reserve Bank, at home and abroad.

Of course, only a few geeks would try to unpick the Insight programme.

But the Sunday Star Times did us a public service with a big double-page article on the Governor that was distinctly less than flattering.  The online version ran under the title “Portrait of the Governor as a strongman”.  I’d encourage you to read the article. Several critics were actually willing to go on the record –  not, of course, ones from among the banks (the “strongman” has a lot of power over them).

Here is an extract, starting with reference to the heavyhanded stance Orr took with veteran and highly capable journalist Jenny Ruth at a recent press conference

The video of the conference remains on the Reserve Bank’s website. Some reporters said they were stunned Orr would air his anger so publicly and called it bullying.

But other observers were not surprised. Details of Lubberink’s experience were already circulating in Wellington and industry sources say they match a pattern of hectoring by Orr of those who question the Reserve Bank’s plan.

“There is a pattern of [Orr] publicly belittling and berating people who disagree with him, at conferences, on the sidelines of financial industry events,” said one source who’s been involved in making submissions to the Reserve Bank on the capital proposal.

There have also been angry weekend phone calls made by Orr to submitters he doesn’t agree with.

“I’m worried about what he’s doing.”

The source said some companies have “withheld submissions,” for fear of being targeted by Orr.

“They’re absolutely scared of repercussions. It’s genuinely disturbing,” he said.

(Orr told someone recently he didn’t read what I write –  his perfect liberty of course –  so I guess I’m safe from the “angry weekend phone calls”.)

Sadly, one can’t really say it is shocking.  It is, more or less, what one might have come to expect.  But it is appalling, and a far cry from the sort of standard the public has a right to expect from such a powerful public servant.  Wielding so much power singlehandedly, with few checks and balances, we need someone with a judicious and calm temperament, happy to engage openly and non-defensively, and so on. Instead we have Adrian Orr.

The article reports that Orr refused to be interviewed.  But perhaps the bigger question is why the journalist responsible –  for a very useful and courageous article –  showed no sign of having sought comment from Neil Quigley, the chair of the Bank’s Board who is paid to hold the Governor to account.  And there was no sign either of having sought comment from Grant Robertson, the person who actually has the power to dismiss the Governor and whom –  as voters –  we might expect to be visible when concerns like these are raised.  (And if the Minister of Finance isn’t visible, why isn’t the Prime Minister insisting that her Minister do his job?)  The behaviour as reported should be unacceptable in a democratic society governed by the rule of law and conventions of acceptable conduct.

Another quote from the article

In the cut and thrust of the debate, Orr’s jokey style and everyman charisma fell away. In recent months he’s dogmatically insisted the cost of his plan would be minimal and has picked personally at critics in the media, academia, and the financial services industry.

He’s been variously described as defensive, bullying, and perilously close to abusing his power.

“He’s in danger of bringing scorn on his office,” said long-time industry watcher David Tripe, professor of banking at Massey University. “I used to know him well. I no longer feel so confident.”

I was exchanging notes last week with someone about comparisons between Graeme Wheeler and Adrian Orr.   The SST article reports insiders claiming that Wheeler had not been keen on the idea of big increases in capital requirements for locally-incorporated banks.  If so, that is to his credit.

Not much else was. I’m not going to repeat his failings, but recall just how unpopular he had become with key stakeholders by late in his term (the survey the New Zealand Initiative undertook). By the end, his departure was almost universally welcomed, and must almost have been a relief to him too, as someone never at all comfortable in the public spotlight.

Orr is more a polarising figure, in that he does still have some supporters, but they must be getting quite uncomfortable with his style, even if they are sympathetic on substance.  But a rerun of that NZI survey would be unlikely to show up the Bank in a good light.  The more time goes on the more unsuited Orr appears to be for the office to which the Bank’s Board and the Minister of Finance appointed him.     He degrades the standing of the Bank here and abroad, as well as eroding its internal analytical capability and whatever spirit of robust internal debate was left after Wheeler, and undermines confidence in the institution’s ability to manage real threats.  It is rather sad to watch, but perhaps only a slightly more extreme example of the sustained degradation of policy capability and leadership in New Zealand public life and public sector this century.

 I hear on RNZ this morning the Governor was quoted as pushing back – I think mainly against MacCulloch – suggesting that criticisms were “narrow nitpicking”.  But there is a long list of sceptics, and of reasoned critical submissions on what is proposing, and how he is doing it. For anyone interested, here was my formal submission

Revisiting some RB history

One of Stuff’s political correspondents, Henry Cooke, had a column in this morning’s  Dominion-Post about Adrian Orr and the power he wields, single-handedly, around banking regulation.

The column starts with some comparisons with some other senior public servants

Think Police Commissioner Mike Bush, former Treasury boss Gabriel Makhlouf​, or State Services Commissioner Peter Hughes. These three have had more influence over the way this country is run than all but the most powerful MPs.

Yet that trio can technically be called to heel by their ministers, even if doing so will probably result in a serious headache for the minister in question. Not so for Reserve Bank governor Adrian Orr, whose independence is enshrined in law.

Not probably company most would want to be numbered with.  A Police Commissioner who gave a eulogy at the funeral of a former policeman widely accepted as having planted evidence in a murder case, who seems to be counted on not to make trouble for whichever party is in power, and who is only too happy for the NZ Police to cosy up to, and assist, the PRC security forces.  A now-departed Treasury Secretary who presided over the decline of his own institution, and then flitted the country refusing to accept any serious responsbility for his own conduct over the “budget hack” affair.  And so on.     Whatever influence these people might have – not much I’d have thought in the case of the Police Commissioner – they have no policymaking powers themselves.

By contrast, when it comes to banking regulation, the Reserve Bank Governor enjoys a great deal of formal power, with little accountability and no rights of appeal against his policy decisions.   They are powers which should be reined in, by MPs and ministers, and which while they exist need to be used with the utmost judiciousness and care.  Under Orr, it is more like a bull in a china shop, pursuing personal whims, perhaps political agendas, all supported by not very much robust analysis at all.   I’ve written about all that previously and am not going to repeat it today.

Cooke notes the suggestion by Paul Goldsmith that the Governor should have fewer policymaking powers, with big policy calls in banking regulation being made by ministers and MPs, as big policy calls in most other areas of public life are.  But then follows a strange end to his article, which is the point of this post.

Goldsmith knows all about how the Reserve Bank can set off real political fires. He wrote the book about the last Reserve Bank governor to step so seriously into the fray: Don Brash. Way way back in 1990 the then-Labour government’s election-year Budget was utterly blunted when Brash decided to immediately hike interest rates in response. Brash was drawn into the bitter debate between David Lange and his own finance minister, and the whole thing was extremely public.

We are nowhere near that level of chaos yet. But things sure are starting to get interesting.

I guess it is what comes of middle age, but the events of 1990 still seem to me not much further back than yesterday (not “way way back”), but I suppose the typical journalist is young.  Even so, it isn’t hard to have checked that the Prime Minister in question was Geoffrey Palmer  (and, unless I’ve missed something, the Goldsmith book doesn’t seem to deal with the episode in question at all).

And there are a few things to bear in mind as institutional context to that episode:

  • the Reserve Bank had received statutory operational independence only a few months earlier, under legislation initiated by the government in question (4th Labour government,
  • under that legislation, the Bank was responsible for pursuing an inflation target, primarily set by the government but formalised in a Policy Targets Agreement between the Governor and the Minister.  That agreement had been signed as recently as March 1990 and required as to get to price stability (0 to 2 per cent annual inflation) by the end of 1992,
  • at the time, the Labour government was miles behind in the polls, in an FPP electorial system, and generally expected to be thrashed in the polls later that year (I see in my diary that in the week in question I observed that “the only question seems to be whether Labour will hold St Albans and Christchurch Central”, two of Labour’s safer seats, held by Minister and PM respectively,
  • while National had supported the Reserve Bank Act (a) it was promising to push the target date further out (to 1993) and (b) that was with the Richardson camp dominant, but there was a fear that a less “hardline” strand within the caucus might prove dominant (eg, as it was thought at the time, the popular Winston Peters and Bill Birch),
  • the reform programme had already ripped apart Labour, the economy was in the midst of a difficult adjustment, and privately even someone as mainstream as the Minister of Finance was saying privately (in a meeting with officials), “we all know that if we don’t get to 0 to 2 per cent, we’ll just change the target”.

All of which could be summed up in the idea that there was not yet a great deal of credibility attached to the notion that inflation was actually going to be securely lowered into a 0 to 2 per cent range.  People, including markets, were searching for signals and signs that might buttress or undermine confidence.  And yet it was the Bank’s job –  mandated by Parliament and the Minister – to deliver that price stability outcome, and to do so at least transitional economic cost.

So what happened?   On 24 July 1990 the government brought down a Budget that was treated by financial markets as something of an election giveaway.  Under the rules at the time, they posted a surplus, but only by including what was in effect a large expected asset sale proceeds as revenue, and significant deficits were again forecast in the out-years.  It was widely viewed as a reversal of direction after five years of sustained fiscal consolidation.  There were a number of measures in the Budget (reductions in government price/fees/excises) which would have the effect of lowering the headline inflation rate for one year, but those weren’t really the focus of either the Reserve Bank or the financial markets.

Bond yields rose in response, and as market participants reflected a bit further the exchange rate fell.    It was that move, rather than the Budget itself, that prompted a reaction from the Reserve Bank.  Until the exchange rate fell, we had planned only a mild passing comment –  about the importance of ongoing fiscal discipline –  in the next Monetary Policy Statement.

At that time, we did not set an official interest rate (the OCR wasn’t a thing until 1999).  And the conventional view, not just at the Bank, was that exchange rate changes had a big short-term effect on domestic prices (whereas these days the short-term effects are roughly a 1 per cent change in the CPI for a 10 per cent change in the exchange rate, in those days empiricial estimates suggested anything up to a 4.6 per cent change in the CPI for a 10 per cent change in the exchange rate).  And so, roughly speaking, we ran policy with (unpublished) ranges in which the TWI could fluctuate, which were reset each quarter in light of the inflation outlook and changes in economic data.  If the exchange rate looked to move through the bottom of the range, we made a statement (‘open mouth operations’) and usually the statement itself was sufficient for interest rates and the exchange rate to adjust (the latter back into the range).

On Tuesday 31 July – thus a week after the Budget –  the exchange rate had fallen throught the bottom of our indicative range, and the Governor agreed to tighten monetary policy (it was a decision made a bit more easily than usual because all three of the more dovish senior officials were all away that week, but it was entirely in line with our standard operating framework).  We knew it wasn’t going to be popular – I noted in my diary that evening the question of whether it would spark a confrontation with the government – but the point of an operationally independent central bank was to be willing to be unpopular, especially in the run-up to elections.  There was a bit of a sense that it would not look good for the case for operational autonomy if we did nothing when first market doubts arose.  (Some years later David Caygill confirmed to me that the government had not expected any adverse reaction.)

We made an initial statement the following morning, which pushed interest rates up but didn’t do much to the exchange rate.  The statement was well-received by market economists (“who seemed surprised that we had the backbone – an NBR article this morning openly suggested that we want to back away”) and the Opposition finance people “who are impressed with the explicitness and clarity of the statement” (they had been criticising us for oblique communications), and even the media coverage wasn’t bad.  The Minister of Finance was not terribly supportive, but the Prime Minister was overseas.

On the following day, we were pondering whether we needed to make another statement –  to get the exchange rate back within the range.    Those with a particularly good memory may recall that this was also the day (2 August) Iraq invaded Kuwait, which pushed oil prices sharply upwards.  At the time –  although we weren’t knee-jerk reacting to oil prices –  our stance would have been that first round oil price effects were to be looked through, but that much higher oil prices would create risks of higher inflation expectations and a spillover into holding underlying or core inflation above target.

And so we made another statement the following morning.  For a time that day we thought we’d completely botched things because there were wire service reports that Iraq had gone on to invade Saudi Arabia too, but of course that was soon proved false.  Interest rates rose quite a bit, and the exchange rate also edged higher.  Banks began raising mortgage rates prompting the Minister of Finance to come out with rather silly comments (“presumably under Palmer’s orders”) about the banks being mean and out to get the government.  With the Prime Minister’s return both he and the Minister were out with further critical comments –  recall that they were less than three months out from an election thrashing .  The comments were aimed especially at the banks, while noting that there was nothing the government could do (monetary policy operational decisions having been handed to the Bank).

It wasn’t as if the Bank itself was totally blinkered and doctrinaire during this period.  In the days following this episode we discussed ourselves at senior levels whether we should consider recommending pushing back the target date (to, say, 1993) but on balance decided not to do so just yet.

That specific controversy died down pretty quickly, and to my mind remains an example of the system working as it was supposed to.  We were doing our job, and the government was doing its (setting fiscal policy, having initially set the inflation target itself).   I haven’t checked with Don Brash but I’ve never heard a suggestion that the framework, the target, or Don’s position was then in jeopardy.  In fact, a month or so later, Don was upsetting the Opposition by making himself somewhat party to the “Growth Agreement” the government and the unions reached –  in our terms, what that amount to was simply restating that if inflation pressures (this time wages) were lower then all else equal monetary policy would be able to be easier and interest rates (and the exchange rate) lower.

With the benefit of hindsight one can argue about whether the Bank’s monetary policy tightening was really necessary. In some respects, the market reaction post-Budget was a confidence shock and demand might have been expected to weaken anyway.  Moreover, actual exchange rate passthroughs were to prove weaker in future than had been the case in the past.   With better analysis might we have realised that sooner? Perhaps.  But as I noted, the Bank’s reaction was wholly consistent with the Policy Targets Agreement, signed only a few months earlier, and with our best understanding then of how the economy worked, in the midst of a highly contentious and uncertain disinflation, and was supported by the bulk of private market economists.

I’m not sure where Henry Cooke got his story, but it just wasn’t “chaos” then, and to the extent there was any, it wasn’t Bank-initiated.

In fact, that episode wasn’t even close to the toughest political challenges for the Bank.   Only a few months later, National was in power and Jim Bolger in particular was very unhappy with some of the choices the Bank was making.  Goldsmith records Ruth Richardson warning Brash, as she was about to leave for an overseas trip, not to “make waves” as his “best friend at court” wouldn’t be around to provide cover.  That angst went on for months, and even culminated in pressure on the Bank from senior Treasury officials to ease monetary policy specifically to assist Richardson’s own political position.  (I am less confident that we handled 1991 that well, even on the sort of information we should have used at the time).

And then, of course, a decade later there was Don Brash’s infamous Knowledge Wave conference speech –  given rather against the advice of various of his closer advisers – which, whatever its substantive merits, did involve stepping well outside his statutory role, and greatly irritated the then Prime Minister, in turn poisoning the prospects for any internal candidate succeeding Brash when he left for politics in 2002.

The point of this post is really twofold.  I quite like delving into the monetary policy history, much of which isn’t that well or readily accessibly documented.  But I was also keen to differentiate that episode from the current controversy around Orr.  In 1990 the government set the mandate –  and was free to change it at any time –  and we were simply doing our best to implement that mandate, in a climate of huge political and economic uncertainty.

By contrast, when Adrian Orr is proposing banning people from serving on the boards of bank parents and subs or –  much more radically –  proposes that he should more or less double how much capital locally-incorporated banks would need, he isn’t following some clear and specific mandate set by Parliament or the Minister, against which he can readily be held to account.  He is pursuing a personal whim.  His stated goal –  reducing the risks to the soundness of the financial system –  is certainly an authorised statutory goal, but there is no professional consensus on what level of risk is appropriate, or what policy steps might deliver that level of risks, or what costs might be imposed in the transition or the steady-state.  And there are no effective rights of appeal, no override powers, to his one-man exercise of his personal preferences.     That simply isn’t appropriate.  With superlative supporting analysis, and a long and open period of real consultation –  before the Governor nailed his colours to the mast, as prosecutor in the case he himself will judge –  it might be one thing (still not ideal).  What we’ve actually had in the past year falls far short of that sort of standard.  It is a much more serious situation –  including because there are no self-correcting mechanisms (eg inflation falling below target, telling the Bank it has things a bit tight –  than a one-week flurry around a modest monetary policy adjustment implemented in pursuit of a goal the government itself had explicitly set.

The Minister of Finance and the Board do not have formal override powers.  But they could, and should, be using the leverage they have to insist on a much more compelling case being made for any actual policy adjustment (and not for that case to be published only after the decision itself has been made).  Cooke’s article quoted a submission suggesting annual GDP costs of up to $1.8 billion a year, but the Governor’s own deputy has quite openly suggested that the policy will cost the economy $750 million a year.  For gains –  in a sound and well-managed banking system – that are far from evident, in an economy where tightening credit conditions, even just in a transition, are about the last thing that is needed.

 

Orr on bank capital

I’ll no doubt have more to say about Radio New Zealand’s Insight documentary on the Reserve Bank Governor’s proposed bank capital reforms after the full programme has run, but Morning Report this morning ran a fairly lengthy piece on the issue, including meaty quotes from the Governor (and some from me and from the former Secretary to the Treasury, Graham Scott, who was involved in the Bankers’ Association submissions on the Governor’s “proposal”).  Even what I heard of that RNZ story was pretty extraordinary in several areas.

First, as if to confirm that the “proposal” wasn’t a serious consultation, the Governor confirmed that capital requirements will be rising, no question about that.  Perhaps he is genuine that he hasn’t quite decided whether he thinks his own proposal is perfect in all its details –  I was pleased RNZ got in my line that he is prosecutor, judge and jury in his own case, with no effective right of appeal – but there was little sign he is interested in alternative perspectives, arguments, or evidence.  And thus remains true to form.

Perhaps more extraordinary –  given his specific statutory role, not a constraint that ever seems to bother him –  was the assertion that Australian banks make “too much money” in New Zealand.  I suppose as a citizen he is entitled to his prejudice, but as Governor of the Reserve Bank how much private businesses make is really none of his business. His job is prudential regulator –  ie safety and soundness of the system –  not about competition, rates of return or the like.  We have, or could have, competition law and associated institutions to deal with those issues.  For all the Governor’s talk about super-profits, if it were really true you’d have to wonder why bank assets in New Zealand weren’t growing very rapidly, and new entrants flocking in, credit abundant to anyone who asks, to take advantage of this extraordinarily profitable corner of the world.  And in feeding the angst in some circles about Australian bank profits, perhaps he might point out that if his proposals are adopted it is likely that total profits earned by Australian banks in New Zealand will rise, not fall (rates of return are likely to fall a bit, but there will be a lot more capital in the banks –  unless the Governor’s proposal really backfires).

On which note, it was extraordinary to hear the Governor suggest that if the Australian banks didn’t like his new regime, well they could just take their money and go elsewhere.  He wasn’t going to be bothered.   This about banks that in some cases have been here, steadily, almost as long as modern New Zealand has.   This from as Governor whose own consultation document never seriously discussed transitions or adjustment paths (in aggregate or specific sectors) to his proposed much higher capital ratios.  The Bank has all year tended to be pretty dismissive of any suggestions that the availability of credit might be adversely affected, and they’ve still provided no supporting analysis.  Nine months ago when they launched the Governor’s radical scheme, they thought the economy didn’t look too bad.  Since then they’ve had to cut the OCR by 75 points, with more cuts to come (on almost everyone’s reckoning) even before allowing for any effects of these capital proposals.  Perhaps then a rash Governor could afford to be cavalier about bank capital, but it borders on the outright irresponsible for him to take that stance now –  with so little conventional monetary policy leeway left, in a world looking more difficult almost by the day.   Reduced credit availability, to the extent it happens, will only exacerbate any downturn, and the effects are likely to be concentrated in those sectors least readily able to tap alternative credit (hint: not big corporates, not household mortgages, but eg farms and small businesses). But, of course, thanks to the government’s indifference there are no effective checks and balances on the Governor following his whim, in some sort of Orr-tarchy.

And finally on this topic for today, there was the line the Governor ran about how he had to do this to end the practice of the public subsidising banks.  He went on to suggest that we forget too easily all the banking failures and near-misses.  But with no a shred of evidence –  in any of his documents –  to support any of this.  The New Zealand banking system has gone for 125 years without any serious crisis, except for the one 30 years when the ensnaring complex of extensive regulation was pulled away quickly and neither banks, borrowers, nor central bankers really knew what they were doing. The Australian banking system is the same.  The Canadian banking system even more so.   The Governor’s own stress tests have repeatedly supported the view – taken by the Bank over many years, supported by the IMF –  that the New Zealand banking system is strong and well-capitalised.  The Governor likes to play on 2008, muddying the water with talk of near-crises here: he should know very well that there were no major credit losses here, and the (real) liquidity issues were global in nature, and would not have been one jot different if banks had had twice the (then untroubling) level of capital they had.

It is a worry that so much power is held by one individual.   It should be concerning even if we had the most thoughtful, considered, consultative, and judicious person in the role.  In fact, we have Adrian Orr, to whom none of those descriptions can reasonably be applied.   And there seems to be a vacuum where there should be a government taking leadership responsibility (in fact, one can imagine Shane Jones –  “consulting the Cabinet Manual” on his holiday –  cheering Orr on).

 

A strikingly poor speech from the Governor

On Wednesday afternoon the Reserve Bank Monetary Policy Committee released their latest OCR decision.  It was, as predicted, no change in the OCR.  I don’t think it was the right decision on the substance (some background to that here) but at least it was in line with the Governor’s public comments following the previous surprise decision.

I didn’t have that much to say about the two pages (statement plus “minutes”) they released.  So just a few quick points:

  • in the statement the Bank continues to overstate the contribution of the “trade war” to the slowdown in global trade and global growth.  It is a convenient “newspaper headlines” story, but the way they use it suggests they haven’t thought much more deeply about the issues,
  • they talk up the prospects of economic recovery, based on the reduction in interest rates, but never seem to recognise that interest rates had been cut for a reason.  Unless the OCR is cut by more than any fall-away in economic fundamentals, you wouldn’t expect to see a rebound.  As I pointed out last week, actual cuts in variable retail rates lag well behind the fall in market-determined long-term rates,
  • there is something inappropriate about the Bank talking up the idea of fiscal stimulus three times in two pages (not that fiscal stimulus might be out of place in some circumstances, but it is entirely a matter for the elected government).  On the other hand, I guess we should be grateful that the Governor has stepped away from his August comment that “of course the government has to be spending more”.
  • it is interesting that, at least as written, the MPC appears not to have any bias on the direction of the next move in the OCR.   They are very widely expected to cut in November and cut again next year but there is nothing in this statement to lead one to think the MPC shares that view –  if anything, in the minutes we read that “some members”, with a cost-plus model of inflation apparently, believe there is “potential for rising labour and import costs to pass through to inflation more substantially over the medium-term”.   Their predecessors were hawking similar lines in 2015/16.

It is 18 months today since Adrian Orr took office at Governor of the Reserve Bank.  I’ve not infrequently bemoaned the fact that in that time Orr has not given a single substantive on-the-record speech on monetary policy or banking regulation/financial stability (the Bank’s two main areas of responsibility).  Yesterday Orr gave short speech to a corporate audience in Auckland, which dealt with both monetary policy and (in more abbreviated form) banking regulation.  I guess we should be thankful for small mercies.

Sadly, the contents of the speech suggest we have a Governor who simply makes stuff up whenever it suits him.  It is extraordinary in such a powerful public figure, one supposedly operating as an independent and judicious technical expert.  Much of it comes across as almost delusional –  perhaps welcome to his mates in the Beehive, but even they must sometimes wonder whether independent public institutions aren’t meant to be more than cheerleaders.

To take just a few examples of what I have in mind, start here

The good news for New Zealand, unlike many other OECD economies, is that our government’s books are in good shape and there is already a strong fiscal impulse underway from public spending and investment. 

There is no disputing the first half of the sentence.  It is to the credit of successive governments of both parties that government debt has been kept pretty low and stable over recent decades.  But what about that second claim, about the “strong fiscal impulse”?  Well, it simply isn’t supported by the facts at all.    This is from my post on last month’s Monetary Policy Statement when the Governor tried to run the same sort of line.

In fact, it prompted the perfectly reasonable question from Bernard Hickey about whether fiscal policy was actually very stimulatory at all.   The standard reference here is The Treasury’s fiscal impulse measure.  This is the chart from the Budget documents

fisc impulse.png

It isn’t a perfect measure by any means, and in particular one can argue about some of the historical numbers. In my experience, it is a pretty useful encapsulation of the fiscal impulse (boost to demand) for the forecast period. In fact, the measure was originally developed for the Reserve Bank –  which wanted to know how best to translate published forecast plans into estimated effects on domestic demand/activity.

And what do we see.  There was a moderately significant fiscal impulse in the year to June 2019.  That year ended six weeks ago.  For current and next June years, the net fiscal impulse is about zero, and beyond that –  which doesn’t mean much at this stage –  the impulse is moderately negative.    All using the government’s own budget numbers.  And consistent with this, operating revenue in 2023 is projected to be higher as a share of GDP than it is now, and operating expenses are projected to be lower (share of GDP) than they are now.    The Budget is projected to be in (fairly modest) surplus throughout.

And yet challenged on this, the Governor seemed to be just making things up when he claimed that we had a “very pro-active fiscal authority” and that “the foot is on the fiscal accelerator”.    It just isn’t.  Orr must know that (after all, he had Treasury’s Deputy Secretary for macro sitting as an observer in this MPS round).  One even felt a little sorry for the Bank’s chief economist spluttering to try to square the circle, but basically acknowledging that Hickey’s story was right, not the Governor’s.   Perhaps, you might wonder, the Bank thinks the fiscal impulse measure is materially misleading and has its own alternative analysis of the government’s announced fiscal plans. But that can’t be so either: there is no discussion of the issue in the Monetary Policy Statement.

(Incidentally, on Morning Report this morning Grant Robertson tried the same sort of line, only for the presenter to point out to him the fiscal impulse measure, reducing the Minister to spluttering “but we are spending more than the last lot”.  That is true, but the material overall fiscal boost was last year –  and growth and activity were insipid even then, inflation still undershooting the target.)

Was he being deliberately dishonest or simply making stuff up as he went protraying things as he’d like them to be?  You can be the judge, but neither alternative puts our central bank Governor in a good light.

Given that he has since had another 7 weeks to get his lines straight and yet repeats the same line, it looks even worse for him now.  As I said last month, if the Bank has an alternative take on the demand implications of fiscal policy it surely behooves them to lay it out for scrutiny, not just make idle claims inconsistent with their longstanding standard reference source the Treasury estimates).

Just as preposterous was this claim from the Governor

The low level of interest rates globally over recent years primarily reflects low and stable inflation rates – a deliberate and desired outcome of monetary policy.

Here the Governor was repeating much the same nonsense it is reported that he ran to Parliament last month

Over the weekend, I came across an account of the Governor’s appearance on Thursday before Parliament’s Finance and Expenditure Committee to talk about the Monetary Policy Statement and the interest rate decision. …. The Governor was reported as suggesting although neutral interest rates had dropped to a very low level, that MPs should be not too concerned as we are now simply back to the levels seen prior to the decades of high inflation in the 1970s and 1980s.

I’m not going to repeat the entire post I devoted to illustrating just how unusual global (and New Zealand) interest rates now are, both in nominal terms and (even more so in the long sweep of history) on real terms.  In centuries past there was little or no rational expectation of sustained inflation, while these days everyone agrees that medium to long-term inflation expectations are somewhere between 1 and 2 per cent.  The Governor may also have forgotten, in a New Zealand context, that the inflation target here is now materially higher than it was, say, 25 years ago.   Interest rates are, of course, far lower.  Here is just one chart from the earlier post, showing how unusual global interest rates were even five years ago (things are still more anomalous now, especially here).

As a final chart for now, here is another one from the old Goldman Sachs research note

GS short rates

In this chart, the authors aggregated data on 20 countries.  Through all the ups and downs of the 19th century and the first half of the 20th century –  when expected inflation mostly wasn’t a thing –  nominal interest rates across this wide range of countries averaged well above what we experience in almost every advanced country now.

Why does the Governor say this stuff?  Does he have no advisers left who are willing to tell him that what he says just isn’t so?

There are claims that the domestic economy still has “ongoing momentum” and that there is “strong demand for goods and services”.  These claims appear to be based the Governor’s interpretation of comments from the small group of firms the Bank went and visited recently.  Never mind the economywide measures, whether the range of business confidence and activity measures, or…..well, the national accounts.

pc GDP growth.png

He goes on repeatedly about how interest rates make it a great time to invest, as if he’d not given a thought to possible reasons why interest rates might be low (NB, it isn’t just because inflation came down again, see above).  He claims we have a “great environment to invest”, talks of “low hurdle rates for investing”, but seems not to recognise that in a climate of uncertainty, whether around policy (here or abroad) or the economic outlook, the option of simply waiting has considerable value, or thus that there is little reason to suppose that hurdle rates for investing have dropped much, if at all, in more recent times.

As a bureaucrat Orr is apparently convinced it is a great opportunity to invest and that profitable investment opportunities abound.  Experience suggests that people with a bottom line to meet disagree with him.  Here is the Bank’s own chart from the most recent MPS showing business investment as a share of GDP, with a few observations from me.

bus investment RB.png

As I’ve noted here repeatedly, business investment never recovered strongly from the last recession, and if anything (as share of GDP) has been falling back again in the last few years, even as population growth remained strong.

But despite the feeble business investment performance, the Bank expects business investment to recover from here.  There is no hint as to why they believe that is likely…. If there is any basis for their beliefs it seems to be little more than the repeated claim by the Governor and the Minister that it is “a great time to invest” in New Zealand.  But firms didn’t think so over the last five years –  even with unexpected population shocks –  and surely the reason the Bank is cutting the OCR has quite a bit to do with deteriorating conditions and investment prospects here and abroad?

But what do firms know?

Orr seems to more or less acknowledge the uncertainty issue, in these strange sentences, tinged with corporatist sentiments

However, there remains a loud call from all quarters of the country for leaders to better signal investment intent, and ensure we have the policy and goodwill to facilitate access to capital and resources to execute.

This call for investment-intent is to all collectively-owned (e.g., Iwi), Crown-owned (i.e., central and local government), and co-operatively owned (e.g., traditional primary sector) sectors. It is not just to traditional businesses, or any one party.

Easily said, harder to do without a clear desire to work together over an agreed horizon.

Or he could just have mentioned the major policy uncertainties.    Whatever your view on the merits of any of these issues (and I’m steering clear of expressing such views) mightn’t you think that uncertainty around the ETS, water quality policy, highly productive lands policy, the future of the RMA itself, whether any more significant roads will be built by a government apparently averse to them, bank capital regimes, the future of extractive industries might all be among the sorts of factors that might leave businesses and potential investors just a little wary, and pricing that uncertainty into their decisions around investment?

It all comes to a climax in this extraordinary claim in the Governor’s final paragraph (emphasis added).

In summary, we are not alone in the low interest rate environment, this is a global phenomenon. However, what we do have is more policy and business opportunities than most OECD economies and this is something that we need to take advantage of.

If by that he means that New Zealand productivity and per capita income rank far behind most of the OECD countries we used to like to compare ourselves to and that, at least in principle, those gaps could be closed, then I’m right with him.  But absolutely nothing about how policy has been run by successive governments for at least 25 years now has (so it appears from the evidence of hindsight) been consistent with closing those gaps: the productivity gaps in particular have just kept on widening and (though you would never know it from the Governor’s speech) we’ve had little or no productivity growth at all for the last five or more years.  Nothing about current policy suggests that record will improve in the next five years, and if anything one could mount a plausible argument that the measures adopted by the current government are heightening the risk of even worse (relative performance outcomes) in the next five.   Not only is this stuff well outside the Governor’s area of responsibility –  which is about macro and financial stabilisation –  but he either just doesn’t know what he is talking up or knowing better he just mouths such platitudes anyway.

Finally, there are several paragraphs in the speech about the Governor’s proposals to hugely increase the amount of capital locally-incorporated banks will need to have to back current balance sheets.    Notionally, there is process of consultation and deliberation going on at present. But when you read from the sole decisionmaker words like these,

Our proposals would see significant increases in shareholder capital in banks. With banks having more of their own ‘skin in the game’, the owners will sharpen their long-term customer focus, and it will reduce the chance of a bank failure and the cost on society as a whole should a bank fail. These outcomes are highly desirable for the long-term economic health of New Zealand, and should promote deeper and more liquid local equity and debt markets.

We finalise our decisions in early-December this year. Whatever our final decisions, we will be insisting on transition to higher capital at a sensible pace.

with all those “will”s, you get a pretty strong sense of pre-judgement.  That is, of course, what you’d expect when those proposals were based on very weak analysis –  numbers plucked out of the air at the last minute –  and when the Governor is prosecutor, judge, and jury in his own case, and where he knows that there are no effective appeal rights against his verdict as unelected unaccountable decisionmaker.

It really isn’t good enough.  Citizens should expect better.  The Bank’s Board is paid to hold the Governor to account, but they are almost worse than useless (they provide shadow without substance, suggesting there is scrutiny and accountability when there isn’t).  If the Minister of Finance were doing his job, or Parliament’s Finance and Expenditure Committee was doing its job, some pretty hard questions would be being asked about just what is going wrong at the Bank, and how such shallow –  and frankly embarrassing –  material is emerging from the mouth of such a powerful public figure.

Instead, no doubt, things will continue to drift, and the slow decline of New Zealand’s economic institutions –  hand in hand with the continuing decline in New Zealand’s relative economic performance – will continue.

But, you businesses out there really should be investing. This Governor tells you so.

 

 

 

A new BIS paper that undermines the Reserve Bank’s case

At the end of my long post yesterday on the Reserve Bank’s latest efforts to spin the Governor’s plans to increase very markedly minimum capital ratios for locally-incorporated banks, I noted

PS.  As Martien Lubberink at Victoria has pointed out there is another international agency paper out just recently that really doesn’t help the Bank’s case much if at all. I might touch on that tomorrow.

His post is here (complete with the sly –  if obscure, presumably deliberately so –  dig at the Governor in the final paragraph).

The paper he was referring was recently published by the Bank for International Settlements as a Working Paper of the Basel Committee on Banking Supervision, with the title “The costs and benefits of bank capital – a review of the literature”.   The paper was released only a couple of weeks ago, and it should be studied carefully by anyone interested in the issues here in New Zealand, including (one hopes) the Reserve Bank.

The paper begins

In 2010, the Basel Committee on Banking Supervision published an assessment of the long-term economic impact (LEI) of stronger capital and liquidity requirements (BCBS (2010)). This paper considers this assessment in light of estimates from later studies of the macroeconomic benefits and costs of higher capital requirements.

That earlier paper is referenced everywhere the issues are discussed, including in the Reserve Bank’s papers earlier in the decade, and in its consultative document for this review.   It supported –  to some extent made –  the (macro) case for higher capital ratios, in particular higher than had been in place up to that point (shortly after the crisis).  A review and update of the issues, by a group involving officials from the BIS, the Bank of England, the Banque de France, the Fed and Comptroller of Currency (among others) has to be taken seriously, including when the authors highlight the limitations of their own work, and outline areas needing further research.   The paper looks at many of the same studies the Reserve Bank cites but –  in Lubberink’s words –

The conclusions of the Basel Committee study, however, are different. They are much more modest than the findings of the RBNZ.

Before going on, I should say that I have serious problems with elements of the approach taken in the earlier and more recent BCBS papers (various points outlined at greater length in my own submission).   In particular, this work (and the Reserve Bank) treats all output losses in recessions associated with financial crises as being attributable to the financial crisis (bank failures etc) itself.  That is almost certainly wrong, and substantially overestimates the cost of crises themselves –  the loan losses that lead to bank failures arise from misallocations of investment resources (and/or overheated economies) and those misallocations will be corrected anyway (with likely output costs), whether or not any bank fails.   Remarkably –  and this is clearer in the more recent paper –  they also treat output losses in countries that didn’t have domestic financial crises (think Australia or Canada in 2008/09) as costs of financial crises, rather than allowing for the more plausible story that common third factors will have been driving, say, productivity growth slowdowns across the advanced world.  As I’ve argued (and as Cline, in a PIIE paper a few years ago, also made the case), if you want to isolate the output costs of financial crises, a better way is to look at the differential growth performance between (otherwise similar) countries that did and did not experience domestic financial crises.

A great deal turns –  in these sorts of modelling exercises – on how costly the modellers assume crises will be.  Both my points in the previous paragraph suggest the BCBS conclusions –  as to how much capital is likely to be warranted –  are likely to materially overstate the “true” numbers.

There are all sorts of other limitations to the BCBS work. For example, it focuses on “banks”, but doesn’t address the fact that for an individual country – think New Zealand –  a capital requirement on locally-incorporated banks won’t affect branches of foreign banks operating locally, or non-bank lenders.  Disintermediaton costs don’t figure.  It also, more generally, won’t apply to debt capital market funding.   Unlike the Reserve Bank, the BCBS paper does touch on the issue of alternative resolution mechanisms –  the Bank long favoured the OBR approach, but it was never mentioned in the consultative document, even though the more confident you are of OBR (I’m not, but they were) the less capital is required –  but it doesn’t touch on the issue of a banking system in which the large banks all have strong foreign parents.  And it doesn’t take account – in the macro calculations – of the possible income losses to New Zealanders from the higher equity returns to foreign shareholders (much of the overseas modelling seems assume redistribution of income within the country).  This latter point, in particular, has been covered in Ian Harrison’s papers.

On my reading, this is the bottom line chart in the BCBS paper.

bcbs chart.png

They report the net marginal economic benefit (slightly lower GDP each year, offset against savings from a less serious crisis decades hence) from higher bank capital ratios, drawn from a series of studies.    On these models there were really big gains in lifting capital ratios, up to around to around 9-10 per cent.  If there are gains at all –  and they don’t report margins of error around these estimates –  they are looking extremely small beyond about 13 per cent.    Perhaps that doesn’t sound too far from the 16 per cent number the Reserve Bank is proposing for the big banks but (among other limitations, many made inevitable by data limitations):

  • this modelling is done on actual capital ratios, not regulatory minima (a 16 per cent minimum ratio is likely to see banks aim for something between 17 and 18 per cent actual ratio), and
  • none of this modelling takes account of differences in accounting and regulatory treatment across countries: conventional wisdom, (backed by estimates done by PWC) suggest that effective capital ratios in New Zealand (and Australia) would be far higher if things were measured the same way they were done in various other advanced countries, and
  • none of it takes account of the regulatory floor in how risk-weighted assets are calculated.  As the Bank is quite open about, a significant part of what is proposing is that in calculating risk-weighted assets, the big banks will have a floor of 90 per cent of what the standardised rules would generate (the more normal floor is, as I understand it, about 72 per cent).  A 17.5 per cent headline actual capital ratio would, on RB proposed rules, be akin to something like 20 per cent in the sort of framework the BCBS authors are looking at.

Nothing in this paper suggests any reason for confidence that effective capital ratios of, say, 20 per cent of risk-weighted assets would be generating net economic benefits, even on the (overly pessimistic) macro assumptions the authors are using.  But that is what the Reserve Bank claims to believe.  The onus, surely, is on them to show us, and to engage on their assumptions and analysis – in open dialogue – well before decisions are made.

And then lets go back to the macroeconomic inputs.    If most of the costs of recessions associated with financial crises would have happened anyway (see above) then the output losses used in these models are substantially overstated.   Higher capital ratios make no difference to whether those losses occur.  Cline (the lower blue line in the chart) uses assumptions more similar to mine: you can see where the crossover point (to net costs) is for him.

Note too that real interest rates and the real cost of capital are higher in New Zealand than in most advanced countries.  The median (real) discount rate used in the studies the BCBS paper looks at is something like 3.5 per cent and none uses a real rate higher than 5 per cent.  A standard New Zealand Treasury guidance for cost-benefit analyses on regulatory proposals is (real) 6 per cent.  Using a higher discount rate materially reduces any benefits from a crisis assumed to arise, probabilistically, decades in the future.   And yet even on the studies reviewed by the BCBS, there is no consensus in favour of anything near as high as the effective capital ratios the Governor is proposing.

And, as I’ve pointed out previously, all this work implicitly assumes that any higher capital ratios can be made binding for decades to come.  Since there is no pre-commitment technology, and actual rules have been changed every few years, there should be a further discounting of any potential gains, particularly in light of the inevitable transition costs from big increases in capital requirements (which are frontloaded, and represents permanent losses, for what may be a temporary policy).

It was also interesting to be reminded, in an annex, of this feature of the earlier (LEI) BCBS modelling

The main results of the LEI appear in Table 8, p 29, of BCBS (2010).  The calibration used is the following:

• the probability of a crisis is 4.6% for a capital ratio of 7%, and declines at a diminishing rate to 0.3% for a capital ratio of 15%.

In other words, a probability of a crisis every 333 years with an (actual) capital ratio –  calculated as more conventionally abroad –  of 15 per cent.  And yet the Reserve Bank’s proposals were supposed to be calibrated to a crisis every 200 years, and yet still somehow generate effective capital ratios of 18 per cent plus for the big banks.

Now in many respects Martien Lubberink’s comment is fair, that for all sorts of reasons

studies on bank capital are more quicksand than a sound foundation for policy recommendations.

And yet, they have been repeatedly invoked by the Reserve Bank, and –  when read carefully – do still provide a commonsense test against which the benchmark the Governor’s ill-considered far-reaching proposals for New Zealand.

The whole exercise really should be suspended.  Come back to it perhaps in a few years’ time when a revised Reserve Bank Act is in place, and when there has been proper parliamentary and public scrutiny of the assignment of powers to the Reserve Bank (which policymaking powers should rest with ministers and which with agencies).  And use the intervening period to undertake some serious local research, working collaboratively with APRA (recognising the common risks, common ownership, likely common resolution) and engaging in workshops and seminars to tests the strengths and weaknesses of staff thinking and research well before decisionmaking authorities reach a provisional view.

And, in meantime, take comfort from the fact that before the IMF suddenly swung in behind the Governor, when there were no institutional pressures at play that international agency only a year ago told us, and told the world, that there were ample capital buffers in the New Zealand banking system.

IMF capital

The risks haven’t changed materially in that time, it is just that the gubernatorial whim has since been revealed.  Such whims are a terrible basis for making serious policy, especially when there are no checks, no appeals, on the Governor’s ability to impose such substantial transitional and ongoing costs on New Zealanders.

 

 

,

Reserve Bank still spinning

Earlier this week, the Reserve Bank published (almost all of) the submissions it received on the Governor’s proposal to increase very markedly the share of bank balance sheets that need to be funded by equity.

Welcome as it is to have the submissions –  it is easy to forget that not four years ago the Reserve Bank was still reluctant to publish any submissions it received at all (even though it was the norm for government agencies, parliamentary select committees, and so on) –  the Governor sought to use the occasion for some more spin in support of his proposal (on which he alone will, a few months from now, make the final decisions –  the rest of us, whether Minister of Finance, banks, businesses or citizens will simply be stuck with the results of his whim, with no mechanisms for appeal or review.)

Instead of just releasing the submissions –  which could have been done weeks ago, very shortly after submissions closed –  the Bank chose to release a 22 page document labelled “Summary of Submissions” and a lengthy and argumentative press release in the name of the Deputy Governor.

I haven’t read all the submissions, or even looked at them all, but one reader –  distracting himself from other stuff he should have been doing –  did look at them all, and sent me a spreadsheet with the names of the submitters, the length of each submissions, and broad tenor of any comments.

A good consultative process draws out perspectives or comments or evidence that the consulting agency may not have thought of, may have chosen to ignore, may have interpreted differently, may have missed the point of, or whatever.  Having received that material, the consulting agency would carefully consider those perspectives, (in principle) looking to make the best decision, open to a revised perspective.   Of course, that sort of openness is rare –  it runs against human nature, particularly where the people making the final decision are the people who proposed the scheme in the first place.

And a consultative process shouldn’t be thought of, or presented as akin to, a public opinion poll.   If one wanted to make such decisions by public opinion poll then I guess (a) we wouldn’t delegate them to a specialised agency, and (b) we would commission a properly structured poll.   Apart from anything else, (a) people who are opposed to what is proposed are typically more likely to submit than those in favour, and (on the other hand) (b) especially when the numbers involved are small, it is easy for a handful of low-information submissions to be generated on either side of the issue.

The Reserve Bank, however, has tended to present the submissions as something of an opinion poll.     There was the silly line that “in general, submitters support the Reserve Bank’s objective to ensure that New Zealand’s financial system is safe” –  yes, and we support motherhood and apple pie too.  The issue isn’t whether the system should be “safe”, but how safe, and at what cost, on what assumptions.  And then

There was significant and wide-ranging media and public interest in the How much capital is enough? (PDF 545 KB) paper, with written feedback from 161 submitters.

Yes, 161 submitters is a lot more than the nine submissions they received on the previous paper in the longrunning capital review  but in the grand scheme of things –  considering the scale of the changes the Bank is proposing – it isn’t many.   And more than 20 per cent of the submissions turned out to be six lines or less: whether the submitter was for or against what the Governor was proposing (and in some cases it really isn’t clear) there is no useful information for a proper consultative process in submissions that short (unless perhaps one of the big banks had submitted “Dear Adrian, We agree.  Do start soon.”, which they didn’t).

Thus, when the Deputy Governor says

Many submitters, particularly from the general public, support the proposed higher capital requirements for banks.

He is correct.  Many did.  Very briefly.  Usually without much engagement in the argumentation and issue (although one of the Governor’s mates did write in to offer support and some argumentation, although strangely even he referred to some evidence that capital ratios should be 13-14 per cent, which led him to the view that the Bank’s proposed (minimum) ratio of 16 per cent was “acceptable”.)

And look at this attempt to play the populist card – the public versus the banks – a bit further

Some submitters, in particular banks and business groups, question whether the proposed increases are too large and too costly.

As they know very well, there were a variety of other serious –  more than half a dozen lines long – submissions from people with no vested interests who were very sceptical of the Bank’s proposal, and of the argumentation and evidence in support of it.

You also have to wonder how well the Bank would be able to defend a claim (perhaps in a judicial review) that the consultative process was a sham.  The Deputy Governor again

Increasing the amount and quality of capital can be reasonably expected to mean that banks can survive all but the most exceptional shocks, Mr Bascand says. “We think the costs of doing so are outweighed by the benefits – someone’s cost is for society’s broader benefit.”

(do note the attempt to play vested interests again: “someone’s cost”).  Isn’t it still months until the final decision is supposed to be made?  And yet the Deputy Governor can confidently declare not just ‘in putting out the consultative document we thought it likely benefits would exceed costs”, but (present tense) “we think the costs…are outweighed by the benefits”.  And if the Deputy Governor already knows perhaps he could release that cost-benefit analysis that so many submitters and other commentators have been calling for.  I guess they haven’t yet back-fitted the numbers to suit the Governor’s conclusion yet.

Continuing with the spin, the Deputy Governor moved on to invoke support from the International Monetary Fund and the OECD, both of whom released comments on the New Zealand economy last week.

Following its recent mission to New Zealand, the International Monetary Fund has released a Concluding Statement that highlights the need for strengthening bank capital levels and that the proposals appear commensurate with the systemic financial risks facing New Zealand. The Organisation for Economic Co-operation and Development’s latest Economic Survey of New Zealand expects increases in capital will likely have net benefits for New Zealand.

It is hard to make much of the IMF comments at this stage.  They are not much more than a couple of sentences in a press release, with no published supporting analysis.  And the Fund almost always backs the authorities – who are the people they talk to most  –  especially when central banks and regulators want to put more restrictions on banks. Why wouldn’t they?  Any economic costs don’t sheet home to them.  But the IMF’s support isn’t without its problem for the Reserve Bank.     Here is what they said

The new requirements would increase bank capital to levels that are commensurate with the systemic financial risks emanating from the dominance of the four large banks with similar concentrated exposure to mortgages, business models and funding structures.

Which, by logical deduction, appears to be saying that current levels of capital are grossly inadequate to the risks the New Zealand banking system faces. But there was no hint of these serious risks in past Financial Stability Report from the Reserve Bank (although they amped up the rhetoric in the latest one), and –  perhaps more to the point –  no hint of that in past IMF Article IV staff reviews or Executive Board discussions.  This snippet is from last year’s Article IV report, published as recently as June last year.

IMF capital

Not a word from staff, from the Board –  or, indeed, fron the New Zealand authorities in their published comments –  of a pressing need for a huge increase in minimum capital ratios.

The Deputy Governor also attempts to deploy the OECD in support.  They typically aren’t particularly expert in such matters, but here is what they actually said:

The Reserve Bank has proposed large hikes in bank capital requirements. High bank capital requirements reduce the cost from financial crises, but might also dampen economic activity through higher lending rates. On balance and nothwithstanding considerable uncertainty, increases in bank capital are likely to have net benefits, but the impacts should be carefully monitored.

Take it from me – I negotiated line by line wording on numerous OECD reports –  that is about as tepid as it gets.  It doesn’t even endorse the huge increases in minimum capital the Governor is proposing –  the comment is simply about “increases”, and there is a long way from current levels to what the Governor has planned.

And if you doubt my take on the OECD, here is their own slide from the presentation when they released the report in Wellington last week.

OECD capital.png

And these comparisons are just of headline required ratios (triangles are actuals I presume), while part of the Reserve Bank proposal is to materially increase the calculation of risk-weighted assets for the big 4 banks, to an extent that would, in effect, add another three percentage points or so to those New Zealand numbers, which already –  in the OECD’s words – “exceed those in other OECD countries”.

So, spin all the way down.    Complete with the observation about their continuing consultation –  fishing around to find some supporters perhaps

It is continuing its stakeholder outreach programme, which includes conducting focus groups to understand the public’s risk appetite, and engagement with iwi, social sector and industry groups, financial institutions and investors. It has also engaged three external experts for an independent review of its proposals.

They elaborate a little in the document that supposedly summarises the submissions.  On the iwi point “a workshop with Maori service providers” –  but why, what specific issues might there be for “Maori service providers” (whatever they are) from any others –  Catholic, Pacific, or whatever?   And the workshop they plan with “social service providers and NGOs” really looks like an attempt to drum up support for the shonky “social costs of crises” material they’ve run previously, and which Ian Harrison (in particular) has comprehensively demolished.  I will be lodging an Official Information Act request for the reports etc from any focus groups –  again it looks a lot like an attempt at distraction, a populist Governor trying to summon a mandate from “the people”, rather than from Parliament.

Also from that Summary of Submissions, this attempt to spin the issue (wasn’t this supposed to be a summary of submitters’ view and analysis?)

It’s about keeping New Zealanders, their investments, and the economy safe from the disastrous impacts of financial instability and the failure of a registered bank, which historical evidence suggests can be very long-lasting and go beyond just the financial costs for people.

Loaded language (and not even particularly well written).  Nothing like a bogeyman to scare people with I suppose, but surely only fairly geeky people even read a document like this.  Who is the Governor hoping to impress?  Not much sign of calm, balanced, detached and objective consideration, that’s for sure.

(Having said that, it was noticeable reading through the Summary itself how few arguments staff managed to find from the submissions in support of what the Governor was proposing.)

The other person who has weighed in this week is the Minister of Finance, with a rather plaintive appeal to everyone to get on and talk nicely, as if he was a harried parent pleading with children to just play nicely (“pleeeeeeease”) at the end of a long tiring day.   The Minister is reported to have called for a “mature debate”, observing

“I want to remind all parties that we are still in a consultation process. I am calling on all interested participants to listen to and work with each other constructively as this work is carried out.”

It wasn’t exactly authoritative.

Perhaps he might address his concerns specifically to the Governor, including via the Acting Secretary to the Treasury and the Bank’s Board (whose job to work for the Minister and the public to monitor and hold to account the Governor).   And perhaps he needs to wake up to the power asymmetries here: we have a single unelected official (largely appointed by some other unelected board members, all appointed by the previous government), championing huge increases in minimum capital requirements, having made no effort to socialise thinking or test reasoning before settling on a view, and is now judge and jury in a case he himself is prosecuting.  And the “defendants” –  not just banks, but the wider economy –  have no rights of appeal.  And the way the Governor has conducted himself –  dismissive of sceptical comments, strong elements of pre-meditation, no cost-benefit analysis, no serious analysis of the transition, no serious engagement with the Bank’s preferred resolutiuon tool (the OBR), “independent” experts handpicked by him to review the proposal (but barred from talking to anyone else without his permission) and so on –  doesn’t exactly inspire confidence.  He talks a lot about “making banks safer”, but all independent analysis  –  and their history –  suggests the banks are fairly safe already: we could reduce lots of risks in society to near-zero (the road toll for example) but the costs just aren’t worth it. He simply hasn’t made the case that this proposal –  which he cannot commit would even endure beyond his governorship – is worth the risks and costs.

The Minister of Finance does not have formal powers to stop the Reserve Bank.  It is right and proper that the Minister should not be able to interfere with supervisory decisions or judgements involving individual institutions, but what is going on here is probably the largest policy initiative (bigger than, eg, outsourcing/local incorporation) around bank regulation in many decades.  Big policy calls –  in areas where there is huge uncertainty (as the OECD, among others, says there is here) – really should be a matter for politicians.  At very least, they shouldn’t be a call for a one-man band with a bee in his bonnet (and without even any particular specialist technical expertise).

If the Minister really wanted to display some leadership he would call in the Governor (in consultation with the Secretary to the Treasury) and strongly urge that the entire review be put on hold.   There are several and sufficient reasons to do so:

  • the government has made provisional decisions around deposit insurance, but there has been no attempt to link that initiative and the bank capital proposal,
  • Phase 2 of the review of the Reserve Bank Act is well underway, and the provisional intention is that the Governor should no longer be the sole decisionmaker on matters of prudential policy, and that in future Treasury should play a stronger review role,
  • there is absolutely no urgency about doing anything about bank capital now (as every one recognises banks are strongly capitalised and have strongly capitalised parents, and it is only a few years since capital ratios were increased),
  • if anything, there is a strong case for doing nothing right now: the looming economic slowdown and diminished inflation pressures that are leading to OCR cuts remind us again of the approaching limits of conventional monetary policy.  The last thing we should be doing in that climate –  when stress tests etc show that bank balance sheets are sound –  is throwing more sand in wheels, potentially impeding credit availability over the next few years.

Of course, the Governor could refuse such a request, but he would be very unwise to do so.   The Governor has no public mandate, no independent source of legitimacy, and this is not an issue about the supervision of an individual institution –  it is about overall economic management, where the big parameters (eg inflation targets, debt targets……and financial stability goals, which are harder to pin down) should be made by those we elect, and can toss out again.   It should hardly be controversial if the Minister were to suggest to the Governor that he would be prepared to legislate so that in future changes in bank conditions of registration –  the lever the Bank uses –  could only be done by Order-in-Council, not simply on the Bank’s whim.  After all, that is how the prudential regime works for non-banks (and you’ll note there is no proposal in front of us to markedly increase capital requirements for non-bank deposit takers).

We need expert advice from the central bank – something we aren’t getting at present –  and expert independent adminstration of the rules, but the big policy calls (which involve significant risks, which no one can determine definitively) need to be the responsibility of the elected government.

For anyone interested, my own submission is here.

PS.  As Martien Lubberink at Victoria has pointed out there is another international agency paper out just recently that really doesn’t help the Bank’s case much if at all. I might touch on that tomorrow.