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Latest in Deficit Terrorism: Postal Service Default

By Mitch Green

Americans living in rural areas should brace themselves for a new dose of pain.  As the USPS approaches the end of its fiscal year, where it will be unable to make payment of $5.5 billion to its employees health benefits fund, it is considering closing over 3600 facilities nationwide.  Just yesterday they placed on the chopping block another 250 processing centers.  Most of these closures are distributed throughout rural areas, a demographic that has borne a considerable amount of hardship throughout this entire contraction. For an interactive map of the proposed closures go here.

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The Debt Pyramid and Clearing: Responses to MMP Blog #15

By L. Randall Wray

This week we examine the debt pyramid and clearing of IOUs in the state money of account. Thank you for your questions and comments, and apologies for being late with the response (believe it or not, I lost track of the days of the week—thought I had another 12 hours to get this done).

Q: (Douwe): Please explain the “degree of separation from the CB”.

GA: Thanks for the nice comment. See the pyramid below. Obviously this is a simplified picture of the hierarchy. Within government IOUs we include the Treasury and the Fed. Bank IOUs include demand deposits and other liabilities that banks promise to convert to government IOUs.

Nonbank IOUs are issued by firms and households; it is rather arbitrary where we put the dividing line between bank IOUs and IOUs of “other” financial institutions. Perhaps the most useful way is to distinguish between those types that have direct access to the central bank, and those that do not.

That also brings up the point made by RVAUCBNS: what happens if something goes wrong at the bottom of the pyramid (say, in the shadow banks)? Yes, and that is indeed what happened in the global financial crisis (GFC). Typically those lower in the pyramid issue IOUs that are convertible on some conditions to bank IOUs, that in turn are convertible to government (central bank reserve) IOUs. When something goes wrong, the nonbanks turn to banks for finance (lending against the nonbank’s IOUs); the banks in turn go to the CB. But when expectations turn ugly, the banks won’t lend so the nonbanks cannot make good on promises. That led to the liquidity crisis; the Fed eventually decided to lend to everyone, including the Real Housewives of Wall Street (as Matt Taibi demonstrated).

Additionally, the pyramid is useful for thinking about whose IOUs one can use to make payments on one’s own IOUs. You cannot repay your IOU with your own IOU (you’d still owe); only sovereign government can do that (as we discussed, if you present a five pound note to the Queen, she gives you another; she still owes, but so what—you’ll never get anything else out of her even if you go to court). You use someone else’s—what we call a second party or third party IOU (not first, which is yours; second would be using your creditor’s own IOU; third would be using the IOU of someone unrelated). Normally those lower in the pyramid use bank IOUs; banks in turn use government IOUs (CB reserves).

Jim wondered about power in the structure. Certainly! I’d love to be at the top of that pyramid! Even being at the bank level is a nice gig: government would stand behind your IOUs so they’d be as good as government’s. Gee, do you think your IOUs would then be widely accepted? Yes. When government handed a bank charter over to Government Sachs (oh, whoops, Goldman Sachs), suddenly its IOUs were as good as the Fed’s. Led to a huge multi-billion dollar subsidy. On the other hand, that comes with tighter regulations and supervision (at least, it is supposed to do so). Jim also wondered about the “flatness” of the pyramid—a good point. The pyramid is bigger at the bottom for a reason: more IOUs issued at the bottom than at the top. We can think of that as a more sophisticated financial system. And generally that is true—in developed economies government IOUs (including cash) are a smaller portion of the whole. Since the US Dollar is used all over the world to finance illegal activities, there are more of them sloshing about than you’d expect for a highly developed financial system. And now after QE, we’ve got a lot more bank reserves (at the top of the pyramid) than usual.

Q2: (Jeff) What about settlement of Eurodollars?

A: Same story. Ultimate clearing is at the Fed since these “leverage” US Dollars. (Note: there are also private settlement services—I am simplifying. Banks with off-setting claims on one another can use a private settlement system; they only need to go to the central bank for net clearing, as only the CB can create reserves.)

Q3: (Anon) The Fed mandates that primary dealers buy and sell treasuries.

A: Yes. This is part of the operating procedures to ensure the Treasury can get deposits as needed and move them to the Fed to cut checks or credit accounts as needed.

Q4: (Dave) Techie question about complications in Fed lender of last resort operations. Scott Fullwiler answered—and there is no way I can improve on Scott’s paper since he is the numero uno expert. Those who are really wonkie can go to his paper—it is far too complex for this primer.

Q5: (Glenn) Didn’t Chairman Bernanke admit he bailed out the banks with keystrokes? Where does the Fed borrow from and is there a limit? And wouldn’t it be better to spend the money to bail-out Main Street?

A: Yep. Fed “keystroked” trillions of reserves into existence, buying Treasuries and toxic waste MBSs. Calling this “borrowing” is misleading, which is why I do not use that term. Yes, the Fed is indebted, dollar for dollar, for every one of those keystrokes. Reserves are Fed IOUs. So you could call that “borrowing” and the banks with the reserves could be called “lenders” since they are the creditors. But this is nothing like you or me borrowing to buy a car. We are truly limited in how much we can borrow. The Fed has no limit to keystrokes (unless Ron Paul finally gets Congress to put a limit on the Fed—in other words, self-imposed limits are always possible).

The Fed and Treasury spent, lent, and guaranteed $29 trillion to rescue the banksters. Wouldn’t it be better to spend a fraction of that to rescue Main Street and the unemployed? I think so. Probably 99% of Americans would agree. Unfortunately we do not control the Fed and Treasury.

Q6: (Godefroy) What is inside bank assets? (RVAUCBNS) Aren’t there two kinds of money? Government and bank.

A: I think you mean what is on the asset side of a bank balance sheet. Reserves (electronic entries on the liability side of the CB), treasuries, private bonds and securities, loans, and a tiny bit of vault cash.

Two kinds of money: yes, two main categories. Inside money is the money-denominated IOUs of the nongovernment sector. What I called private money things. Outside money is the money-denominated IOUs of the government sector (cash plus reserves; we can also include treasuries since those are just reserves that pay higher interest). Note it is outside money that is at the top of the pyramid.

Thanks, again. Sorry for being a bit late and a bit brief.

What to Do With the Euro?

Michael Hudson weighs in on the fate of the euro with Jeffrey Sommers and Matthew Lynn on Cross Talk

http://rt.com/s/swf/player5.4.swf?file=http://rt.com/files/programs/crosstalk/euro-eurozone/programs_crosstalk_euro-eurozone_i8dadeb190d03b8b5368f87680dff6192_crosstalk.flv&image=http://rt.com/files/programs/crosstalk/euro-eurozone/programs_crosstalk_euro-eurozone_i366cdc8683d0fe18958b8af502e948cc_euro-eurozone.jpg&skin=http://rt.com/s/css/player_skin.zip&provider=http&abouttext=Russia%20Today&aboutlink=http://rt.com&autostart=false

For more analysis from Michael Hudson visit his website

Today’s Modern Money Primer

Follow Professor Wray as he examines bank clearing and the notion of a “pyramid” of liabilities with the government’s own IOUs at the top of that pyramid.

MMP Blog #15: Clearing and the Pyramid of Liabilities

By L. Randall Wray

Last week we discussed denomination of government and private liabilities in the state money of account—the Dollar in the US, the Yen in Japan, and so on. We also introduced the concept of leverage, for example, the practice of holding a small amount of government currency in reserve against IOUs denominated in the state’s unit of account while promising to convert those IOUs to currency. This also led to a discussion of a “run” on private IOUs, demanding conversion. Since the reserves held are not nearly sufficient to meet the demand for conversion, the central bank must enter as lender of last resort to stop the run by lending its own IOUs to allow the conversions to take place. This week we examine bank clearing and the notion of a “pyramid” of liabilities with the government’s own IOUs at the top of that pyramid.

Clearing accounts extinguishes IOUs. Banks clear accounts using government IOUs, and for that reason either keep some currency on hand in their vaults, or more importantly maintain reserve deposits at the central bank. Further, they have access to more reserves should they ever need them, both through borrowing from other banks (called the interbank overnight market; this is the fed funds market in the US), or through borrowing them from the central bank.

All modern financial systems have developed procedures that ensure banks can get currency and reserves as necessary to clear accounts among themselves and with their depositors. When First National Bank receives a check drawn on Second National Bank, it asks the central bank to debit the reserves of Second National and to credit its own reserves. This is now handled electronically. Note that while Second National’s assets will be reduced (by the amount of reserves debited), its liabilities (checking deposit) will be reduced by the same amount. Similarly, when a depositor uses the ATM machine to withdraw currency, the bank’s assets (cash reserves) are reduced, and its IOUs to the depositor (the liabilities in the deposit account) are reduced by the same amount.

Other business firms use bank liabilities for clearing their own accounts. For example, the retail firm typically receives products from wholesalers on the basis of a promise to pay after a specified time period (usually 30 days). Wholesalers hold these IOUs until the end of the period, at which time the retailers pay by a check drawn on their bank account (or, increasingly, by an electronic transfer from their account to the account of the wholesaler). At this point, the retailer’s IOUs held by the wholesalers are destroyed.

Alternatively, the wholesaler might not be willing to wait until the end of the period for payment. In this case, the wholesaler can sell the retailer’s IOUs at a discount (for less than the amount that the retailer promises to pay at the end of the period). The discount is effectively interest that the wholesaler is willing to pay to get the funds earlier than promised.

Usually, it will be a financial institution that buys the IOU at a discount—called “discounting” the IOU (this is where the term “discount window” at the central bank comes from—the US Fed would buy commercial paper—IOUs of commercial firms–at a discount). In this case, the retailer will finally pay the holder of these IOUs (perhaps a financial institution) at the end of the period, who effectively earns interest (the difference between the amount paid for the IOUs and the amount paid by the retailer to extinguish the IOUs). Again, the retailer’s IOU is cancelled by delivering a bank liability (the holder of the retailer’s IOU receives a credit to her own bank account).

Pyramiding currency. Private financial liabilities are not only denominated in the government’s money of account, but they also are, ultimately, convertible into the government’s currency.

As we have discussed previously, banks explicitly promise to convert their liabilities to currency (either immediately in the case of demand deposits, or with some delay in the case of time deposits). Other private firms mostly use bank liabilities to clear their own accounts. Essentially, this means they are promising to convert their liabilities to bank liabilities, “paying by check” on a specified date (or, according to other conditions specified in the contract). For this reason, they must have deposits, or have access to deposits, with banks to make the payments.

Things can get even more complex than this, because there is a wide range of financial institutions (and, even, nonfinancial institutions that offer financial services) that can provide payment services. These can make payments for other firms, with net clearing among these “nonbank financial institutions” (also called “shadow banks”) occurring using the liabilities of banks. Banks, in turn, clear accounts using government liabilities.

There could, thus, be “six degrees of separation” (many layers of financial leveraging) between a creditor and debtor involved in clearing accounts.

We can think of a pyramid of liabilities, with different layers according to the degree of separation from the central bank. Perhaps the bottom layer consists of the IOUs of households held by other households, by firms engaged in production, by banks, and by other financial institutions. The important point is that households usually clear accounts by using liabilities issued by those higher in the debt pyramid—usually financial institutions.

The next layer up from the bottom consists of the IOUs of firms engaged in production, with their liabilities held mostly by financial institutions higher in the debt pyramid (although some are directly held by households and by other production firms), and who mostly clear accounts using liabilities issued by the financial institutions.

At the next layer we have nonbank financial institutions, which in turn clear accounts using the banks whose liabilities are higher in the pyramid. Just below the apex of the pyramid, banks use government liabilities for net clearing.

Finally, the government is highest in the pyramid—with no liabilities higher than its inconvertible IOUs.

The shape of the pyramid is instructive for two reasons. First, there is a hierarchical arrangement whereby liabilities issued by those higher in the pyramid are generally more acceptable. In some respects, this is due to higher credit worthiness (the government’s liabilities are free from credit risk; as we move down the pyramid through bank liabilities, toward nonfinancial business liabilities and finally to the IOUs of households, risk tends to rise—although this is not a firm and fast rule).

Second, the liabilities at each level typically leverage the liabilities at the higher levels. In this sense, the whole pyramid is based on leveraging of (a relatively smaller number of) government IOUs. There are typically far more liabilities lower in the pyramid than there are high in the pyramid—at least in the case of a financially developed economy.

Note however that in the case of a convertible currency, the government’s currency is not at the apex of the pyramid. Since it promises to convert its currency on demand and at a fixed exchange rate into something else (gold or foreign currency), that “something else” is at the top. The consequences have been addressed in previous blogs: government must hold or at least have access to the thing into which it will convert its currency. As we will see in coming weeks, that can constrain its ability to use policy to achieve some policy goals such as full employment and robust economic growth.

Next week we will take a bit of a diversion to look at the strange case of Euroland. This is the biggest experiment the world has ever seen that attempts to subvert what Charles Goodhart has called the “one nation, one currency” rule. The members of the European Monetary Union each gave up their own sovereign, state, currencies to adopt the euro. While there have been other such experiments, they were small, usually temporary, and often an emergency measure. In the case of Euroland, however, we had strong, developed, rich, and reasonably healthy nations that voluntarily abandoned their sovereign currencies in favour of the euro. The experiment has not gone well. To say the least.

Join In! We’re Talking with Mark Thoma on Twitter

We engaged Mark Thoma of Economist’s View on Twitter this morning. The debate is raging. Follow both of us on Twitter to watch things unfold.  It’s not pretty.

Follow us @deficitowl

Follow him @MarkThoma

With $300 Billion, The President Could Reduce Unemployment to Zero

By L. Randall Wray and Stephanie Kelton

On Thursday night Barack Obama will deliver his highly anticipated jobs speech. At this point, only those closest to the president know exactly how he intends to help spur the economy and create jobs, but reports suggest that he is mulling a $300 billion jobs package that includes more of the same—a one-year extension of the payroll tax cut, a continuation of unemployment benefits, some additional spending on infrastructure and tax incentives to encourage businesses to hire and invest in new capital. Too little of what will work and too much of what won’t for an economy that’s teetering on the brink of a double-dip recession and a president who is running out of time to deliver jobs.  [Read the entire article here]

Government and Private IOUs Denominated in the State Money of Account: Responses to Blog #14

By L. Randall Wray 

This week we addressed denomination of “money things” in the state money of account—for example, the Dollar in the US. We began a discussion of “leveraging”—making one’s IOUs convertible (on demand or on some contingency) into another’s IOUs. Next week we will turn to the notion of a “debt pyramid” with the state’s own IOUs at the apex. For now, on to the questions and comments. As usual I will group them into themes; some commentators actually answered several of the questions (Thanks!) but I’ll briefly repeat some of what they said.

Q1: (Jeff) Can’t the Fed just control inflation by raising required reserve ratios? At the limit, to 100% reserves? And would that affect interest rates?

A: As discussed in a bit more detail below, and in this blog later, required reserve ratios do not control bank lending. To hit its interest rate target, the central bank must accommodate the demand for reserves—whether the ratio is 1% (about where it is now) or 10% (the ratio usually used in textbooks to simplify math). (Note: the required reserve ratio in Canada is a big zip, zero! That is actually the most advanced way to run the system. Hats off to our neighbors to the north.) Since it would not control lending there is little reason to believe raising ratios would affect inflation. Also note that raising the ratio does not affect the overnight rate (fed funds rate in the US)—since that is the policy variable.

Higher ratios do act like a tax on banks—they must hold a very low earning asset. If the ratio is 1% they hold 1% of their assets (more or less—close enough for this analysis) in an asset that earns a very low interest rate (the support rate paid by the central bank on reserves). They need to cover their costs and make profits by earning more than that on the rest of their assets (99%). Raising the ratio to 10% means they only have 90% of their assets potentially earning higher returns. And so on. Will that affect lending rates earned (what they charge borrowers) and deposit rates paid (what they pay depositors)? Well banks live on the spread between those two—that is how they cover costs and make profits. So, yes, raising ratios might cause them to raise loan rates and lower deposit rates—not a good thing for borrowers or depositors. 

Finally, what about 100% reserves? There is a good book by Ronnie Phillips (Google it) on the Fisher-Simons-Friedman proposal to do just that. However, this is usually presented as a way to make banks “safe”—they’d hold only reserves or treasuries against their demand deposits, on the idea that with safe assets, the deposits are always safe (so you do not need deposit insurance, FDIC). Sounds OK so far as it goes. Someone else has to do the lending since the banks are not allowed to do it. A big topic.

Q2: (Jeff) How can China operate domestic policy with a fixed exchange rate?

A: Trillions of dollars of foreign exchange reserves! No George Soros is going to bet against China’s ability to peg its exchange rate. So, yes, there are exceptions to the rule that pegged exchange rates reduce policy space.

Q3: (Neil) What about IMF conversion clause? What makes banks special? (others also asked that)

A: Come on, you are sounding like Ramanan. I answered that already—yes you can tie your shoes together and try to run a marathon. First, this discussion was general. Second, as I showed, in practice the clause has no impact. What makes banks special? We’ll save that for coming blogs. But two characteristics that are very important are: access to central bank, and access to deposit insurance.

Q4: (Godefroy) What does the central bank lend against? How does a bank get cash?

A: Central bank lends against qualifying assets. It’s the boss and can decide. Yes, it lends against treasuries (IOUs of the Treasury); it can lend against “real bills” (short term commercial loans made by banks to good customers); it can lend against toxic waste MBSs (maybe a bad idea?). It can use collateral requirements as a way to supervise/regulate banks: encourage them to make only safe loans by narrowing what it accepts as collateral.

When you go to the ATM to withdraw cash, your bank has a bit on hand—that counts as part of its reserve base. If everyone goes tomorrow, obviously the bank runs out quickly. It orders more from the Fed—shipped in armored trucks—and the Fed debits the bank’s reserves, and when that is insufficient it lends the cash (a loan of reserves) against collateral. The Fed holds the bank’s IOU as an asset; it is of course a liability of the bank.

Q5: Do money center banks influence the FOMC?

A: Is Goldman Sachs a bloodsucking vampire squid that bought and paid for Timmy Geithner’s NY Fed as well as Treasury?

Q6: (Glenn; Jeff) Why does government need to borrow its own IOUs and pay interest? And why pay interest on “fiat money”?

A: Good question! Government cannot borrow its own IOUs. Neither can you! If you give an IOU to your neighbor for a cup of borrowed sugar, you do not go back and ask if you can borrow it. It is a senseless operation.

Instead, government offers Treasuries as a higher interest paying IOU, exchanged for reserves. When you go down to your bank, you can exchange your demand deposit for a saving deposit on which you earn higher interest. That is really all that a government bond sale is—a substitution of a demand deposit at the central bank for a time deposit.

Note that cash (“fiat money”) does not pay interest. A Chicago Mafioso loan shark might lend you cash at 140% interest. Why? You are desperate. He gets compensated for the risk that you will run with the money. Of course, there is a substantial penalty for nonpayment. But why would the Treasury pay interest on bonds, and why would the Fed pay interest on reserves? There is no necessity of doing that. We’d accept cash and banks would accept reserves without interest—there is no default risk (on sovereign government IOUs on a floating exchange rate), and we need them to pay taxes. But it is nice to get interest, isn’t it? Think of it as a government transfer payment, a form of charity. It might be a bad idea—a topic for later.

Q7: Does a lack of sufficient reserves constrain loans?

A: No. Don’t take my word for it. Here’s a comment from the Fed’s Senior Vice President, Federal Reserve Bank of New York, Alan Holmes. Holmes explained why the then faddish Monetarist policy of controlling inflation by controlling the growth of Base Money had failed, saying that it suffered from “a naive assumption” that the banking system only expands loans after the [Federal Reserve] System (or market factors) have put reserves in the banking system. In the real world, banks extend credit, creating deposits in the process, and look for the reserves later. The question then becomes one of whether and how the Federal Reserve will accommodate the demand for reserves. In the very short run, the Federal Reserve has little or no choice about accommodating that demand…

Q8: (unknown) How do banks work? What happens if a borrower goes bankrupt?

A: We’ll look in more detail at how banks “work”. They’ve got assets on one side of their balance sheet and liabilities plus capital on the other. When the assets go bad, the capital is reduced (shareholders lose); once the capital is wiped out, the losses come out of the other liabilities, so creditors lose. Since the FDIC insures depositors, if losses are big enough to hit deposits, Uncle Sam covers those.

Q9: (HadNuff) Don’t you pay taxes with demand deposits? Banks can be illiquid but not insolvent?

A: You write a check to the IRS but your bank pays the taxes for you using reserves, since the IRS sends the check on to the Fed, which debits the bank’s reserves (and increases the Treasury’s deposit). The central bank lends reserves to solve liquidity problems, lending against collateral. Banks do become insolvent, as discussed above. They then must be “resolved”—there are a variety of methods but it comes down to selling the assets, covering insured depositors first, and then other creditors and the shareholders take the loss.

FHFA Complaints: Can Control Frauds Recover for Being Defrauded by other Control Frauds?

By William K. Black 

(Cross-posted from Benzinga.com)

Reading the FHFA complaints against many of the world’s largest banks is a fascinating and troubling process for anyone that understands “accounting control fraud.” The FHFA, a federal regulatory agency, sued in its capacity as conservator for Fannie and Freddie. Its complaints are primarily based on fraud. The FHFA alleges that the fraud came from the top, i.e., it alleges that many of the world’s largest banks were control frauds and that they committed hundreds of thousands of fraudulent acts. The FHFA complaints emphasize that other governmental investigations have repeatedly confirmed that the defendant banks were engaged in endemic fraud. The failure of the Department of Justice to convict any senior official of a major bank, and the almost total failure to indict any senior official of a major bank has moved from scandal to farce.

The FHFA complaints are distressing, however, intheir failure to explain why the frauds occurred and how an accounting controlfraud works.  The FHFA complaint againstCountrywide is particularly disappointing because it accepts hook line andsinker Countrywide’s internal claim that it acted improperly for the purpose ofattaining a larger market share. Executive compensation drops entirely out of the story even though it isthe reason the frauds occur and the means by which controlling officers loot“their” banks.  The FHFA complaintagainst Countrywide ignores executive compensation.  The FHFA complaint against J.P. Morgan(purchaser of WaMu) mentions only that loan officers’ compensation was based onloan volume rather than loan quality. 

The complaints fail to explain the extraordinarysignificance of widespread appraisal fraud – something that only the lender andits agents can produce and a “marker” of accounting control fraud.  No honest lender would inflate, or permit tobe inflated, appraisals.

The complaints also fail to explain why no honestmortgage lender would make “liar’s” loans. The FHFA complaint against Countrywide notes that Countrywide loanofficers would use undocumented loans to aid their creation of fraudulent loanapplications.

Even neoclassical economists – the weakest of allfields in understanding fraud – understand that this crisis was driven byexecutive compensation.  Consider theadmirably short piece entitled
Fake alpha or Heads I win, Tails you lose” by Raghuram Rajan.  Rajan’spiece is badly flawed, but it at least understands the importance ofcompensation, accounting, and risk. 

“Whatthe shareholder will really pay for is if the manager beats the S&P 500index regularly, that is, generates excess returns while not taking more risk.Hence pay for alpha.”
Rajan is correct that the neoclassicaltheory of CEO compensation is that the CEO should only be compensated for high (“excess”)returns if they were not generated by“taking more risks.”  Modern bonus plans oftenpurport to provide exceptional compensation to CEOs who achieve extreme short-term“excess” returns that are not generated by “taking more risks.”  Rajan gets the next point analytical pointcorrect as well:  “In reality, there areonly a few sources of alpha for investment managers.  [S]pecial ability is by definition rare.”  It is the “rare” CEO who can achieve massivebonuses through exceptional performance, but all CEOs desire massive bonuses.  
Rajan gets the next step in theanalytics correct – the answer to the CEO’s dilemma is to create “fake alpha,”but he falls off the rails in the last clause.
“Alphais quite hard to generate since most ways of doing so depend on the investment managerpossessing unique abilities – to pick stock, identify weaknesses in managementand remedy them, or undertake financial innovation. Unique ability is rare. Howthen can untalented investment managers justify their pay? Unfortunately, alltoo often it is by creating fake alpha – appearing to create excess returns butactually taking on hidden tail risk.” 
In his recent book, Rajan explainsthat by “hidden tail risk” he means taking risks that will only cause losses inhighly unusual circumstances.  I willreturn to why this aspect of Rajan’s reasoning is false. 
Rajan gets the next part correct– generating fake alpha will cause the bank to fail when the risks blow up.  Rajan’s “tail risk” theory, however, predictsthat these risks will only blow up rarely.
Rajan then stresses, correctly,that executive compensation based largely on short-term reported income willcreate perverse incentives to generate fake alpha.  He also        
“Truealpha can only be measured in the long run ….  Compensation structures that reward managersannually for profits, but do not claw these rewards back when lossesmaterialize, encourage the creation of fake alpha.”
Rajan, being a good neo-classicaleconomist, recognizes the vital need to change compensation, but has no urgencyabout doing so. 
“[U]nlesswe fix incentives in the financial system, we will get more risk than webargain for. And the enormous pay of financial sector managers, which has hithertobeen thought of as just reward for performance, will deservedly come underscrutiny.”
Corporations have changedexecutive compensation in response to the crisis – by making it even moredependent on short-term reported income. Rajan does not ask why corporations base executive compensation onshort-term reported income without clawbacks. Rajan is correct that such compensation systems create intenselyperverse incentives that cause managers to loot the shareholders and creditorsand cause the bank to fail. 
Rajan’s extreme tail risk theorydescribes an accounting control fraud. Rajan does not understand that he is describing conduct that wouldconstitute accounting fraud.  Rajan alsodoes not understand that his hypothetical has nothing to do with what actuallyhappened in the crisis.  The extreme tailrisk scheme he hypothesizes would be a terrible fraud scheme.  He does not understand accounting controlfraud.
The real investments that drovethe financial crisis were not assets that would suffer losses only in rarecircumstances.  They were nonprimeloans.  Roughly 30% of total loansoriginated by 2006 were “liar’s” loans – with a 90% fraud incidence.  Liar’s loans and subprime are not mutuallyexclusive categories.  By 2006, half ofall loans called subprime were also liar’s loans.  Appraisal fraud was also epidemic.  The probability of endemically fraudulentloans causing losses (instead of fictional “excess return”) was certainty.  The loss recognition could only be delayedthrough a combination of accounting fraud (failing to provide remotely adequateallowances for loan and lease losses (ALLL)) and hyper-inflating thebubble.  Hyper-inflating the bubbleincreases the ultimate losses.
Making extreme tail riskinvestments is a deeply inferior fraud scheme. Rare risks produce tiny risk premiums and the entire game is to createsubstantial risk premiums.  Making liar’sloans allows exceptional growth (part one of the fraud “recipe” for a lender)and booking a premium yield (if one engages in accounting fraud on theALLL).  The key is found in GeorgeAkerlof and Paul Romer’s article title – “Looting: the Economic Underworld ofBankruptcy for Profit” (1993).  As theycorrectly observed, the fraud recipe is a “sure thing” – it maximizes(fictional) short-term reported income, executive bonuses, and real losses.
Rajan got many things correct andmany things wrong about generating fake alpha, but at least he sought toexplain the perverse dynamic.  The FHFAcomplaints lose explanatory power and persuasiveness because they ignorecompensation and accounting.  It pays tounderstand accounting control fraud.