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WALL
STREET AND THE RISE OF HITLER. By Antony C. Sutton
http://reformed-theology.org/html/books/wall_street/index.html
Unraveling the Basel Capital Accord
TEN TIMES A YEAR - once a month except in August and October - a small group of well dressed men arrives in Basel, Switzerland. Carrying overnight bags and attaché cases, they discreetly check into the Euler Hotel, across from the railroad station. They have come to this sleepy city from places as disparate as Tokyo, London, and Washington, D.C., for the regular meeting of the most exclusive, secretive, and powerful supranational club in the world.
Each of the dozen or so visiting members has his own office at the club, with secure telephone lines to his home country. The members are fully serviced by a permanent staff of about 300, including chauffeurs, chefs, guards, messengers, translators, stenographers, secretaries, and researchers. Also at their disposal are a brilliant research unit and an ultramodern computer, as well as a secluded country club with tennis courts and a swimming pool, a few kilometres outside of Basel.
The membership of this club is restricted to a handful of powerful men who determine daily the interest rate, the availability of credit, and the money supply of the banks in their own countries. They include the governors of the U.S. Federal Reserve, the Bank of England, the Bank of Japan, the Swiss National Bank, and the German Bundesbank. The club controls a bank with a $40 billion kitty in cash, government securities, and gold that constitutes about one tenth of the world's available foreign exchange. The profits earned just from renting out its hoard of gold (second only to that of Fort Knox in value) are more than sufficient to pay for the expenses of the entire organization. And the unabashed purpose of its elite monthly meetings is to coordinate and, if possible, to control all monetary activities in the industrialized world. The place where this club meets in Basel is a unique financial institution called the Bank for International Settlements - or more simply, and appropriately, the BIS (pronounced "biz" in German).
THE BIS was originally established in May 1930 by bankers and diplomats of Europe and the United States to collect and disburse Germany's World War I reparation payments (hence its name). It was truly an extraordinary arrangement. Although the BIS was organized as a commercial bank with publicly held shares, its immunity from government interference - and taxes in both peace and war was guaranteed by an international treaty signed in The Hague in 1930. Although all its depositors are central banks, the BIS has made a profit on every transaction. And because it has been highly profitable, it has required no subsidy or aid from any government.
Since it also provided, in Basel, a safe and convenient repository for the gold holdings of the European central banks, it quickly evolved into the bank for central banks. As the world depression deepened in the Thirties and financial panics flared up in Austria, Hungary, Yugoslavia, and Germany, the governors in charge of the key central banks feared that the entire global financial system would collapse unless they could closely coordinate their rescue efforts. The obvious meeting spot for this desperately needed coordination was the BIS, where they regularly went anyway to arrange gold swaps and war-damage settlements.
Even though an isolationist Congress officially refused to allow the U.S. Federal Reserve to participate in the BIS, or to accept shares in it (which were instead held in trust by the First National City Bank), the chairman of the Fed quietly slipped over to Basel for important meetings. World monetary policy was evidently too important to leave to national politicians. During World War II, when the nations, if not their central banks, were belligerents, the BIS continued operating in Basel, though the monthly meetings were temporarily suspended. In 1944, following Czech accusations that the BIS was laundering gold that the Nazis had stolen from occupied Europe, the American government backed a resolution at the Bretton Woods Conference calling for the liquidation of the BIS. The naive idea was that the settlement and monetary-clearing functions it provided could be taken over by the new International Monetary Fund. What could not be replaced, however, was what existed behind the mask of an international clearing house: a supranational organization for setting and implementing global monetary strategy, which could not be accomplished by a democratic, United Nations-like international agency. The central bankers, not about to let their club be taken from them, quietly snuffed out the American resolution.
After World War II, the BIS reemerged as the main clearing house for European currencies and, behind the scenes, the favored meeting place of central bankers. When the dollar came under attack in the 1960s, massive swaps of money and gold were arranged at the BIS for the defence of the American currency. It was undeniably ironic that, as the president of the BIS observed, "the United States, which had wanted to kill the BIS, suddenly finds it indispensable." In any case, the Fed has become a leading member of the club, with either Chairman Paul Volcker or Governor Henry Wallich attending every "Basel weekend."
"It was in the wood-paneled rooms above the shop and the hotel that decisions were reached to devalue or defend currencies, to fix the price of gold, to regulate offshore banking, and to raise or lower short-term interest rates."
ORIGINALLY, the central bankers sought complete anonymity for their activities. Their headquarters were in an abandoned six-storey hotel, the Grand et Savoy Hotel Universe, with an annex above the adjacent Frey's Chocolate Shop. There purposely was no sign over the door identifying the BIS so visiting central bankers and gold dealers used Frey's, which is across the street from the railroad station, as a convenient landmark. It was in the wood-paneled rooms above the shop and the hotel that decisions were reached to devalue or defend currencies, to fix the price of gold, to regulate offshore banking, and to raise or lower short-term interest rates. And though they shaped "a new world economic order" through these deliberations (as Guido Carli, then the governor of the Italian central bank, put it), the public, even in Basel, remained almost totally unaware of the club and its activities.
In May 1977, however, the BIS gave up its anonymity, against the better judgement of some of its members, in exchange for more efficient headquarters. The new building, an eighteen-story-high circular skyscraper that rises over the medieval city like some misplaced nuclear reactor, quickly became known as the "Tower of Basel" and began attracting attention from tourists. "That was the last thing we wanted, " Dr. Fritz Leutwiler, current president of both the BIS and the Swiss National Bank, explained to me while watching currency changes flash across the Reuters screen in his office. "If it had been up to me, it never would have been built."
Despite its irksome visibility, the new headquarters does have the advantages of luxurious space and Swiss efficiency. The building is completely air-conditioned and self-contained, with its own nuclear-bomb shelter in the sub-basement, a triply redundant fire-extinguishing system (so outside firemen never have to be called in), a private hospital, and some twenty miles of subterranean archives. "We try to provide a complete clubhouse for central bankers ... a home away from home," said Gunther Schleiminger, the super-competent general manager, as he arranged a rare tour of the headquarters for me.
The top floor, with a panoramic view of three countries - Germany, France, and Switzerland - is a deluxe restaurant, used only to serve the members a buffet dinner when they arrive on Sunday evenings to begin the "Basel weekends." Aside from those ten occasions, this floor remains ghostly empty.
On the floor below, Schleiminger and his small staff sit in spacious offices, administering the day-to-day details of the BIS and monitoring activities on lower floors as if they were running an out-of-season hotel.
The next three floors down are suites of offices reserved for the central bankers. All are decorated in three colors - beige, brown, and tan - and each has a similar modernistic lithograph over the desk. Each office also has coded speed-dial telephones that at a push of a button directly connect the club members to their offices in their central banks back home. The completely deserted corridors and empty offices - with nameplates on the doors and freshly sharpened pencils in cups and neat stacks of incoming papers on the desks - are again reminiscent of a ghost town. When the members arrive for their forthcoming meeting in November, there will be a remarkable transformation, according to Schleiminger, with multilingual receptionists and secretaries at every desk, and constant meetings and briefings.
On the lower floors are the BIS computer, which is directly linked to the computers of the member central banks, and provides instantaneous access to data about the global monetary situation, and the actual bank, where eighteen traders, mainly from England and Switzerland, continually roll over short-term loans on the Eurodollar markets and guard against foreign-exchange losses (by simultaneously selling the currency in which the loan is due). On yet another floor, gold traders are constantly on the telephone arranging loans of the bank's gold to international arbitragers, thus allowing central banks to make interest on gold deposits.
Occasionally there is an extraordinary situation, such as the decision to sell gold for the Soviet Union, which requires a decision from the "governors," as the BIS staff calls the central bankers. But most of the banking is routine, computerized, and riskless. Indeed, the BIS is prohibited by its statutes from making anything but short-term loans - most are for thirty days or less - that are government-guaranteed or backed with gold deposited at the BIS. The profits the BIS receives for essentially turning over the billions of dollars deposited by the central banks amounted to $162 million last year.
AS SKILLED as the BIS may be at all this, the central banks themselves have highly competent staff capable of investing their deposits. The German Bundesbank, for example, has a superb international trading department and 15,000 employees - at least twenty times as many as the BIS staff. Why then do the Bundesbank and the other central banks transfer some $40 billion of deposits to the BIS and thereby permit it to make such a profit?
One answer is, of course, secrecy. By commingling part of their reserves in what amounts to a gigantic mutual fund of short-term investments, the central banks create a convenient screen behind which they can hide their own deposits and withdrawals in financial centers around the world. For example, if the BIS places funds in Hungary, the individual central banks do not have to answer to their governments for investing in a communist country. And the central banks are apparently willing to pay a high fee to use the cloak of the BIS.
There is, however, a far more important reason why the central banks regularly transfer deposits to the BIS: they want to provide it with a large profit to support the other services it provides. Despite its name, the BIS is far more.than a bank. From the outside, it seems to be a small, technical organization. Just eighty-six of its 298 employees are ranked as professional staff. But the BIS is not a monolithic institution: artfully concealed within the shell of an international bank, like a series of Chinese boxes one inside another, are the real groups and services the central bankers need -- and pay to support.
The first box inside the bank is the board of directors, drawn from the eight European central banks (England, Switzerland, Germany, Italy, France, Belgium, Sweden, and the Netherlands), which meets on the Tuesday morning of each "Basel weekend." The board also meets twice a year in Basel with the central banks of Yugoslavia, Poland, Hungary, and other Eastern bloc nations. It provides a formal apparatus for dealing with European governments and international bureaucracies like the IMF or the European Economic Community (the Common Market). The board defines the rules and territories of the central banks with the goal of preventing governments from meddling in their purview. For example, a few years ago, when the Organization for Economic Cooperation and Development in Paris appointed a low-level committee to study the adequacy of bank reserves, the central bankers regarded it as poaching on their monetary turf and turned to the BIS board for assistance. The board then arranged for a high-level committee, under the head of Banking Supervision at the Bank of England, to preempt the issue. The OECD got the message and abandoned its effort.
To deal with the world at large, there is another Chinese box called the Group of Ten, or simply the "G-10." It actually has eleven full-time members, representing the eight European central banks, the U.S. Fed, the Bank of Canada, and the Bank of Japan. it also has one unofficial member: the governor of the Saudi Arabian Monetary Authority. This powerful group, which controls most of the transferable money in the world, meets for long sessions on the Monday afternoon of the "Basel weekend." It is here that broader policy issues, such as interest rates, money-supply growth, economic stimulation (or suppression) , and currency rates are discussed - if not always resolved.
Directly under the G-10, and catering to all its special needs, is a small unit called the "Monetary and Economic Development Department," which is, in effect, its private think tank. The head of this unit, the Belgian economist Alexandre Lamfalussy, sits in on all the G-10 meetings, then assigns the appropriate research and analysis to the half dozen economists on his staff. This unit also produces the occasional blue-bound "economic papers" that provide central bankers from Singapore to Rio de Janeiro, even though they are not BIS members, with a convenient party line. For example, a recent paper called "Rules versus Discretion: An Essay on Monetary Policy in an Inflationary Environment," politely defused the Milton Friedmanesque dogma and suggested a more pragmatic form of monetarism. And last May, just before the Williamsburg summit conference, the unit released a blue book on currency intervention by central banks that laid down the boundaries and circumstances for such actions. When there are internal disagreements, these blue books can express positions sharply contrary to those held by some BIS members, but generally they reflect a consensus of the G-10.
OVER A BRATWURST-AND-BEER lunch on the top floor of the Bundesbank, which is located in a huge concrete building (called "the bunker") outside of Frankfurt, Karl Otto Pöhl, its president and a ranking governor of the BIS, complained to me about the repetitiousness of the meetings during the "Basel weekend." "First there is the meeting on the Gold Pool, then, after lunch, the same faces show up at the G-10, and the next day there is the board [which excludes the U.S., Japan, and Canada], and the European Community meeting [which excludes Sweden and Switzerland from the previous group]." He concluded: "They are long and strenuous - and they are not where the real business gets done." This occurs, as Pöhl explained over our leisurely lunch, at still another level of the BIS: "a sort of inner club," as he put it.
The inner club is made up of the half dozen or so powerful central bankers who find themselves more or less in the same monetary boat: along with Pöhl are Volcker and Wallich from the Fed, Leutwiler from the Swiss National Bank, Lamberto Dini of the Bank of Italy, Haruo Mayekawa of the Bank of Japan, and the retired governor of the Bank of England, Lord Gordon Richardson (who had presided over the G -10 meetings for the past ten years). They are all comfortable speaking English; indeed, Pöhl recounted how he has found himself using English with Leutwiler, though both are of course native German-speakers. And they all speak the same language when it comes to governments, having shared similar experiences. Pöhl and Volcker were both undersecretaries of their respective treasuries; they worked closely with each other, and with Lord Richardson, in the futile attempts to defend the dollar and the pound in the 1960s. Dini was at the IMF in Washington, dealing with many of the same problems. Pöhl had worked closely with Leutwiler in neighboring Switzerland for two decades. "Some of us are very old friends," Pöhl said. Far more important, these men all share the same set of well-articulated values about money.
The prime value, which also seems to demarcate the inner club from the rest of the BIS members, is the firm belief that central banks should act independently of their home governments. This is an easy position for Leutwiler to hold, since the Swiss National Bank is privately owned (the only central bank that is not government owned) and completely autonomous. ("I don't think many people know the name of the president of Switzerland - even in Switzerland," Pöhl joked, "but everyone in Europe has heard of Leutwiler.") Almost as independent is the Bundesbank; as its president, Pöhl is not required to consult with government officials or to answer the questions of Parliament - even about such critical issues as raising interest rates. He even refuses to fly to Basel in a government plane, preferring instead to drive in his Mercedes limousine.
The Fed is only a shade less independent than the Bundesbank: Volcker is expected to make periodic visits to Congress and at least to take calls from the White House - but he need not follow their counsel. While in theory the Bank of Italy is under government control, in practice it is an elite institution that acts autonomously and often resists the government. (In 1979, its then governor, Paolo Baffi, was threatened with arrest, but the inner club, using unofficial channels, rallied to his support.) Although the exact relationship between the Bank of Japan and the Japanese government purposely remains inscrutable, even to the BIS governors, its chairman, Mayekawa, at least espouses the principle of autonomy. Finally, though the Bank of England is under the thumb of the British government, Lord Richardson was accepted by the inner club because of his personal adherence to this defining principle. But his successor, Robin Leigh-Pemberton, lacking the years of business and personal contact, probably won't be admitted to the inner circle.
In any case, the line is drawn at the Bank of England. The Bank of France is seen as a puppet of the French government; to a lesser degree, the remaining European banks are also perceived by the inner club as extensions of their respective governments, and thus remain on the outside.
A second and closely related belief of the inner club is that politicians should not be trusted to decide the fate of the international monetary system. When Leutwiler became president of the BIS in 1982, he insisted that no government official be allowed to visit during a "Basel weekend." He recalled that in 1968, U.S. Treasury undersecretary Fred Deming had been in Basel and stopped in at the bank. "When word got around that an American Treasury official was at the BIS," Leutwiler said, "bullion traders, speculating that the U.S. was about to sell its gold, began a panic in the market." Except for the annual meeting in June (called " the Jamboree" by the staff), when the ground floor of the BIS headquarters is open to official visitors, Leutwiler has tried to enforce his rule strictly. "To be frank," he told me, "I have no use for politicians. They lack the judgement of central bankers." This effectively sums up the common antipathy of the inner club toward "government muddling," as Pöhl puts it.
The inner-club members also share a strong preference for pragmatism and flexibility over any ideology, whether that of Lord Keynes or Milton Friedman. For this reason, there was considerable apprehension last spring that Paul Volcker would be replaced by a supply-side ideologue like Beryl Sprinkel, and considerable relief when he was reappointed for another term. Rather than resorting to rhetoric and invoking principles, the inner club seeks any remedy that will relieve a crisis. For example, earlier this year, when Brazil failed to pay back on time a BIS loan that was guaranteed by the central banks, the inner club quietly decided to extend the deadline instead of collecting the money from guarantors. "We are constantly engaged in a balancing act - without a safety net," Leutwiler explained.
THE FINAL AND by far the most important belief of the inner club is the conviction that when the bell tolls for any single central bank it tolls for them all. When Mexico faced bankruptcy last year, for instance, the issue for the inner club was not the welfare of that country but, as Dini put it, "the stability of the entire banking system." For months Mexico had been borrowing overnight funds from the interbank market in New York - as every bank recognized by the Fed is permitted to do - to pay the interest on its $80 billion external debt. Each night it had to borrow more money to repay the interest on the previous nights transactions, and, according to Dini, by August Mexico had borrowed nearly one quarter of all the "Fed Funds," as these overnight loans between banks are called.
The Fed was caught in a dilemma: if it suddenly stepped in and forbade Mexico from further using the interbank market, Mexico would be unable to repay its enormous debt the next day, and 25 percent of the entire banking system's ready funds might be frozen. But if the Fed permitted Mexico to continue borrowing in New York, in a matter of months it would suck in most of the interbank funds, forcing the Fed to expand drastically the supply of money.
It was clearly an emergency for the inner club. After speaking to Miguel Mancera, director of the Banco de Mexico, Volcker immediately called Leutwiler, who was vacationing in the Swiss mountain village of Grison. Leutwiler realized that the entire system was confronted by a financial time bomb: even though the IMF was prepared to extend $4.5 billion to Mexico to relieve the pressure on its long-term debt, it would require months of paperwork to get approval for the loan. And Mexico needed an immediate fix of $1.85 billion to get out of the interbank market, which Mancera had agreed to do. But in less than forty-eight hours, Leutwiler had called the members of the inner club and arranged the temporary bridging loan.
While this $1.85 billion appeared - at least in the financial press - to have come from the BIS, virtually all the funds came from the central banks in the inner club. Half came directly from the United States - $600 million from the Treasury's exchange-equalization fund and $325 million from the Fed's coffers; the remaining $925 million mainly from the deposits of the Bundesbank, Swiss National Bank, Bank of England, Bank of Italy, and Bank of Japan, deposits that were specifically guaranteed by these central banks, though advanced pro forma by the BIS (with a token amount advanced by the BIS itself against the collateral of Mexican gold). The BIS undertook virtually no risk in this rescue operation; it merely provided a convenient cloak for the inner club. Otherwise, its members, especially Volcker, would have had to take the political heat individually for what appeared to be the rescue of an underdeveloped country. In fact, they were - true to their paramount values - rescuing the banking system itself.
On August 31 of this year, Mexico repaid the BIS loan. But the bailout was only a temporary, if not pyrrhic, victory. With the multibillion-dollar debts of a score of other countries - including Argentina, Chile, Venezuela, Brazil, Zaire, the Philippines, Poland, Yugoslavia, Hungary, and even Israel - hanging like so many swords of Damocles over its sacred monetary system, the inner club has "no choice," as Leutwiler has concluded, but to remain a crisis manager. This new role has created considerable concern among the outer circle, and even in the Bank of England, since the members who don't entirely share the mentality of the inner club want the BIS to remain primarily a European institution. "Let the Fed worry about Brazil and the rest of Latin America - that is not the job of the BIS," a blunt representative of the Bank of England, definitely not part of the inner club, told me. Others at the BIS have argued that it does not have the experience or facilities to become "a mini-IMF - putting out fires around the world," as one staffer described it.
To mollify such dissent on the periphery, inner club members publicly pay lip service to the ideal of preserving the character of the BIS and not turning it into a lender of last resort for the world at large. Privately, however, they will undoubtedly continue their maneuvers to protect the banking system at whatever point in the world it seems most vulnerable. After all, it is ultimately the central banks' money at risk, not the BIS's. And the inner club will also keep using the BIS as its public mask - and pay the requisite price for the disguise.
The next meeting of the inner club is Monday, November 7.....
Edward Jay Epstein is the author of The Rise and Fall of Diamonds, Legend: The Secret World of Lee Harvey Oswald, and News From Nowhere. He also has written a book on international deception.
Investor's Business Daily, May 1, 1992 summed up the character of the BIS in an article entitled:
Why a Global Credit Crunch? Some say Little-known BIS Is Partly to Blame - Despite its global anonymity, the BIS is one of the most powerful financial institutions in the world ...
In the book Global Financial Integration: the End of Geography, author Richard F. O'Brien further confirms the powerful role of the BIS:
In the financial marketplace, the trend towards some sort of global governance is best represented by the efforts of bank supervisors under the aegis of the Bank for International Settlements in Basel to impose common minimum capital requirements on banks ... and to integrate and coordinate the supervision of banking, securities markets and insurance ...
Financial World Magazine - February 16, 1993 "Where Has All the Money Gone?" explains how the BIS has more recently flexed its muscle:
Even before Japan's equity markets began to contract, regulations put into effect in 1988 by the Bank of International Settlement's Committee on Banking regulation and Supervisory Practices had begun to exact a particularly heavy toll on Japanese lenders. Those regulations require the world's bankers to raise their underlying asset bases, the money against which they lend, to 8% to total capital, more than double the asset average of the 1980's.- J Epstein
"The Power of financial capitalism had [a] far reaching plan, nothing less than to create a world system of financial control in private hands able to dominate the political system of each country and the economy of the world as a whole.This system was to be controlled in a feudalistic fashion by the central banks of the world acting in concert, by secret agreements arrived at in frequent meetings and conferences.
The apex of the system was to be the Bank for International Settlements in Basel, Switzerland, a private bank owned and controlled by the world's central banks, which were themselves private corporations.
Each central bank sought to dominate its government by its ability to control treasury loans, to manipulate foreign exchanges, to influence the level of economic activity in the country, and to influence co-operative politicians by subsequent rewards in the business world."
The wealth of the country flees the land
Like cottonseed on a wind
Blown by the fetid breath
Of money-pimps in Bedlam
Pursuing the creed of masters
Who worship a market freed
Of all restraints on greed -
While politicians posture
And feed on delusions of power
The above graph [couldn't reproduce it here, see below ed.] was created in order to bestow meaning in simplistic, delineated form to such terms as 'free market', 'new world order' and 'globalisation' - terms that have dominated political/economic terminology over the past two decades-or-so, and the fact that it focusses on banks and bankers (a profession endowed with the aura of authority in the eyes of the public) is quite simply because, without money, those terms are meaningless. Indeed, the title itself emphasises the role of money: After all, what is a banker if he's not a trader in money? Similarly, 'globalisation' would be equally meaningless if such politically omnipotent groups as the Bilderberg Group and the Trilateral Commission were not taken into account when assessing it's (globalisation's) significance. Moreover, how is it possible to disassociate banker from politician from businessman when, at times, one individual is all three - and, in any case, they are constituent parts of a single entity: the corporate establishment? Hence the inclusion of these two groups withinthe graph.
The Bilderberg (or BB from now on) was formed in 1954 out of the need of corporate America to ensure cohesion of purpose on the part of its European partners in the recently formed North Atlantic Alliance (NATO) - the twin aim being to facilitate the flow of American capital into the region, and to bring Germany into the Alliance (against, it should be noted, the wishes of many of its partners). That it is a group endowed with enormous political clout can be attested to by: (1) examination of the lists of committee members and conference attendees over the years - together with the gravity and importance of the subjects discussed at these conferences (NATO, understandably, being repeatedly a key subject); and (2) these conferences take place under very strict security cover supplied by the respective host countries - even though implicit within the structure of this cabal is its unaccountable, secretive nature.
The Trilateral Commission (or TRI from now on) was formed in 1973, its agenda determined by the corporate-funded Brookings Institute and the Kettering Foundation - with not-a-little-help from David Rockefeller of the Chase/Manhattan Bank. That its projected formation should have been so enthusiastically acclaimed by the BB Conference in Knokke (Belgium) in 1972 should cause no surprise. Both corporate-controlled organisations, with linked membership, they shared the same aim: increasing globalisation of their wealth and power. Certainly, the BB with its total lack of any 'democratic accountability', must be in agreement with the TRI's declaration (published in their "The crisis of Democracy") that what the West needs most "is a greater degree of moderation in democracy". Though, on second thoughts, the former probably thinks the 'the degree of moderation' somewht understated!
A further examination of both graph and list of bankers' names reveals that, of the banking organisations, the Banks for International Settlements (or BIS from now on) is self-evidently of prime importance on the international scene - not only because of its prestigious membership (embracing as it does the head bankers of the leading industrial nations) - but also because of the significance of its links with other groups. This article will focus on it, at the expense of the other better-known banking institutions, for two reasons: (1) its prime ranking in the international hierarchy; and (2) so little knowledge of it is in the public domain.
The BIS is the world's oldest international financial institution, having been set up in 1930 with the twin aim of (1) coping with reparations/loans from/to a very unstable post-World War one Germany; and (2) more importantly, to act as a forum for central bankers in the future. As such, it was the epitome of supranationality - able to circumvent all those orthodox ideals that had, over the years, become synonymous with the concept of the 'nation state' - such as 'love of country', 'patriotism' etc., - the danger, of course, being that, in certain circumstances (such as a state of war), such circumvention of patriotism by any of its board members could lead to them being accused of treasonable offences.
In order to appreciate what followed, it is essential to offer a brief resumé of the political/economic situation at the turn of the century: the Industrial Revolution, having fostered the rapid growth of a capitalist economy, inevitably gave birth to an ideal/dogma exposing the socio-political discord inherent within that same system which was based on the concept of one comparatively small group of people garnering profit from the wealth created by the labor of a much larger group. Thus was Marxism born - leading to the Bolshevik revolution in 1917.The USSR, now perceived by the industrial nations as representing the very antithesis of capitalism, was henceforth 'the enemy'. The 'cold war' had begun, and its most blatant expression was the birth of fascism in the aftermath of the Bolshevik revolution - a birth both induced and nurtured by corporations such as I.G.Farben, SKF, Ford, ITT and Du Pont - corporation which were fast becoming multi-national in nature..Enter BIS. Set up in 1930 (see above),it consisted, initially, of a group of 6 central banks and a 'financial institution of the USA'. Granted a constitution charter by Switzerland, it was henceforth based in that country. That America was by then a financial force to be reckoned with on the international scene is borne out by the fact that the first President appointed to the BIS was Gates W. McGarrah (ex-Chase National Bank & Federal Reserve Bank).
By the late 1930's the BIS had assumed an openly pro-Nazi bias - much of it disclosed by Charles Higham in his book "Trading With the Enemy", and years later corroborated by a BBC Timewatch film "Banking With Hitler" (broadcast in late '98). Two examples of such bias (there were many more) were: (1) The BIS had arranged transfers into the account of the German's Reichbank of $378 million of what was, in effect, gold looted from the coffers of the invaded countries of Austria, Czechoslovakia, Holland and Belgium; and (2) in the summer of 1942, plans for the projected American invasion of Algeria were leaked to the governor of the French National Bank, who immediately contacted his German colleague in the BIS, SS Gruppenfuehrer Baron Kurt von Schroder (of the Stein Bank of Cologne), and by transferring 9 billion gold francs to Algiers - via the BIS - the Germans and their French subsidiaries made a killing of some $175 million in this dollar-exchange scam. Given the membership of the BIS at that time, this was hardly surprising. On the board were the following high-profile representatives of the Axis powers (there were 4 others): Walther Funk (Pres. of the Reichbank); Kurt von Schroder (above); Dr. Hermann Schmitz (Jt.Chm. of I.G.Farben); Emil Puhl (V/Pres. of the Reichbank); Yoneji Yamamoto; and Dr. V. Azzolini (Gov. Bank of Italy). It should be added that, of the non-Axis members on the board, many - such as Montagu Norman (Gov. of the Bank of England) were Nazi sympathisers, and that the President of the BIS from 1939 to 1946 was Thomas McKittrick, an American corporate lawyer who had been both Director of Lee, Higginson & Co. (a company which had made substantial loans to the Third Reich) and Chairman of the British-American Chamber of Commerce in London. His continued presidency of the BIS after America's entry into the war in December1941 was approved by Germany and Italy with this significant addendum to their note of authorisation: "McKittrick's opinions are safely known to us".
With the above noted disclosures in mind, the policy of appeasement pursued by Britain and France towards Germany in the pre-war period can now be more readily understood. By concluding a pact with Hitler, Britain and France - in effect - gave him the green light to advance eastwards (ref. "Mein Kampf"). Furthermore, the fact that they shared his endemic anti-communism blinded them to the risk that they were running by negotiating from a position of comparative military weakness - of which Hitler was perfectly aware - and for which they paid a heavy price. It should also be added that the architect of this act of appeasement, Prime Minister Chamberlain, was a shareholder in ICI, which had ties with I.G.Farben.
In the late '30's, and more particularly during World War 2, given America's great wealth - as opposed to Europe's straitened circumstances - it was inevitable that the trade between the two would be of a one-way nature, from the former to the latter. And not surprisingly, in view of the close relationship between American and German corporations (as noted above), a substantial portion of supplies went to Germany - often via fascist Spain - by ship and tanker under flags of neutrality. Many of the financial arrangements covering such trade were handled by BIS in neutral Basle. As an example of how substantial this trade was: in mid-'44 Am,erica was supplying Germany with 48 thousand tons of oil, and 11 hundred tons of much-needed wolfram (tungsten) per month! The fact that this trade was illegal in the USA for much of this period - and particularly after America's entry into the war in December '41 - did little to stop such trade. The large corporations, such as Standard Oil and ITT, saw to that. After all, then - as now - the US Administration was effectively under corporate control (as it has been since 1933, during FDR's term of office). Even the Secretary of Treasury, Henry Morgenthau, and his Assistant, Harry Dexter White, aware as they well were of the part played by BIS in this, could do little about it. In July '44, 730 delegates from 44 countries met at Bretton Woods to plan a framework for post-war international trade, payments and investments - a conference which subsequently resulted in the setting up in'47 of both the International Bank for Reconstruction & Development (IBRD, or World Bank) and the International Monetary Fund (IMF). The apparent inviolability of the BIS referred to above was perhaps best illustrated by the fact that Resolution 5, calling for the dissolution of BIS, was subsequently ignored and proven ineffective. The corporate establishment had seen to that - as indeed, it had seen to all such previous attempts.
With war's end now calling for a clearing of conscience, BIS's method of achieving this was by stressing its somewhat euphemistic neutrality, while playing down its less palatable, but quintessential supranationality. Their annual report of 1946 - as quoted in the Times - stated: "It is noted that the Bank has continued to supply the principles of strict neutrality, but that circumstances have caused a further decline in the volume of its business". Further: "Wars are the worst cause of monetary convulsions, and the first condition for enjoying the benefits of an ordinary monetary system is to establish and maintain a reign of peace". In view of their recent previous history, the term 'irony' hardly does justice to the above statements!. This report was, incidentally, the last to be signed by its President, Thomas McKittrick: in June 1946 he was appointedVice/Chairman of the Chase National Bank by its owners, the Rockefellers - presumably as a mark of gratitude for the assistance rendered to them by the BIS during his presidency.
In view of the somewhat puzzling fact that this now meant that there were in this post-war period three international financial/banking institutions - all with the self-evidently similar aim of resolving the world's serious economic problems - a brief, close look is called for in order to clarify the situation. The first (and intriguing) fact to be noted here is that, whereas the IMF and The World Bank have been frequently and conspicuously in the public eye from birth, the BIS has adopted a low profile and remained uncommunicative. This was an expedient tactic for the latter to adopt - for two reasons: (1) it thus eluded any investigation into its previous financial dealings with the Third Reich; and (2) more importantly, by so diassociating itself from the IMF and World Bank, the latter would henceforth be widely (though erroneously) regarded as the sole guardians of the worldwide economy, thus allowing the BIS more latitude to follow the agenda set by the corporate establishment - to whom, it must be recalled, they owed their survival.
This ambivalent relationship between the IMF/World Bank vis-a-vis the BIS/commercial banks in the 70's is epitomised by Anthony Sampson in his book "The Money Lenders": "The commercial banks in the meantime had created a very different perspective, for the IMF now controlled much less of the world's money. In 1966, the quotas which made up its capital amounted to 10% of the total world imports; but by '76 they made up only 4%"..."by '76 world annual deficits had reached $75 billion : of this, 7% financed by the IMF; 18% by other official international bodies (governments and World Bank) - remaining three-quarters financed by banks (commercial)". (Today, some two-and-a-half decades later, the board members of BIS, between them, control 95% of the money in circulation). The reason for this apparent taking over of such responsibility by the BIS from the IMF/World Bank is twofold: (1) the collapse of the Bretton Woods system of exchange convertibility in the early seventies exposed the irrelevance of the latter as agents for European reconstruction; and (2) the latter being statutorily-appointed agents of the UN, were therefore - ostensibly - accountable to a much wider constituency than the BIS, and therefore politically less manageable by the corporate establishment, whose primary aim in the aftermath of World War 2 was to ensure the unrestricted flow of American capital into Europe. A flow considerably eased by subsequent European integration, in which both NATO and the Bilderberg played a crucial role. This aim was furthered by means of the US Congressionally-authorised European Cooperation Act (ECA) of 1948, and implemented by its subsidiary, the European Payments Union (EPU) of 1950 - both under the aegis of the Marshall Plan of 1947. Predictably, the BIS was the institution chosen by the EPU to oversee this movement of capital (a point worthy of note here is that the head of the EPU at that time was one Richard Bissell, an economist who, years later, was to be the CIA Deputy Director of Planning overseeing the Bay of Pigs fiasco in April '61!).The BIS was now firmly ensconced in the heart of European integration, and was subsequently to play a critical role in the events leading to its (Europe's) eventual evolvement into the European Union, a bureaucratic politico-economic body occupying a position of crucial importance within the wider global hierarchy envisaged by the corporate establishment.
The significance of the American's key central role in this sequence of events is underscored by the fact that, in the aftermath of World War 2, they (the Americans) set up the Bundesbank in Frankfurt (in their zone of control), ensuring that the bank would be independent of government and follow a strict monetary policy - in effect, another Federal Reserve System. In 1948 they replaced the existing Reichmarks with approximately 11 billion Deutschmarks, and Germany's subsequent conduct vis-a-vis European integration must be viewed with this in mind. In any case, the fact remains that Germany's subsequent frequent delaying tactics enabled the dollar to consolidate its dominance.
In their published précis entitled "Profile of an International Organisation", the BIS states that its "predominant tasks are summed up most succintly in part of Article 3 of its original Statutes. They are 'to promote the co-operation of central banks and to provide additional facilities for international financial operations'". To achieve this aim it has 3 administrative bodies: (1) a Board of Directors, comprising the Governors of the central banks of Belgium, France, Germany, Italy, the UK and the USA, each of whom appoints another member of the same nationality - plus the central bank Governors of Canada, Japan,Holland, Sweden and Switzerland: a total of 17. (2) A Management Board; and (3) An annual General Meeting in June of each year.
That this is an organisation carrying enormous clout is readily confirmed by a closer look at said synopsis, pertinent quotes from which follow (italics are BIS's):
(A) "Since September 1994, the eleven countries from which the members of the Bank's Board of Directors are drawn have been identical with the countries which comprise the Group of Ten (G-10), with which the BIS has had a long and close association".
(B) "As well as making resources available to the IMF under the GAB (General Arrangements to Borrow) the G-10 has, since 1963, been a principal forum for discussion of international monetary questions. From the outset, the BIS has been a participant in G-10 Meetings, above all because the Governors of the G-10 central banks meet regularly on the occasion of the Basle monthly meetings. The G-10 meetings have, over time, become the pivotal forum in which much wider activities have been set in motion by the G-10 central banks in the pursuit of financial stability". (Meetings, it should be noted, hosted by the BIS in their high-rise office block in Basle).
(C) "As early as 1971 concern among central banks about the evolution of the Eurocurrency markets led to the establishment of a Standing Committee of the Group of Ten central banks which has met periodically in Basle ever since"
(D) In December 1994 the G-10 Governors set up "The Basle Committee on Banking Supervision, the secretariat for which is provided by the BIS".
(E) "The BIS hosts meeting of, and provides the secretariat for, the Committee on Payment and Settlement Systems and its various working parties".
(F) "..the BIS in a joint initiative with the Basle Committee on Banking Supervision is establishing an Institute for Financial Stability ahich is expected to commence its activities sometime in the second half of this year" (1998).
(G) " From 1964 until the end of 1993 the BIS hosted the Secretariat of the Committee of Governors of the Central Banks of the Member States of the European Economic Community (theCommittee of Governors). From 1st of June 1973 until the end of 1993 the Secretariat of the Committee of Governors also served the Board of Governors of the European Monetary Co-operation Fund (EMCF) and the Bank (BIS) acted as EMCF agent. Until they were replaced by the European Monetary Institute on 1st January 1994, the Committee of Governors and the EMCF were the Community bodies which provided the institutional framework for monetary co-operation in the European Community".
(It should be added that the above quotes are by no means a comprehensive listing in the synopsis of the BIS's activities on the global scene).
Three news items concerning the role played by the BIS are worthy of note:
(1) In 1994 the Belgian banker, Baron Alexandre Lamfalussy resigned from his post as General Manager of the BIS in order to become Head of the European Monetary Institute (EMI) - forerunner of the European Central Bank (ECB). As reported in the Times of 10/11/'93: Andrew Crockett (Executive Director of the Bank of England), who was replacing Lamfalussy as General Manager of the BIS,.."said he did not foresee the ENI..impinging on the work of the Basle-based BIS which is widely regarded as the central banker's central bank"..and adding that.."The EMI would enable the BIS to re-focus on global issues, and develop its role as a forum for collaboration between central banks in the monetary and regulatory fields".
(2) C.Fred Bergsten, Head of the Institute for International Economics, told the Washington Post on the 3rd of January '99 "The adoption of a common currency is by far the boldest chapter of European integration. Money traditionally has been an integral element of national sovereignty"..and the decision by Germany and France to give up their mark and franc "..represents the most dramatic voluntary surrender of sovereignty in recorded history. The European Central Bank that will manage the euro is a truly supranational institution".
(3) In the Independent On Sunday of the 21st February '99 it was reported that Andrew Crockett (see above) has been appointed Chairman of a newly-established 'Stability Forum' (see quote 'F' above), whose aim is to monitor global markets (this was the idea of Hans Tietmeyer, President of the Bundesbank).
Certain conclusions can be drawn from a recapitulation of the facts noted above:
(1) The BIS occupies a central role within the global/European financial scene - to the extent that such institutions as the G-10 and ECB (among others) play a surrogate role.
(2) The goal of the corporations is precisely the same today as it was at the end of the Great War. This is inevitable, inasmuch as inherent within the capitalist system is its obligation to the aggrandisement of profit.
(3) As a consequence, sovereignty - in the sense of a country's or organisation's political independence - can be ignored and overridden. This is happening today. The signs are there for all to see: Is America really in the Gulf Region for the benefit of its inhabitants ('ragheads' in American parlance)? Ask any oilman.
Are the two terms 'NATO' and the "International Community' really synonymous? Ask any country not in the Alliance.
Is the 'Cold War' really dead? Ask NATO why it is still in existence.
Is it not clear that NATO's primary role in Europe is to act as corporate America's anti-Marxist enforcer (even though the Marxism in question may be of a purely nominal nature)? Ask the head formulator of NATO, George Kennan (he may be dead, but his disclosure of the real reason for NATO's birth is on record in the BBC's Lord Reith Lecture of 1957).
Has not the UN's sovereignty been by-passed time-and-time again over the years? Ask its main debtor - America.
And finally, why is so little of the BIS in the public domain? Ask the owners/controllers of the means of communication - the media.
DAVIES, Glyn "A History of Money" (University of Wales '94)
DEDMAN, Martin "The Origins & Development of the European Union - '45 to '95 (Routledge '96)
HIGHAM, Charles "Trading With The Enemy" (Robert Hale '83)
MARSHALL, Matt "The Bank" (Random House '99)
SAMPSON, Anthony "The Money Lenders" (Hodder & Stoughton '81)
BIS Précis '98
INTERNET (Membership lists, etc.)
The "big five" prime banks of Wall Street, the owners of the "Class A" stock of the NewYork Federal Reserve Bank, are: Chase-Manhattan, Citibank, Guaranty Trust, Chemical/Manufacturers-Hannover, and Bankers' Trust. The Class A stock of the Federal Reserve has not been sold or traded on the open market since it was hermetically sealed from the public at the end of the summer of 1914. It is the exclusive property of Wall Street and European prime banks, whose major stockholders are the trans-Atlantic Ruling Class. This pattern holds true of Central Banks throughout the nations of the advanced capitalist sector. The Big Five have interlocking directorates with the "Seven Sisters," the Anglo-Dutch-American oil cartels: Exxon, BP (British Petroleum), Dutch-Royal Shell, Texaco, Mobil, Gulf, and Standard Oil of California (SOCAL).
Several of these trans-Atlantic money and commodity cartels financed Mussolini and Hitler and actively maintained their connections with the Reich throughout World War II. They were also all actively involved in Stalin's Russia by the beginning of the first Five Year Plan in 1928. None of this is really secret-anyone can discover the facts by doing a little research. Nor should it be considered a "conspiracy" (either by those who promote or deny the essential facts of the matter) - bankers and businessmen have been "trading with the enemy" for centuries. It is just one more example of "the wise investment policy" of cartels like J.P. Morgan and Co. and Standard Oil of New Jersey.
The seat of first world finance capital is Basel, Switzerland, where the Central Banks of the Group of Seven (G-7) form the directorate of the Bank for International Settlements (BIS). The G-7 include Britain, France, Germany, Italy, Canada, the U.S., and Japan. The G-7 are called the "Hard Currency Countries" because their Central banks, corporations privately owned by the Prime Banks of these nations, have acquired most of the mined, milled, and ingotted gold of the world. Approximately 80 percent of this is in the vaults of Credit Suisse, under the Berghoff, the airport in Zurich. A somewhat larger formation, called the G-10, includes Belgium, Holland, and Sweden.
The U.S. has become the greatest debtor nation on earth because the Prime Banks of the other nations of the G-10 (especially Britain, Holland, and Japan) have purchased the U.S. government debt in the form of semi-annual and tax-exempt U.S. Treasury Securities through the operations of the Federal Open Market Committee, the Fed's window on Wall Street.
Of these U.S. Treasury Securities, 95% have been floated since the end of World War II to finance the Cold War against the "Evil Empire." Now Communism has been deflated as an enemy; nativist fascist movements are being pumped up all around the globe and the aggregate Debt is approaching the net worth of all the real estate and movables on the planet. Now, also, the U.S. and Russia are joining their military and space programs, the U.S. is becoming by degrees a full-blown totalitarian state, and the bankers are beginning to foreclose upon the bankrupted minions and dupes within their new global condominium.
The Bank for International Settlements (BIS), the "first beast", was founded in 1930 and was the first entity to be called a "World Bank." Monetarist and gold-based, it functions as a clearing house for the balance of payments between nations. It operated throughout WWII as an interlocking directorate and a clearinghouse for joint Allied and Axis high finance.
The World Bank/International Monetary Fund (IMF), the "Second Beast," was founded in 1946, after being drafted at Bretton Woods, New Hampshire, during the war in 1944. The IMF functions as the collection agency for the World Bank, much as the IRS functions as the collection agency for the Federal Reserve Bank. The Wall Street branch of the Federal Reserve is the "fiscal agent" for the IMF in the USA. The capital pool of the IMF consists of the Prime Banks of the First World, which interlock with the First World (G-7) military-industrial complexes and the oil conglomerates.
The IMF functions under the aegis of the United Nations, as a Keynesian paper credit-mill, extending credit in the form of Special Drawing Rights (SDRs) to the Second and Third World debtor nations, requiring that they purchase specified amounts of the currency of the G-7 nations, imposing "austerity terms" upon their internal economies, and looting them by means of "repayment schedules" of their natural resources and minerals. These are channeled through the General Agreement on Tariffs and Trade (GATT) to the multinational cartels, also headquartered in Geneva, Switzerland.
With the implementation of NAFTA and the Uruguay Round of GATT, the real wages of blue and white collar workers in the U.S. will be leveled in time to near parity with the Third World. The last "Superpower," the United States, is not the primary head of the G-7 Beast, but is, owing to its debtor status, the last head, appropriately close to the horned tail, engaging disproportionately in UN Security Council "police actions" around the globe.
International Capital, having gone "global," will increasingly employ the blue-helmeted troops of the UN to enforce the hegemony of Capital in the future.
Mark Evans
North Coast HOME
Electrons to the Editor
Urban Bäckström, Stockholm (Chairman of the Board of Directors, President of the Bank)
Lord Kingsdown, London (Vice-Chairman)
Vincenzo Desario, Rome;
David Dodge, Ottawa;
Antonio Fazio, Rome;
Sir Edward A J George, London;
Alan Greenspan, Washington;
Hervé Hannoun, Paris;
Masaru Hayami, Tokyo;
William J McDonough, New York;
Guy Quaden, Brussels;
Jean-Pierre Roth, Zürich;
Hans Tietmeyer, Frankfurt am Main;
Jean-Claude Trichet, Paris;
Alfons Vicomte Verplaetse, Brussels;
Nout H E M Wellink, Amsterdam;
Ernst Welteke, Frankfurt am Main
Bruno Bianchi or Stefano Lo Faso, Rome;
Roger W Ferguson or Karen H Johnson, Washington;
Jean-Pierre Patat or Marc-Olivier Strauss-Kahn, Paris;
Ian Plenderleith or Clifford Smout, London;
Peter Praet or Jan Smets, Brussels;
Jürgen Stark or Stefan Schönberg, Frankfurt am Main
Andrew Crockett, General Manager
André Icard, Deputy General Manager
Gunter D Baer, Secretary General, Head of Department
William R White, Economic Adviser, Head of Monetary and Economic Department
Robert D Sleeper, Head of Banking Department
Renato Filosa, Manager, Monetary and Economic Department
Mario Giovanoli, General Counsel, Manager
Günter Pleines, Deputy Head of Banking Department
Peter Dittus, Deputy Secretary General
Josef ToÆovský, Chairman, Financial Stability Institute
George Pickering, Chief Representative
Carlo Azeglio Caiampi - Italian politician
Lamberto Dini - Italian politician and banker - board of directors BIS
Antonino Occhiuto Italian central banker - BIS 1975 - now
Tommaso Padoa-Schioppa - Italian central banker - BIS 1993 - now
By Smithy (e-mail: smithy@mindspring.com)
Table of Contents
The Basel Committee on Banking Supervision (BCBS) is a committee of bank supervisory authorities from the G10 (i.e. the wealthiest 10 nations). They meet regularly at the Bank for International Settlements in Switzerland and are in the process of putting together the international agreement known as the Basel Capital Accord (BCA). This sets bank supervision, risk-based capital and disclosure requirements for banks operating internationally. These concepts are described more fully in Sections 2 and 3. The new BCA will effect the activities of all large international banks, and will probably be adopted by more than 100 countries.
While such an Accord might seem rather obscure and irrelevant to the general public, this is perhaps more a feature of the general ignorance, secrecy and complexity surrounding the operations of the international banking and monetary systems than anything else. The purpose of this paper is to act as a discussion document to start gathering concerns from various NGOs working on monetary/finance system issues so that more comments representing public interest issues can be submitted to the BCBS for its next comment period in 2002.
This Accord is of particular interest because of:
In the following sections I wish to unravel some of the main features of the Basel Capital Accord and highlight what I perceive as some of the issues that the general public should be concerned about. In doing so I will attempt to relate the significance of BCA to these above-mentioned issues of global finance sector deregulation, mergers and acquisitions, IMF bailouts, low income credit access, bank supervision trends, and the general imbalance in creditor/debtor relations.
However it should be noted that I am making these observations and drawing conclusions based on public information analyzed using skills acquired in my own training as an actuary who has been primarily concerned with the insurance industry throughout my career. In looking at the banking sector extensive information about exactly what is going on underneath is not easy to find in the public domain.
Based on public information it is not easy to fully understand a bank's risk exposures and it has been widely acknowledged by many bank industry watchers that this is a key part of the success of the monetary system. For the monetary system is no more than a confidence game and this requires confidence in the banks at all times, especially those responsible for the creation of the linchpin currency - the US Dollar.
This necessary "secrecy" surrounding the monetary system in order to keep confidence in the ($US driven) financial system probably has a lot to do with the secrecy that surrounds institutions like the IMF. Public information from the IMF does not reveal how bailout sums are determined or what creditors are at the other end of the bailout packages. Nor do public bank financial statements reveal such details. It is highly likely that the main beneficiaries of IMF bailouts are large western creditors with banking licenses (and therefore those "regulated" under BCA standards) since these institutions sit closest to the heart of the international monetary system. Any large hit to their balance sheet is most likely to threaten global financial stability.
In no way do the opinions expressed herein reflect
the views of my employer nor the views of the professional actuarial societies
of which I am a member. In fact the International Actuarial Society, representing
these organizations, has submitted public comments on BCA that do not overlap
at all with the concerns expressed herein. Nevertheless I consider it the
duty of any professional to consider the broader public implications of the
goings on in their profession. My profession is built around the practice
of financial risk management and it is my opinion that the financial and
other risks to the broader public of the global financial order are unacceptable,
so this is why I write this paper. I do not consider this exercise to be
inconsistent with my duty as an actuary to sound alarm bells when risks are
getting out of hand.
2. Background to Development of Basel Capital Accord (BCA)
The first BCA came into existence in 1988. More information about the original Accord can be found at the web site of the Bank for International Settlements (BIS) at www.bis.org. The BIS is an international bank for central bankers, whose dominant members are the central banks (NOT governments) of the G-10 + Switzerland. More recently other countries' central banks have been able to join the BIS but it is dominated by the G-10. I cannot be certain of all the things the BIS does but I think it is important to note that this is the main place for the meeting of minds of the world's most powerful central bankers. These meetings are conducted in private, as are the Federal Reserve's Open Market Committee and Federal Advisory Council meetings. No doubt, very key decisions about the international monetary system - the same monetary system we all depend on - are made behind these closed doors.
The BCA of 1988, according to the BIS web site, came out of the need to set consistent capital standards for international banks so that one country's banking sector would not have regulatory advantages over another. A "behind-the-scenes look" would reveal that in the late 1980s the US and other bank regulators saw the need to introduce better risk-based capital requirements in the wake of the emerging Savings and Loans Debacle and the Latin American Debt Crisis. In both crises the banks were holding capital way short of what the risk of default of their loans implied and this ultimately led to the need for bailouts (from US public and Latin American public).
The BIS web site also states that the new BCA is coming out of a need to get away from "one size fits all" requirements, and the need to better incorporate operational and market risks (to be discussed in Section 3) into capital requirements. They also state that "sophisticated" banks should be allowed to use their own internal risk management techniques to set their own capital levels. A behind-the-scenes look reveals that the financial crises of the 1990's and subsequent IMF bailouts scared the heck out of those at the helm of the financial system. They found that the old BCA did not have a sufficient capital charge for very risky cross-border loans over that for safer ones. Hence many creditors were incented to engage in very risky cross-border financing which played a large role, not only in triggering the crisis, but also in all the trouble the western creditors found themselves in once the crisis emerged.
The meetings of the Basel Committee on Banking Supervision (BCBS), responsible for the BCA, are hosted by the BIS and are also conducted behind closed doors. Public input into draft BCA documents has been welcomed, however, and this opportunity has certainly been utilized by the global finance sector. So far the major groups of NGOs opposed to the Bretton Woods institutions and the global financial order have not provided input and I am certain the BCBS is not expecting them to. Therefore it would be very nice to give them the big surprise of public input from the members of the public who are not large, powerful financial players. This makes sense especially because this public is called upon to bailout banks whose capital can't cover their risks.
The latest "public" comment period ended on May 31st 2001. Due to the extensive complaints received from the banking sector (who, of course, wish to hold less capital and be less supervised) the BCBS is saying that they will have another round of comments for another (more bank friendly, no doubt) revised draft in 2002. It is important to note that the BCBS is currently chaired by William McDonough, the current President of the Federal Reserve Bank of New York, and who therefore sits on the Federal Open Markets Committee - THE committee that determines monetary policy for the world's linchpin currency.
As noted, the BCBS is composed of central bankers from the G-10. This is a critical observation for several reasons. First, bank supervision standards are being set only by the wealthy countries that create all the "hard currency". Second, bank supervision standards are being set by those responsible for monetary policy, not by separate national government bodies responsible for bank supervision. The domination by central bankers in this process means that most of the input will come directly out of the banking sector, rather than the general public or their elected representatives.
In a better world a large part of the role of bank supervision would be to protect some balance of power between creditors and debtors. Instead the large international banks seem to be moving into a world where they are gaining more ability to "supervise themselves" and this will become more evident as we study BCA. The structure of the BCBS and its role in producing the BCA is consistent with this observation.
In a much better world the actual process of money origination would be democratic, which it is far from today. The reality is that we are stuck with the international monetary system based on the US dollar because that is what people all over the world have placed their confidence and trust in. This is unlikely to change in any hurry, though baby steps are being taken with the emergence of local currencies. In the meantime it makes sense to focus attention on the supervision of those with credit creation powers in the dominant "trusted monetary system", regardless of how unsavory this system and its major players have become.
It is important to note that BCA covers ONLY international banking institutions. It does not cover non-bank financial institutions (NBFI). In one sense it is quite reasonable that banks should have tougher capital requirements and supervision standards on them for the following reasons:
However the emergence of the NBFIs poses a problem and this is giving the banks a lot of leverage in arguing against tough capital requirements. Basically NBFIs have emerged as a result of huge accumulation of financial capital into few hands and the development of new instruments such as loan-backed securities. This means that large NBFIs without a banking license (who do not create M3 money) can compete with bank financiers, so they may have an advantage if banks have to comply with tougher capital and supervision requirements.
Hence many banks are approaching the BCBS with the complaint that the BCA unfairly penalizes them for being a bank. Rather than ignoring these arguments on the basis that the banking sector has privileged access to various bailout mechanisms that NBFIs don’t, I fear that the BCBS may cave in to such arguments. Hence it is important for the concerned public to remind the BCBS of these things and this makes it even more important to get access to the list of creditors benefiting from the IMF bailouts.
If NBFIs are also benefiting from these bailouts then maybe the solution is that NBFIs also need something similar to the BCA. In any case that would be recommended from the point of view of prevention of crises for tougher capital requirements help curtail speculative activity.
3. (Very Brief) Overview of BCA Standards (see www.bis.org/ )
The BCA contains what are known as the three pillars of bank supervision. These are:
Each of these are now discussed in turn:
Capital is the excess of a bank's assets (mostly loans to the non-bank public, including security holdings) over its liabilities (primarily deposits of the non-bank public).
Risk-based capital requirements demand that a bank's capital (or equity) be at least as large as something specified as minimum capital.
Minimum capital requirements act like a safety net and are set based on the riskiness of a bank's assets. If a bank makes lots of risky loans or holds risky securities, then it must hold more capital -more of a safety net - than a bank that takes less risks. Thus capital requirements act like sort of a charge on risky speculations. This helps to curtail risky speculation (which can often serve to destabilize markets) and provides institutions with a capital buffer big enough to absorb the higher expected losses on the asset. In turn this helps reduce the need for publicly funded bailouts of the banking industry such as what happened with the S&L Debacle and what seems to happen with IMF bailouts.
Advocates of the so-called Tobin Tax should be rather fond of well-crafted capital requirements for banks and also other non-bank speculators. Therefore it would be appropriate for such advocates to have some input into BCA.
To see how banks view capital requirements and to see why they like this charge to be as low as possible (especially since handy public bailouts are often available anyway) it is useful to look at an example.
Example of the "Cost of Capital" Charge:
- Suppose shareholders have 10 units of equity capital to invest in a bank.
- Let's suppose the bank's assets will earn 5% and its liabilities will costs 3%.
- If capital requirements are at 10% assets, then the bank can create a total of 100 units in assets by lending with 90 in liabilities and 10 in capital. Then shareholders Return on Equity (ROE) is:
(100 * 5% - 90 * 3%) / 10 = 23%
- If capital requirements are at 5% assets, then the bank can create a total of 200 units in assets by lending with 190 in liabilities and 10 in capital. Then shareholders Return on Equity (ROE) is:
(200 * 5% - 190 * 3%) / 10 = 43%
Banks refer to the "cost of capital" as the earnings that are given up by holding capital earning whatever the assets are invested in (usually a low risk bond rate) versus the required shareholder return rate, which for banks is normally around 20% after tax. In the case of the example above we might like to calculate the cost of capital of the extra 5 units of capital that had to be held as capital in the 10% requirement, but got to be released and invested in banking business (making loans) for another 100 in loans in the 5% requirement.
The costs of capital of these 5 units is:
Earnings on 5 units in 5% Capital Requirement - Earnings on 5 Units in 10% Capital Requirement
= (100 * 5% - 95 *3%) - 5% * 5 = 1.9
This equates to an ROE cost of 1.9/5 = 38% = 43% - 5%.
So you can see why banks like lower capital requirements on the same set of assets and why good risk-based capital requirements help deter certain risky or speculative activities.
Minimum capital is defined in BCA as:
8% * Risk Weighted Asset Base
The risk weighted asset base brings assets into capital requirements commensurate with the risks associated with them. These risks are:
In what follows I will focus primarily on Credit Risk requirements because this is the primary risk for banks and is the main culprit in financial crises. Explanation of how this risk is being treated under the new BCA will serve to illustrate the direction things are headed in and will sound most of the necessary alarm bells.
Credit Risk Assessment
The contribution of bank assets (loans or securities) to the risk weighted asset base for credit risk can be calculated using one of these methods:
0%, 20%, 50%, 100% or 150%
The factor will be selected based on the claim counter-party type (sovereign, bank, corporate) and their rating from an independent body such as Standard and Poors, or the Export Credit Agencies. For claims such as retail mortgages a blanket 50% is used and for unrated entities a blanket 100% is used. Interestingly a risk weighting of 100% for commercial real estate is being proposed because this area has been so much of the cause of recent financial crises.
Though a passing statement is made about higher risk weights for higher risk loans, no explicit mention is made of certain types of loans that caused great shocks to the financial system in the late 1990s. Specifically I am talking about the loans underlying the Long Term Capital Management (LTCM) crisis whereby major US banks lent heavily to this high-risk, highly leveraged hedge fund whose losses almost collapsed the global financial system. Given the growth in these hedge funds and similar vehicles, their tendency to get debt capital from banks on favorable terms, and the fact that they are NOT REGULATED because they involve "sophisticated investors" the BCA should address this explicitly. The unnamed high risk activities with discretion for setting capital requirements is an area wide open for abuse.
BCA also sets out the capital relief that will be
given for various credit mitigation techniques, such as collateral against
loans, guarantees, and credit derivatives. This is based on the amount of
the asset covered by such risk mitigation techniques.
Under the IRB approach banks will use their own internal measures and techniques for setting the Probability of Default associated with each borrower grade. Either the regulators (under the Foundation Approach) or the banks themselves (under the Advanced Approach) will set the other variables for assigning a risk weighting - these include Loss Given Default, Exposure at Default and treatment of guarantees and credits.
The risk weights for each asset are derived using a continuous formula specified by the BCA which assumes a normal default distribution, and is function of both the probability of default, the loss given default and the maturity of the loan under the advanced approach. Another adjustment is made to the group of assets for concentrated risk exposure to single borrowers. No adjustment appears to be made for single groups of related borrowers, which might be a problem, and has certainly been a problem in recent financial crises.
Under these approaches capital relief is also given for credit risk mitigation such as collateral, guarantees, and credit derivatives based on the amount of the asset covered.
There are very detailed sets of rules for the circumstances under which banks may be able to set capital requirements under the Standardized, IRB - Foundation and IRB - Advanced techniques.
Without going into this detail here I think it suffices to use the terminology that the BCA uses - that sophisticated banks with sophisticated risk management techniques will be the ones that get to set their own capital requirements, which are then to be reviewed by the Bank Regulators under Pillar 2. This means that, generally, the self-setting of capital requirements will be done by the largest international banks who also suffer most from the "too-big-to-fail" moral hazard risk.
These are the same banks that tend to exercise power over their regulators rather than the other way around. Furthermore the complexity of both the methodology for the subjective approaches and the complexity of the underlying financial instruments will make it very difficult for the regulators to adequately monitor capital requirements. For example, instruments like credit derivatives are very new, and will often be used for purely speculative, as opposed to risk-mitigation, purposes. Self-setting of capital requirements for such new, complex and speculative investments is wide open for abuse. It is very interesting that the insurance industry regulators do not yet allow such capital relief on credit derivatives.
Market Risk, Interest Rate Risk and Operational Risk
This section of the BCA describes the role of bank supervisors in making sure that banks are managing their risks appropriately. This involves review of banks' risk monitoring techniques and ensuring that banks comply with minimum capital requirements. Obviously this role of the supervisor will become many times more complicated than it has been for those classified as sophisticated banks. This is because of the level of subjectivity and complexity involved in these banks being able to set their own capital requirements.
In my view an adequate supervisory effort in the context of increasingly complex and subjective capital setting methodologies, in conjunction with the convergence of financial services, the increasing cross-border acquisitions, and the growing complexity of financial instruments is becoming almost impossible for the largest financial players. As noted earlier this is also where the "too-big-to-fail" moral hazard and associated risk is also greatest.
Interestingly the current BCA draft states, in its section on Pillar 2 that "Bank management clearly bears primary responsibility for ensuring that the bank has adequate capital to support its risks". This sounds very nice. If only it were true! Then we might have avoided so many nasty financial crises whose costs were ultimately borne by the public and generally by those who could least afford it. In this statement I would have to say that the BCBS is wrong, and that this view they have is leading bank supervisors down a very dangerous path. Because banks sit at the heart of credit (money) creation - at the heart of the international monetary system that we all depend on - it is the PUBLIC in general, not bank management, who bear ultimate responsibility for whether or not the banks have adequate capital and risk management techniques. The BCBS, and bank supervisors in general, clearly need to be reminded of this as they seem to have forgotten that they have any responsibility to the public at all.
Pillar 3: Market Discipline or Public Disclosure
This includes disclosure of risk exposures and calculations of risk-based capital, risk mitigation techniques, and comparison of minimum capital to actual capital. Without seeing an example or explicit list of reporting requirements it is difficult to know how detailed this will be. Nevertheless it sounds like it has potential for the general public to understand just what kind of risks the banking industry is getting us into.
What already has become clear is that the major banks are complaining about the amount of detail of disclosure required under this Pillar. However, given the statements above about who ultimately bears responsibility for bank risks, the public should prefer very detailed disclosure, and maybe even add some additional requirements - such as details of loans rescued by the IMF.
4. Problems with the new BCA from Public Interest Perspective
Bank supervision and the setting of risk-based capital requirements are very complex issues. Mandating risk-sensitive capital requirements for banking book assets is very complex because of the diverse range of complex assets and loan structures banks can invest in (or really, create money for). The mandating of quantitative capital requirements tends to lump together assets with different risk profiles into the same minimum capital requirement class. This then leads to problems with banks investing predominantly in the most risky of this class where the returns are higher, but capital requirements the same, as for a lower risk asset.
This reality played a major role in laying the foundations for the Asian financial crisis whereby so many loans made by large creditors were related to overpriced real-estate that didn't carry a capital charge over safer loans. There is no question this was also a primary cause of the Latin American Debt crisis, the aftermath of which helped create the first round of Basel Accords. There is also little doubt that this facilitated the Long Term Capital Management Crisis, heavily funded by large US banks.
It is highly likely that this problem of mandated % capital requirements for broad asset groups and the extensive "regulatory arbitrage" it generates is a large part of the rational behind the BCA recommendations of Internal Ratings Approaches. Here banks largely set their own capital requirements based on their internal assessments of risk for the specific assets they hold. It is then thought that the supervisory role of regulators and various disclosure requirements will ensure that banks' capital levels and risk management techniques are adequate.
In a world where bank regulators truly represented the interests of the public, and the public had extensive oversight and input into banking system operations and risk management, this would sound like a pretty good idea. It would also require that bank regulators actually have the resources and ability to properly monitor bank risk exposures and capital levels, as well as the necessary authority to make banks improve their practices where needed. Unfortunately none of these conditions hold today and this is discussed in more detail in the following points.
As noted earlier bank supervision has undergone radical shifts in recent decades in part due to the worldwide convergence of financial services - banking, brokerage and insurance - operations. This has created large conglomerates involved in all aspects of financial services and resulted in new regulatory structures in the form of "umbrella supervision" of the new conglomerates. This has complicated financial supervision and also may create a shift towards more uniform supervision across financial operations (though we are not there yet, or even close).
The last major industrialized nation to merge financial services was the United States in 1999. Under such changes the Federal Reserve became the US Umbrella Supervisor of Financial Services Conglomerates, in addition to retaining its previous powers as bank holding company and state-chartered bank supervisor. While the US Government body known as the Office of the Comptroller of the Currency still retains some powers as supervisor of national banks, today the Federal Reserve is the "king of regulators". It seems that the Federal Reserve will have the ultimate responsibility for the supervision of all big financial operators based in the United States. It is the Federal Reserve in the United States who will ultimately oversee the standards set by BCA, because BCA applies to the international players that will be supervised by the Fed.
This reality is potentially fraught with peril for a number of reasons. First, although the Federal Reserve has some government oversight its operations are disproportionately controlled by the private banking sector itself, the very same group supervised by the Fed. This domination by the banking sector comes partly from the role of the Federal Advisory Council, who are the primary Federal Reserve Board advisors and are 100% bankers. It also comes from the fact that most (67%) of the directors of the 12 Federal Reserve Banks are appointed by the banks, and that the Federal Reserve Board is generally dominated by Wall Street choices.
Second is the fact that the Federal Reserve is first and foremost responsible for the monetary policy of the world's linchpin currency, the US Dollar. The role of supervisor - concerned with safety and soundness in the banking system - can and does often directly conflict with the goals of monetary policy. This creates the potential for very harmful conflicts of interest with worldwide consequences. A classic example of this arose before the Latin Debt Crisis when the Federal Reserve, from a monetary policy point of view, wanted to raise interest rates to squash inflation. At the same time, based on earlier years' desire for credit expansion (a monetary goal), the Federal Reserve (as bank holding company supervisor) had allowed banks to expand loans well beyond what their capital levels could support. So by the end of the 1970's past credit expansion had led banks into a situation where defaults on Latin loans could not be swallowed by their low capital levels, and the Fed's desired increase in interest rates would surely trigger such defaults. The end result that solved this conflict - hike up US interest rates, trigger the Latin Debt Crisis and have the IMF and World Bank come in as lenders of last resort to bail out the US banks! And who paid for this crisis for which the conflict of interest in supervisory structure/monetary policy was largely responsible? The people of Latin America, of course!
The recognized dangers of having the umbrella financial regulator be the same entity as that responsible for monetary policy are illustrated by the fact that no other major industrialized nation has put these two, often conflicting, functions under the same body. The fact that this has been done only in the country that is responsible for credit creation in the linchpin currency could have serious global ramifications as the example of the Latin debt crisis indicates.
The situation in the United States before Gramm-Leach-Bliley was that the Federal Reserve as bank holding company supervisor would basically assign staff either from Washington and/or the local regional Fed bank to work permanently on the supervision of the larger banks. These staff work mostly on site at the big banks, sort of like permanent fixtures there, or actually like staff of the banking group itself. These close relations are likely to get even closer under the "self-regulation" approach proposed by BCA for the larger banks, and don't bode well for independent supervision of the larger banking entities.
The incredible complexities of monitoring the capital adequacy of financial conglomerates in a world of increasingly complex instruments and loan structures under the "self-regulatory" methods of the Internal Ratings Based (IRB) approach (specified by BCA) will likely made adequate bank supervision a Herculean task! Given that a potentially talented bank supervisor would makes pots more money working for the banks themselves, the job is close to impossible and therefore wide open to abuse by those banks most likely to adopt IRB. That is, the big banks, and the ones for which bailouts are most necessary.
These new rules have the potential to increase both the frequency and severity of IMF bailouts by allowing more risks to be taken and by allowing those most in need of bailout mechanisms the most leeway for "bending the rules" during their "self-regulation".
International treaties like GATT, administered by the WTO, and under which new financial services agreements have been added, are accelerating the pace of cross-border acquisitions by large Western institutions. Another contributor to this activity was the Asian financial crises, in the aftermath of which various countries and investors were forced to sell off their bankrupt financial institutions at fire-sale prices to the Western institutions who benefited from the IMF bailouts.
Domestically, within the borders of the G-10 countries, mergers and acquisitions between financial institutions have also been accelerating. This is creating huge "financial empires" that are increasingly too-big-to-fail and, as noted earlier, will also be able to set their own internally determined capital requirements. The incentives for abuse of minimal capital requirements created by the "too-big-to-fail" moral hazard are tremendous. This may also give the larger players extra competitive advantages via lower capital charges and thereby facilitate more acquisitions.
Furthermore these financial empires seem to be acquiring greater powers over their own supervisors, meaning that supervisors may not be able to control them anyway, even if they wanted to. Further compounding the problem is that these same regulators are allowing mergers and acquisitions to proceed unheeded. The best example of that recently was the Federal Reserve's speedy approval of Citigroup's acquisition of the Mexican banking giant Banamex. The Federal Reserve completely ignored all public opposition to this deal, and gave no justification for its approval or for overlooking public complaints. One can conclude from this that the Federal Reserve, now the financial regulation king, does not consider itself at all subject to the discipline of democratic accountability.
We saw earlier that some of the requirements in the new BCA are aimed at addressing some of the causes and excessive risk taking that ended in various crises such as the Latin American Debt Crisis, the Asian Financial Crises and the US Savings and Loans Debacle.
Yet other areas of concern are notably absent. The past few years have seen a rise in what are known as hedge funds which are generally high risk, highly leveraged investment funds for the extremely wealthy. They are also completely unregulated on the premise that they involve "sophisticated investors". As we saw in the case of the Long Term Capital Management fund, banks have been making significant loans to these hedge funds without any corresponding capital charge commensurate with the risks involved. Fortunately the banking industry was able to bail itself out of this crises and the public did not have to bear the costs of the associated recklessness. However the new BCA does not appear to address this increasing risk of exposure to hedge funds explicitly at all. With no extra capital charge on hedge fund financing, banks are probably taking excessive risks in this area. This also exacerbates the risks that hedge funds introduce into the markets by providing them with an easy source of financing.
The new BCA also does little to address the issue of bank speculative activity, outside more traditional loans, and what risk this introduces into the financial system in general. For example some disincentive on speculative activity like currency attacks would go a long way towards reducing major risks in the financial system.
The fact that under both the old and new BCA there are no additional capital charges for sub-prime loans seems to have created a situation whereby banks are originating a significant amount of sub-prime loans to prime risks. This tends to happen with mortgages in the lower income markets and, in fact, in 2000 the Chairman of Fannie Mae reported that about one third of sub-prime home loans in the US actually could have received a prime loan if credit assessment had been done properly.
It seems that the lack of capital charge differential has incented a number of banks to offer higher yielding sub-prime loans which reflect a higher risk in the return but not in the capital charge. This has had tragic consequences for these borrowers with many people losing their homes in recent years. I am pretty sure that the folks who meet in Basel don't have lower income customers much on their minds, therefore it is very important for NGOs to make this point.
In general the whole area of predatory lending and credit creation powers over the poor must be addressed in bank supervision standards and is currently nowhere to be found in BCA. In the US for example, the banking industry has a long history of discrimination in providing credit to various groups and a poor record of providing credit on reasonable terms in low and middle income neighborhoods.
Part of the tremendous growth in both overseas lending and sub-prime lending by US banks has surely been driven by the fact that domestic non-bank corporations have sought financing from non-bank sources such that only 20% of their financing actually comes from banks. This has lead to banks increasingly accessing the retail and overseas markets for credit creation. In both of these markets the banks have not behaved well, and have abused their power over financially weaker debtors. Only stronger bank supervision representing the interests of these debtors can help remedy such problems.
Supervision of US financial holding companies by the Federal Reserve does not bode well for any representation of the interests of poorer and foreign creditors in bank supervision. The Federal Reserve has a long track record of ignoring the interests of these groups and indeed has been lax in enforcing standards such as the US Community Reinvestment Act. A sneak preview of how the Federal Reserve may respond to interests of these groups in the future was provided by the Fed's speedy approval of Citigroup's recent acquisition of the Mexican banking group Banamex. In this approval the Federal Reserve completely ignored all complaints from NGOs representing low income groups who have been harmed by Citigroup's widespread predatory lending abuses. The total non-response by the Fed to all complaints about the merger has lead many observers to wonder whether Citigroup actually supervises the Federal Reserve now.
BCA does not cover non-bank financial institutions. However we are seeing various countries' umbrella supervisors feeling the pressure to streamline regulation in the wake of financial services convergence.
One the surface it might not make too much sense for a non-bank lender to have different capital requirements than a lender with a banking license. However it does make more sense if one considers that banks are backed up by various bailout mechanisms including the IMF and FDIC, due to their special status of being creators of money for the (M3) money supply. Because of this central role in money creation it is more important for confidence to be maintained in banks than in non-bank institutions. This is what maintains the overall confidence in the international monetary system. Therefore the likelihood of bailout is much higher for banks, particularly the large ones, and bank capital requirements are of much greater interest to the public than those of non-bank financial institutions.
That said, there could also be a very important role for risk-based capital requirements on non-bank financial institutions to curtail the type of speculative activity often responsible for causing crises in the first place. People opposing the Bretton Woods institutions and advocates of the Tobin Tax might want to keep this in mind as risk-based capital standards develop across other financial players.
The previous sections have been prepared to present a case for public input into the Basel Capital Accord for the majority of the public who are not aligned with the interests of big financial players, but are certainly affected by such international banking agreements. Supervision of banks and their risk management practices are important public issues for reasons outlined above.
However the unfortunate reality is that, of the 200+ public comments received by the BCBS, only 1 or 2 are public concerns from outside the finance sector. These comments can be viewed at the BIS web site at www.bis.org. The majority of comments coming from the larger banks (e.g. comments from Citigroup and the American Bankers Association) are generally asking for more leeway in setting their own capital requirements, and basically requesting lower capital standards. Furthermore there have been many complaints from the big banks about the proposed disclosure requirements.
Originally the last comment period was supposed to be the one ended May 31st, 2001 but due to the number of comments about the current draft the BCBS has stated on its web site that it will issue another draft for comments in early 2002. Hopefully this will provide opportunity for various NGOs to compile and submit a list of concerns. This document is intended as a discussion document to begin the process of collecting comments and concerns from various NGOs working on monetary system issues.