Quote from TPCS: it is important to stay on point with what they are looking for. Read the Lipsky interview if clarity on this issue is required
Point taken. But you see, the IMF editors/moderators turned out to be rather selective... With the 95%+ rejection rates in mind, I submitted several letters, all equally technical and all containing insights not really that far intellectually behind those that were eventually published (the 'What the fcuk' comment nothwithstanding

:
- Estimating Tobin tax revenue (the US example)
- Estimating the "fair" rate for the financial transactions tax
- RegT cap on house market leverage; counter-cyclical Basel
and while they replied to the first one I sent, they selected for publication only the (abstract of) the middle one. Perhaps it's as simple as exceeding the user quota (I am naive enough not to use multiple identities - but I'm learning from you benwm

, or perhaps there is something more to their selectivity than meets the eye...
So given the apparent limits, can you submit yet another comment of mine (the one you see below), which is hopefully adequately general and macro-level, and completely avoids our usual obsession with Prof. Tobin's wishes.
More importantly, it comes from the corporate sector, which is the only disinterested party in this case. No more banking sector complaints about leverage limits, no more governments and NGOs praising transaction taxes to help them out of their current funding crisis (and get re-elected to boot). It is a rather technical review of policy recommendations contained in a recent McKinsey report on deleveraging. Oh, and it would suit your blog rather nicely, don't you think?
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A recent report "Debt and deleveraging: The global credit bubble and its economic consequences" published by McKinsey Global Institute (McKinsey & Co's research arm established in 1990) includes several suggestions for regulators seeking to increase financial markets stability (see URL:
http://www.mckinsey.com/mgi/publications/debt_and_deleveraging/index.asp, p. 46-8).
The report argues in favor of the following stability-enhancing measures, all of which are targeting "excessive" build-up of leverage in the financial system and in the real economy, placing constraints on such build-up to avoid "over-leveraging" and ease the deleveraging process required afterwards:
1) a high-granularity (sector-level), internationally standardized system for tracking leverage should be maintained by the Financial Stability Board or the IMF, which would facilitate early identification of potentially developing credit bubbles (with sector-level leverage being proxy for such bubbles),
2) a new regulation should be incorporated in the Basel II framework, requiring banks to adjust their internal risk models to reflect levels of leverage in the relevant sectors (or ideally even narrower borrower groups) they are exposed to; this would effectively force banks to increase capital reserves in anticipation of any increases in default rates, rather than merely reacting to volatility increases when the deleveraging process is already underway (note that this assumes leverage is a leading indicator of volatility, which may be contested by banks forced to implement such models at their own expense),
3) because it would be "impractical and undesirable" for regulators to intervene at a very micro level of detail, macroprudential policy should be used instead to control leverage levels in specific (overheated) sectors of the real economy; an example of such intervention, albeit still at a national level, is a comprehensive set of "overexuberance" metrics (with readily available datasets) and a systemic risk "surcharge" over the existing microprudential bank capital requirements, recently proposed by the Bank of England (see pages 17-19 of their November 2009 discussion paper "The role of macroprudential policy", URL:
http://www.bankofengland.co.uk/publ...ability/roleofmacroprudentialpolicy091121.pdf ),
4) national regulators should reassess the need for further increases in bank capital ratios, given that the leverage of the US commercial banks has already reached average pre-crisis levels by the third quarter of 2009 (the ratio of risk-weighted assets to Core Tier 1 capital is around 13.3, i.e. below the 15-year average of 13.8) and further regulation-induced compulsory deleveraging would restric credit supply to the real economy or raise the cost of credit; if this long-term leverage level were to be used as a regulatory leverage limit (i.e. if banks were required to maintain at least 7.5% of tangible common equity to secure their risk-weighted assets), then 3/4 of the banks in financial distress would have weathered the recent financial crisis,
5) central bankers should include leverage in their monetary policy objectives, on top of the traditional inflation targets, thus preventing the development of asset bubbles, not only in financial markets but also in real estate; this can be also achieved with more precisely targeted regulatory tools, such as margin requirements propagated through the broker-dealer industry (already implemented or under discussion, such as the new leverage limits recently proposed by the US regulators) or maximum loan-to-value ratios permitted in mortgage lending (however difficult they may be to implement for political reasons),
6) policy makers should reconsider the highly preferential tax and capital treatment of residential mortgages, because most bank loans are extended to finance real estate purchases (and asset bubbles), at the cost of small and medium-sized enterprise loans; moreover, equity financing should receive equal treatment with corporate debt issuance (which currently enjoys preferential tax treatment),
7) regulators should analyze and possibly limit all incentives for households to take on debt (broadly defined, not restricted to tax incentives, because they were not required for overleveraging to develop in countries such as Spain), making it more difficult to access credit, especially for less creditworthy borrowers (this should include limiting loan-to-value ratios on broadly defined household debt).