20/6/16: Aid:Tech in Techstars 2016

So it is now official: AID:tech (https://aid.technology/) is one of 11 companies selected for the Techstars 2016 programme: http://www.techstars.com/content/accelerators/announcing-11-companies-summer-2016-techstars-london-class/

AID:tech is the largest blockchain player in the market for providing payments facilitation, data collection and analytics; and assets / supply chain management company for international NGOs and State organisations providing aid and social welfare supports around the world. The company has fully-developed, field-tested suite of solutions allowing it to assist NGOs and governments in:

• Reducing risk of fraud in international aid and social welfare payments by digitalising their payments processes;
• Transmit a payment to the end recipient of aid, instantaneously verifying identity of the recipient, receipt of funds, and confirming the use of funds in the case of aid-related purchases
• Substantially (by a factor of up to 3 times) reduce the cost currently charged by less secure platforms that generally offer lower degree of tractability of transactions.

Today there is a lack of transparency and accountability in the distribution of funds by NGO's and governments.

Of the $360bn transferred each year by NGO's, only $90bn is currently delivered via transparent systems and these systems are extremely expensive to administer. By utilising private blockchain technology, AID:tech enables all international aid to be accounted for, including the distribution of assets such as medicine, food and other essentials. The platform also offers add-ons such as smart contracts and instant micro-insurance, as well as advanced data analytics that help organisations to better plan and execute aid deliveries.

AID:tech is finalist in the Irish Times Innovation Awards (http://www.irishtimes.com/business/irish-times-innovation-awards-finalists-original-thinkers-from-all-sectors-1.2663210 and http://trueeconomics.blogspot.ie/2016/05/30516-aidtech-through-to-irish-times.html) and is shortlisted for the ‘Best Humanitarian Tech Startup’ for The Europas European Tech Startup Awards https://aid.technology/aidtech-shortlisted-for-the-europas-european-tech-startup-award/.

Disclosure: I am very proud of being involved with the company as an adviser and shareholder.

20/6/16: Creating Fiscal Space. Or Money Growing on Trees

You might excuse an average punter for thinking things are going the beleaguered Irish Health Services ways with some EUR500 ml added to the spending bin (http://www.thetimes.co.uk/article/eu-ruling-means-extra-540m-for-health-fbpnqcqb8?shareToken=699206929a359223e8662e8ae88a18d2). After all, even the good folks of The Times bought into the positive story.

But, such a conjecture is wrong. What really is happening, thus? In simple terms, the Eurostat reclassification of the Government conversion of AIB preference shares into ordinary shares generates several implications:

1. Preference shares represent a preferred (or senior) claim on AIB assets in the case of default or dilution compared to ordinary shares. That is the basics corporate finance and as such implies that State conversion of shares adds new risk to the State holdings, as well as reduces the value of that holding. It does create a marginal improvement in the AIB’s outlook for selling shares in the markets, however.
2. The conversion also raises official State deficit and spending volume for 2015, which has no direct material impact on 2015 spending, except via two channels: Channel 1 is the impact that added spending has on future (2016) spending; and Channel 2 is the GDP effect - as AIB transaction added some EUR500 million to State official spending, that EUR500 million is now an addition to 2015 GDP.
3. Because State spending for 2015 is now EUR500 million higher, and because our 2015 deficit was still below the approved (by the EU) target, the State is allowed - by the EU rules - to spend extra cash this year.
4. Although Ireland has funds ‘available’ for such increased spending, the funding will come from borrowing. The reason for this is simple: Ireland is still running a general deficit. Not a general surplus. If the State were to spend EUR500 million of ‘added fiscal space’ on activities for which it is borrowing funds under pre-existent budgetary commitments, the deficit would have dropped - in 2016 - by, roughly, that amount. However, if Ireland were to spend it on a new spending line or to increase spending above previously planned, the funding will come via borrowing from some other activity, such as repaying Government debt.

In simple terms, there is no free lunch. Irish State does not have extra EUR500 million floating around that it did not have before. No matter what you classify things as, basic accounting means: unless you got paid by someone EUR500 million, you have to borrow EUR 500 million in order to spend it.

Simples. But not for Irish media that keeps confusing deficit financing via debt for resources.

19/6/16: Irish Regulators: Betrayed or Betrayers?..

As I have noted here few weeks ago, Irish Financial Regulator, Central Bank of Ireland and other relevant players had full access to information regarding all contraventions by the Irish banks prior to the Global Financial Crisis. I testified on this matter in a court case in Ireland earlier this year.

Now, belatedly, years after the events took place, Irish media is waking up to the fact that our regulatory authorities have actively participated in creating the conditions that led to the crisis and that have cost lives of people, losses of pensions, savings, homes, health, marriages and so on. And yet, as ever, these regulators and supervisors of the Irish financial system:

1. Remain outside the force of law and beyond the reach of civil lawsuits and damages awards; and
2. Continue to present themselves as competent and able enforcers of regulation capable of preventing and rectifying any future banking crises.

You can read about the latest Irish media 'discoveries' - known previously to all who bothered to look into the system functioning: http://www.breakingnews.ie/business/report-alleges-central-bank-knew-of-fraudulent-transactions-between-anglo-and-ilp-740684.html.

And should you think anything has changed, why here is the so-called 'independent' and 'reformed' Irish Regulator - the Central Bank of Ireland - being silenced by the state organization, the Department of Finance, that is supposed to have no say (except in a consulting role) on regulation of the Irish Financial Services: http://www.independent.ie/business/finance-ignored-central-banks-plea-to-regulate-vulture-funds-34812798.html. 

Please, note: the hedge funds, vulture funds, private equity firms and other shadow banking institutions today constitute a larger share of the financial services markets than traditional banks and lenders.  

Yep. Reforms, new values, vigilance, commitments... we all know they are real, meaningful and... ah, what the hell... it'll be Grand.

18/6/16: Retail At Google Conference: June 2016

My slides from this week's presentation at Google Retail conference:

18/7/16: Gamed Financial Information and Regulation Misfires

A recent interview by the Insights by Stanford Business, titled “In Financial Disclosures, Not All Information Is Equal” (all references are supplied below and all emphasis in quotations is mine) touched upon a pivotal issue of quality of information available from public disclosures by listed companies - the very heart of the market fundamentals.

The interview is with Stanford professor of accounting Iván Marinovic, who states, in the words of the interviewer, that “financial statements are becoming less and less relevant compared to other sources of information, such as analysts and news outlets. ...there is a creeping trend in financial disclosures away from the reliance on verifiable assets and toward more intangible elements of a business’s operations.”

In simple terms, financial information is being gamed. It is being gamed by increasing concentration in disclosures on ‘soft’ information (information that cannot be verified) at the expense of hard information disclosures (information that can be verified). More parodoxically, increasing gaming of information is a result, in part, of increasing requirements to disclose hard information! Boom!

Let's elaborate.

In a recently published (see references below) paper, Marinovic and his co-author, Jeremy Bertomeu define ‘hard’ and ‘soft’ information slightly differently. “The coexistence of hard and soft information is a fundamental characteristic of the measurement process. A disclosure can be soft, in the form of a measure that “can easily be pushed in one direction or another”, or hard, having been subjected to a verification after which “it is difficult to disagree”."

For example, firms asset classes can range "from tangible assets to traded securities which are subject to a formal verification procedure. Forward-looking assets are more difficult to objectively verify and are typically regarded as being soft. For example, the value of many intangibles (e.g., goodwill, patents, and brands) may require unverifiable estimates of future risks.”

The problem is that ‘soft’ information is becoming the focus of corporate reporting because of coincident increase in hard information reporting. And worse, unmentioned in the article, that ‘soft’ information is now also a matter of corporate taxation systems (e.g. Ireland’s ‘Knowledge Development Box’ tax scheme). In other words, gamable metrics are now throughly polluting markets information flows, taxation mechanisms and policy making environment.

Per interview, there is a “tradeoff between reliability and the relevance of the information” that represents “a big dilemma among standard setters, who I think are feeling pressure to change the accounting system in a way that provides more information.”

Which, everyone thinks, is a good thing. But it may be exactly the opposite.

“One of the main results — and it’s a very intuitive one — shows that when markets don’t trust firms, we will tend to see a shift toward financial statements becoming harder and harder. [and] …a firm that proportionally provides more hard information is more likely to manipulate whatever soft information it does provide. In other words, you should be more wary about the soft information of a firm that is providing a lot of hard information.”

Again, best to look at the actual paper to gain better insight into what Marinovic is saying here.

Quoting from the paper: “...a manager who is more likely to misreport is more willing to verify and release hard information, even though issuing hard information reduces her ability to manipulate. To explain this key property of our model, we reiterate that not all information can be made hard. Hence, what managers lose in terms of discretion to over-report the verifiable information, they can gain in credibility for the remaining soft disclosure. Untruthful managers will tend to issue higher soft reports, naturally facing stronger market skepticism. We demonstrate that untruthful managers are always more willing to issue hard information, relative to truthful managers."

Key insight: "...situations in which managers release more hard information are also more likely to feature aggressive soft reports and have a greater likelihood of issuing overstatements.”

As the result, as noted in the interview, “…we should expect huge frauds, huge overstatements precisely in settings or markets where there is a lot of credibility. The markets believe the information because they perceive the environment as credible, which encourages more aggressive manipulations from dishonest managers who know they are trusted. In other words, there is a relationship between the frequency and magnitude of frauds, where a lower frequency should lead to a larger magnitude.”

In other words, when markets are complacent about information disclosed and/or markets have greater trust in the disclosures mandates (high regulation barrier), information can be of lower quality and/or risk of large fraud cases rises. While this is intuitive, the end game here is not as clear cut: heavily regulating information flows might be not necessarily a productive response because markets trust has a significant positive value.

Let’s dip into the original paper once again, for more exposition on this paradox: “We consider the consequence of reducing the amount of discretion in the reporting of any verifiable information. The mandatory disclosure of hard information has the unintended consequence of reducing information about the soft, unverifiable components of firm value. In other words, there is a trade-off between the quality of hard versus soft information. Regulation cannot increase the social provision of one without reducing the other.”

Now, take European banks (U.S. banks face much of the same). Under the unified supervision by the ECB within the European Banking Union framework, banks are required to report increasingly more and more hard information. In Bertomeu-Marinovic model this can result in reduced incidence of smaller fraud cases and increased frequency and magnitude of large fraud cases. Which will compound the systemic risks within the financial sector (small frauds are non-systemic; large ones are). The very disclosure requirement mechanism designed to reduce large fraud cases can mis-fire by producing more systemic cases.

In its core, Jeremy Bertomeu and Ivan Marinovic paper shows that “certain soft disclosures may contain as much information as hard disclosures, and we establish that: (a) exclusive reliance on soft disclosures tends to convey bad news, (b) credibility is greater when unfavorable information is reported and (c) misreporting is more likely when soft information is issued jointly with hard information. We also show that a soft report that is seemingly unbiased in expectation need not indicate truthful reporting.”

So here is a kicker: “We demonstrate that …the aggregation of hard with soft information will turn all information soft.” In other words, soft information tends to fully cancel out hard information, when both types of information are present in the same report.

Now, give this a thought: many sectors today (think ICT et al) are full of soft information reporting and soft metrics targeting. Which, in Bertomeu-Marinovic model renders all information, including hard corporate finance metrics, reported by these sectors effectively soft (non-verifiable). This, in turn, puts into question all pricing frameworks based on corporate finance information whenever they apply to these sectors and companies.



References for the above are:

The Interview with Marinovic can be read here: https://www.gsb.stanford.edu/insights/financial-disclosures-not-all-information-equal.

Peer reviewed publication (gated version) of the paper is here: http://www.gsb.stanford.edu/faculty-research/publications/theory-hard-soft-information

Open source publication is here: Bertomeu, Jeremy and Marinovic, Ivan, A Theory of Hard and Soft Information (March 16, 2015). Accounting Review, Forthcoming; Rock Center for Corporate Governance at Stanford University Working Paper No. 194: http://ssrn.com/abstract=2497613.

18/7/16: Euromoney on Brexit

My comment for Euromoney on the topic of Brexit impact on UK sovereign credit risks: http://www.euromoney.com/Article/3563119/Country-risk-Experts-say-UK-economy-will-quickly-recover-from-Brexit-shock.html.

18/7/16: Stock Markets Crashes: 1955-2015

A good summary of all stock markets crashes since 1955 through 2015 via Goldman Sachs:

The caption to the chart says it all.

18/6/16: Brexit, U.S. Elections & State of Discontent

My interview with ItalVideoNews’ Concetto La Malfa about Brexit and the US Elections:
https://alternativeeconomics.co/tubeline/#/view/PuaUax7A1sc.

17/6/16: Credit markets on the ropes?

In their research note, titled aptly “Credit Metrics Bode 1ll”, Moody’s Analytics produced a rather strong warning to the corporate credit markets, a warning that investors should not ignore.

Per Moody’s: “The current business cycle upturn is in its latter stage, aggregate measures of corporate credit quality suggest. The outlook for the credit cycle is likely to deteriorate, barring improved showings by cash flows and profits, where enhanced prospects for the latter two metrics depend largely on a sufficient rejuvenation of business sales.”

In other words, unless corporate performance trends break to the upside, credit markets will push into a recessionary territory.

“Recessions materialized within 12 months of the year-long ratio of internal funds to corporate debt descending to 19.1% i n Ql -2008, Ql-2000, and Q4-1989. As derived from the Federal Reserve's Financial Accounts of the United States, or the Flow of Funds, the moving year long ratio of internal funds to corporate debt for US non-financial corporations has eased from Q2-2011's current cycle high of 25.4% to the 19.1% of Ql-2016.”

Moody’s illustrate:

Now, observe the ratio over the current cycle: the peak around the end of 2011-start of 2012 has now been fully and firmly exhausted. Current ratios sit dangerously at 4Q 2007 and close to 1-3 quarters distance from each previous recession troughs.

The safety cushion available to the U.S. corporates when it comes to avoiding a profit recession is thin. Per Moody’s: “The prospective slide by the ratio of internal funds to corporate debt underscores how very critical rejuvenations of profits and cash flows are to the outlooks for business activity and credit quality. Getting profits up to a speed that will keep the US safely distanced from a recession has been rendered more difficult by the current pace of employment costs."

Here’s the problem. Employment costs can be cut back to improve profitability in a normal cycle. The bigger the cut back, the more cushion it provides. But in the current cycle, employment costs are subdued (do notice that this environment - of slower wages and costs inflation - is the same as in 2004-2007 period). Which means two things:

1. U.S. corporates have little room to cut employment costs except by a massive wave of layoffs (which can trigger a recession on its own); and
2. U.S. corporates have already front-loaded most of the risk onto employment costs during the Great Recession. Which means any new adjustment is going to be even more painful as it will come against already severe cuts inherited from the Great Recession and only partially corrected for during the relatively weak costs recovery period since then. 

Moody’s are pretty somber on the prospect: "As inferred from the historical record, restoring profits through reduced labor costs is all but impossible without the pain of a recessionary surge in layoffs. Thus, barring a recession, employment costs should continue to expand by at least 5% annually."

That’s the proverbial the rock and the hard place, between which the credit markets are wedged, as evidenced by the recent dynamics for both Corporate Gross Value Added (the GDP contribution from the corporate sector) and the nominal GDP:

Again, the two lines show steady downward trend in corporate performance (Corporate GVA) and slight downward trend in nominal GDP. In terms of previous recessions, sharp acceleration in both trends since the end of 4Q 2014 is now long enough and strong enough to put the U.S. onto recessionary alert.

Per Moody’s: "As of early June, the Blue Chip consensus projected a 3.2% annual rise by 2016's nominal GDP that, …signals a less than 3% increase by corporate gross value added. [This]... implies a drop by 2016's profits from current production that is considerably deeper than the - 2.5% dip predicted by early June's consensus. Moreover, as inferred from the consensus forecast of a 4.4% increase by 2017's nominal GDP, net revenue growth may not be rapid enough to stabilize profits until the second-half of 2017, which may prove to be too late for the purpose of avoid ing a cyclical downturn."

In other words, there is a storm brewing in the U.S. economy and the credit markets are exhibiting stress consistent with normal pre-recessionary risks. Which is, of course, somewhat ironic, given that debt issuance is still booming, both in the USD and Euro (a new market of choice for a number of U.S. companies issuance in response to the ECB corporate debt purchasing programme):

Just as the corporate credit quality is deteriorating rapidly:

You really can’t make this up: the debt cornucopia is rolling on just as the debt market is flashing red.

17/6/16: Forget Brexit. Think EUrisis

Swedish research institute, Timbro, published their report covering the rise of political populism in Europe. And it makes for a sobering reading.

Quoting from the report:

“Never before have populist parties had as strong support throughout Europe as they do today. On average a fifth of all European voters now vote for a left-wing or right-wing populist party. The voter demand for populism has increased steadily since the millennium shift all across Europe.”

Personally, I don’t think this is reflective of the voter demand for populism, but rather lack of supply of pragmatic voter-representing leadership anywhere near the statist political Centre. After decades of devolution of ethics and decision-making to narrow groups or sub-strata of technocrats - a process embodied by the EU systems, but also present at the national levels - European voters no longer see a tangible connection between themselves (the governed) and those who lead them (the governors). The Global Financial Crisis and subsequent Great Recession, accompanied by the Sovereign Debt Crisis and culminating (to-date) in the Refugees Crisis, all have exposed the cartel-like nature of the corporatist systems in Europe (and increasingly also outside Europe, including the U.S.). Modern media spread the information like forest fire spreads ambers, resulting in amplified rend toward discontent.

Again, per Timbro:
“No single country is clearly going against the stream. 2015 was the most successful year so far for populist parties and consistent polls show that right-wing populist parties have grown significantly as a result of the 2015 refugee crisis. So far this year left-wing or right-wing populist parties have been successful in parliamentary elections in Slovakia, Ireland, Serbia, and Cyprus, in a presidential election in Austria and in regional elections in Germany. A growing number of populist parties are also succeeding in translating voter demand into political influence. Today, populist parties are represented in the governments of nine European countries and act as parliamentary support in another two.”

Net: “…one third of the governments of Europe are constituted by or dependent on populist parties.”

And the direction of this trend toward greater populism in European politics is quite astonishing. Per Timbro, “discussions on populism too often focus only on rightwing populism. Practically everything written on populism, at least outside Southern Europe, is almost entirely concerned with right-wing populism. Within the political sciences the study of right-wing populist parties has even become its own field of study, while studies on leftwing populism are rare.”

This skew in reporting and analysis, however, is false: while “…it is the right-wing populism that has grown most notably, particularly in Scandinavia and Northern Europe. However, in Southern Europe the situation is the opposite. If the goal is to safeguard the core values and institutions of liberal democracy we need a parallel focus on those who challenge it, regardless of whether they come from the right or the left. It is seriously worrying that seven per cent of the population in Greece vote for
a Nazi party, but it is also worrying that five per cent vote for a Stalinist one. The second aim of this report is therefore to present an overview of the threat of populism, both right-wing and left-wing, against liberal democracy.”

Here are some trends:

The chart above shows that authoritarian left politics are showing a strong trend up from 2010 through 2014, with some moderation in 2015, which might be driven more by the electoral cycle, rather than by a potential change in the trend. The moderation in 2015, however, is not present in data for right wing authoritarianism:

So total support for authoritarian parties is up, a trend present since 2000 and reflective of the timing that is more consistent with the introduction of the euro and subsequent EU enlargements. An entirely new stage of increase in authoritarianism tendencies was recorded in 2015 compared to 2014.

Save for the correction downward in 2007-2009 period, authoritarian parties have been on an increasing power trend since roughly 1990, with renewed upward momentum from 1999.

You can read the full study and reference the study definitions and methodologies here: http://timbro.se/sites/timbro.se/files/files/reports/4_rapport_populismindex_eng_0.pdf.


What we are witnessing in the above trends is continuation of a long-running theme: the backlash by the voters, increasingly of younger demographics, against the status quo regime of narrow elites. Yes, this reality does coincide with economic inequality debates and with economic disruptions that made life of tens of millions of Europeans less palatable than before. But no, this is not a reaction to the economic crisis. Rather, it is a reaction to the social, ideological and ethical vacuum that is fully consistent with the technocratic system of governance, where values are being displaced by legal and regulatory rules, and where engineered socio-economic system become more stressed and more fragile as risks mount due to the technocratic obsession with… well… technocracy as a solution for every ill.

While the EU has been navel gazing about the need for addressing the democratic deficit, the disease of corporatism has spread so extensively that simply re-jigging existent institutions (giving more power to the EU Parliament and/or increasing member states’ voice in decision making and/or imposing robust checks and balances on the Commission, the Eurogroup and the Council) at this stage will amount to nothing more than applying plasters to the through-the-abdomen gunshot wound. Brexit or not, the EU is rapidly heading for the point of no return, where any reforms, no matter how structurally sound they might be, will not be enough to reverse the electoral momentum.

For those of us, who do think united Europe can be, at least in theory, a good thing, time is to wake up. Now. And not to oppose Brexit and similar movements, but to design a mechanism to prevent them by re-enfranchising real people into political decision making institutions.

13/6/16: Twin Tech Challenge to Traditional Banks

My article for the International Banker looking at the fintech and cybercrime disruption threats to traditional banking models is out.

The long-term fallout from the 2008 global financial crisis created several deep fractures in traditional-banking models. Most of the sectoral attention today has focused on weak operating profits and balance-sheet performance, especially the risks arising from the negative-rates environment and the collapse in yields on traditional assets, such as highly rated sovereign and corporate debt. Second-tier concerns in boardrooms and amidst C-level executives relate to the continuously evolving regulatory and supervisory pressures and rising associated costs. Finally, the anemic dynamics of the global economic recovery are also seen as a key risk to traditional banks’ profitability.

However, from the longer-term perspective, the real risks to the universal banks’ well-established business model come from an entirely distinct direction: the digital-disruption channels that simultaneously put pressure on big banks’ core earnings lines and create ample opportunities for undermining the banking sector’s key unique selling proposition—that is, security of customer funds, data and transactions, and by corollary, enhancing customer loyalty. These channels are FinTech innovations—including rising data intensity of products on offer and technological threats, such as rising risks to cybersecurity. This two-pronged challenge is not unique to the banking sector, but its disruptive potential is a challenge that today’s traditional banking institutions are neither equipped to address nor fully enabled to grasp.

Read more here: Gurdgiev, Constantin, Is the Rise of Financial Digital Disruptors Knocking Traditional Banks Off the Track? (June 13, 2016). International Banker, June 2016. Available at SSRN: http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2795113.

12/6/16: Few Thoughts on Anglo Trial Verdicts

A friend recently did me a small service by summing up my comments on twitter on the Anglo Irish Bank - Irish Life & Permanent roundabout loans verdict:

I have provided an expert testimony on the matter in April in a court case involving the Central Bank, the Department of Finance and the Attorney General of Ireland, focusing precisely on the nature of the relationship between the Irish Financial Regulation authorities and the misconduct by banks and banks boards prior to 2008 Global Financial Crisis.  Quoting from my expert opinion:

"Part 4: Regulatory enforcement effectiveness and efficiency

46. In my opinion, and based on literature referenced herein, objectives of the function of enforcement in financial regulation are best served by structuring enforcement processes and taking robust actions so as to:
1. Target first and foremost the core breaches of regulatory and supervisory regimes, starting with systemic-level breaches prior to proceeding to specific institutional or individual level infringements [Targeting];
2. Timely execute enforcement actions, both in the context of market participants’ timing and timing relevant to the efficiency and effectiveness of uncovering the actual facts of specific alleged infringements [Timely execution];
3. Prevent or at the very least reduce, monitor and address any potential conflicts of interest in enforcement-related actions [Conflict of interest minimisation];
4. Assure that enforcement actions are taken within the constraints of the regulatory regime applicable at the time of alleged committing of regulatory breaches, while following well-defined and ex ante transparent processes [Applicability and quality of regulation and enforcement];

5. Assure that regulatory enforcement actions do not contradict or duplicate other forms of enforcement and remedial measures, including legal settlements [Consistency of legal and administrative frameworks]."

In simple terms, systemic lack of imposition of meaningful sanctions on senior policy, regulatory and supervisory decision-makers active in the Irish financial services in the period prior to the Global Financial Crisis severely undermines the signalling and deterrence functions of regulatory enforcements. Convicting bankers for mis-deeds is fine, but not sanctioning regulatory and supervisory officials is not conducive to establishing any tangible credibility to the regulatory enforcement regime. Worse, it establishes a false sense of security that the system has been repaired and strengthened by convictions achieved, whilst in reality, the system remains vulnerable to exactly the same dynamics and risks of collusion between regulators and supervisors and the new financial services executives.

It is, perhaps, telling that my counterparts providing expert opinions in the case on behalf of the Central Bank, Department of Finance and the Attorney General of Ireland have based their analysis on the axiomatic assumption that no regulatory, supervisory and enforcement staff can ever be held liable for their actions or inactions in the events and processes that led to the Global Financial Crisis. No matter what they have done or refused to do. Full impunity must apply.