본문 바로가기
Writing

폴 크루그먼, 누리엘 루비니 교수의 미국경제비판

by 『Nero』 2009. 5. 9.

Paul Krugman

Stressing the Positive 


In the end, the actual release of the much-hyped bank stress tests on Thursday came as an anticlimax. Everyone knew more or less what the results would say: some big players need to raise more capital, but over all, the kids, I mean the banks, are all right. Even before the results were announced, Tim Geithner, the Treasury secretary, told us they would be "reassuring." 

But whether you actually should feel reassured depends on who you are: a banker, or someone trying to make a living in another profession. 

I won't weigh in on the debate over the quality of the stress tests themselves, except to repeat what many observers have noted: the regulators didn't have the resources to make a really careful assessment of the banks' assets, and in any case they allowed the banks to bargain over what the results would say. A rigorous audit it wasn't. 

But focusing on the process can distract from the larger picture. What we're really seeing here is a decision on the part of President Obama and his officials to muddle through the financial crisis, hoping that the banks can earn their way back to health. 

It's a strategy that might work. After all, right now the banks are lending at high interest rates, while paying virtually no interest on their (government-insured) deposits. Given enough time, the banks could be flush again. 

But it's important to see the strategy for what it is and to understand the risks. 

Remember, it was the markets, not the government, that in effect declared the banks undercapitalized. And while market indicators of distrust in banks, like the interest rates on bank bonds and the prices of bank credit-default swaps, have fallen somewhat in recent weeks, they're still at levels that would have been considered inconceivable before the crisis. 

As a result, the odds are that the financial system won't function normally until the crucial players get much stronger financially than they are now. Yet the Obama administration has decided not to do anything dramatic to recapitalize the banks. 

Can the economy recover even with weak banks? Maybe. Banks won't be expanding credit any time soon, but government-backed lenders have stepped in to fill the gap. The Federal Reserve has expanded its credit by $1.2 trillion over the past year; Fannie Mae and Freddie Mac have become the principal sources of mortgage finance. So maybe we can let the economy fix the banks instead of the other way around. 

But there are many things that could go wrong. 
It's not at all clear that credit from the Fed, Fannie and Freddie can fully substitute for a healthy banking system. If it can't, the muddle-through strategy will turn out to be a recipe for a prolonged, Japanese-style era of high unemployment and weak growth. 

Actually, a multiyear period of economic weakness looks likely in any case. The economy may no longer be plunging, but it's very hard to see where a real recovery will come from. And if the economy does stay depressed for a long time, banks will be in much bigger trouble than the stress tests - which looked only two years ahead - are able to capture. 

Finally, given the possibility of bigger losses in the future, the government's evident unwillingness either to own banks or let them fail creates a heads-they-win-tails-we-lose situation. If all goes well, the bankers will win big. If the current strategy fails, taxpayers will be forced to pay for another bailout. 

But what worries me most about the way policy is going isn't any of these things. It's my sense that the prospects for fundamental financial reform are fading. 

Does anyone remember the case of H. Rodgin Cohen, a prominent New York lawyer whom The Times has described as a "Wall Street éminence grise"? He briefly made the news in March when he reportedly withdrew his name after being considered a top pick for deputy Treasury secretary. 

Well, earlier this week, Mr. Cohen told an audience that the future of Wall Street won't be very different from its recent past, declaring, "I am far from convinced there was something inherently wrong with the system." Hey, that little thing about causing the worst global slump since the Great Depression? Never mind. 

Those are frightening words. They suggest that while the Federal Reserve and the Obama administration continue to insist that they're committed to tighter financial regulation and greater oversight, Wall Street insiders are taking the mildness of bank policy so far as a sign that they'll soon be able to go back to playing the same games as before. 

So as I said, while bankers may find the results of the stress tests "reassuring," the rest of us should be very, very afraid. 


Nouriel Roubini

Ten Reasons Why the Stress Tests Are "Schmess" Tests and Why the Current Muddle-Through Approach to the Banking Crisis May Not Succeed 

What shall we make of the recently announced results of the stress test? Are they credible? Will they restore confidence in our battered financial system? Will the current approach to resolving the financial crisis work, be effective and minimize the fiscal costs of the financial bailout? 

For a number of reasons these results are a significant underestimate of the capital/equity needs of these 19 large US banks. Also this underestimate of the losses and the current "muddle-through" approach to the banking and financial crisis may accelerate the creeping partial nationalization of the US financial system, exacerbate moral hazard distortions, not resolve the too-big-to-fail problem, increase the fiscal costs of this financial crisis, make the credit crunch last longer and lead some near insolvent financial institutions to become zombie banks. Let me explain in ten points why I hold such views (see also my two recent op-eds with Matt Richardson in the WSJ and the FT): 

First, the stress tests are not stressful enough. As discussed in a previous note current levels of unemployment rates are already higher than those assumed in the more adverse scenario; and even assuming that the rate of job losses will slow down over the next few months to a 400-500K monthly range it is highly likely that the US will reach an unemployment rate of 10% by the fall of 2009, a rate of 10.5% by the end of 2009 and a rate above 11% some time in 2010; instead the parameters of the stress tests assumed that the unemployment rate would average 10.3% in the more adverse scenario in 2010, not 2009. Note also that the parameters for the more adverse scenario in the stress tests were a political compromise among the agencies involved in the stress tests; one of these agencies had found more realistic the hypothesis that the parameter for the unemployment rate in the more adverse scenario should be 12% rather than 10.3%. Moreover, the stress tests found that the 19 banks needed $185 bn of additional equity; the published figure of $75 is based on assets dispositions and capital raises of $110 bn that are still under way and, in most cases, not completed yet. Booking such increases in equity before they have occurred does not seem appropriate accounting procedure. 

Second, the capital/needs of these banks depend on a race between retained earnings before writedowns/provisioning that will be positive given a high net interest rate margin and the losses deriving from further writedowns. It appears that regulators have overestimated the amount of such retained earnings for 2009-2010. The IMF recently estimated that retained earnings (after taxes and dividends) for all US banks - not just these 19 ones - would be only $300 bn total over the 2009-2010 period. The stress tests - instead - assumed much higher retained earnings - $362 bn - for these 19 banks alone for the 2009-2010 period in the more adverse scenario. Since these 19 banks account for about half of US banks assets if one were to use the IMF estimate of net retained earnings for these 19 banks their net retained earnings for 2009-2010 would be $150 bn rather than the $362 bn assumed by the regulators. While the IMF may have been too conservative in its estimates of net retained earnings it appears that regulators may have been too generous to these 19 banks in forecasting their earnings in an adverse scenario. Thus, ex-post capital needs will be significantly higher if net retained earnings turn out to be lower than assumed in the stress tests. While regulators resisted the banks' attempt to use Q1 earnings (that were fudged via under-provisioning for loan losses, paper gains on securities via changes in FASB rules on mark-to-market, and accounting gains coming from the lower market value of bank liabilities) as proxy for the future profitability of banks it appears that such regulators were too optimistic in estimating what net retained earnings will be in 2009-2010. 

Third, banks bargained hard to reduce the regulators estimates of needed additional equity. For example, according to press reports Citigroup was initially assessed to need an additional $30bn of equity; such figure was then reduced to $5 billion after aggressive bargaining by the bank. One can only guess how much higher were the regulators initial estimates of the banks' capital needs and how much lower the published estimates became after the banks lobbied for lower figures. 

Fourth, the estimates of additional losses on loans - $445 bn - appear to be relatively reasonable even if they could end up being significantly higher in a weaker macro scenario. But estimates of losses on securities - $154bn - are most likely too low. And the results of the stress scenario do not provide details on how much regulatory forbearance has been provided in the estimate of losses on securities; while current market values of some securities may be lower than long term values given an illiquidity premium many banks still keep many of these securities in the level 2 and 3 buckets and use a mark-to-model, rather than a mark-to-market approach to value these assets. Certainly in the last year regulators have been lenient and provided plenty of forbearance - on top of expensive formal guarantees of hundreds of billions of toxic assets for several banks - to reduce the amount of revealed losses on securities. Also, if one were to bring forward to today the writedowns/charge-offs for 2009-2010 estimated by the US regulators (an exercise that the IMF has done for all US banks in its recent Global Financial Stability Report) the TCE ratio for these 19 banks - and all US banks - would be effectively 0.1% today. So, the US regulators estimates of equity needs of these 19 banks are heavily depended on what net earnings before writedowns will be in 2009-2010. 

Fifth, estimates of net retained earnings before writedowns are massively beefed up by the direct and indirect subsidies that the government is providing to the financial system: with the Fed Funds rate and deposit rates now close to 0% and with banks having been able to borrow since last year about $350 bn at close to 0% interest rates given the FDIC guarantee on new borrowings the bank can now earn a fat net interest rate margin that is a direct subsidy to financial institutions. The Fed is also losing a fortune on its three Maiden Lane funds that purchased toxic assets of Bear Stearns and AIG. On top of this major US financial institutions got a massive direct subsidy from the bailout of AIG. Overall, the US government has committed - between liquidity supports, recapitalization, insurance of bad assets, guarantees - over $13 trillion of resources to the financial system and already provided $3 trillion of such resources to the financial institutions. The financial system is already effectively a ward of the state in spite of the fact that all these direct and indirect subsidies have bailed out both the shareholders and the unsecured creditors of financial institutions. Even taking into account the fact that not all of these resources will represent a net long term loss to the US taxpayer even a conservative estimate of the net subsidy to the banks' shareholders and unsecured creditors may be above $500 bn. 

Sixth, in estimating equity needs of these 19 banks the regulators correctly used a measure of capital - Tangible Common Equity or TCE - that is narrower than Tier 1. Tier 1 capital includes many forms of capital - on top of tangible common equity - that are of poor quality as a buffer against losses or outright fishy: preferred equity and in particular intangible assets and goodwill. While Tier 1 capital of US banks was - at the end of 2008 - about $1,550 common tangible equity was only about $560 bn. The regulators estimated equity needs of the 19 banks based on a TCE ratio of 4% (as a percent of tangible assets). However, even 4% implies a leverage ratio for these banks of 25. The IMF instead - properly - considered a scenario where the TCE ratio is increased to 6% that is equivalent to a leverage ratio of 17 that represent the average leverage ratio for all US banks in the mid-1990s before leveraged shot up in the latest credit bubble. A capital adequacy ratio is also certainly necessary for these banks as they are systemically important: every academic analysis of systemic risk suggests that banks that are systemically important should have much higher capital in order to internalize the externalities deriving from too-big-to-fail distortions. And while Basel criteria for capital adequacy have not been yet revised to include this need for additional capital for too-big-to-fail banks the G20 and the FSF have already acknowledge the need to charge more capital for such large institutions. 

Indeed, some national regulators have already moved to increase the capital required from their own banks: for example Switzerland has already unilateral imposed a 16% capital ratio for its systemically important banks to be phased in by 2013, a ratio that is double the Basel criteria of 8% for Tier 1 and Tier 2. Thus, it would have been appropriate that US regulators request that these 19 banks - that are all deemed to be systemically important - should aim to achieve a TCE ratio of at least 6% - not 4% - equal to the one prevailing in the mid-1990s for all US banks (not just the systemically important ones). The capital needs of all US banks would have been an additional $225 bn (based on IMF estimates) if the TCE ratio were to be increased from 4% to 6%. For these 19 banks a 6% TCE ratio - the minimum justifiable for systemically important institutions - would imply about an additional $100 bn of common equity compared to the estimates of the regulators. 

Seventh, considering even only the need for a higher TCE ratio for too-big-to-fail banks - let alone the implications of other factor discussed above that would have increased the estimates of capital needs for US banks - all 19 banks would have required higher TCE. Giving a clean bill of financial health to half a dozen too-big-to-fail banks - including JP Morgan Chase and Goldman Sachs - that have survived this financial crisis only because of the massive direct and indirect subsidies received from the US government is a public disservice in two ways: first, it does not recognize that these banks survived the crisis only because of the government subsidies (liquidity, insurance, guarantees, recapitalization); second, it ignores the fundamental fact that too-big-to-fail banks should have much more tangible common equity than the one that they currently hold. It is reckless behavior by regulators to ignore the too-big-to-fail distortion that derives from excessively low capital ratios and not to start demanding from such systemically important banks additional capital to control for this negative externality. 

Indeed, the problem with the current approach to the financial crisis is that the too-big-to-fail problem has become an even-bigger-to-fail problem and that moral hazard distortions from government bailouts have been sharply increased via trillions of dollars committed to backstop the financial system. First, while some significant support of the financial system was necessary and desirable to stop bank runs, reduce serious refinancing risks and avoid a more severe credit crunch the extent of the support and subsidy of the financial system has created the mother of all moral hazard distortions. Second, the current approach to crisis resolution has led to an even-bigger-to-fail problem because of the government inducing relatively less weak institutions to take over weaker ones. JP Morgan took over Bear Stearns and then WaMu; Bank of America took over Countrywide and then Merrill Lynch; and Wells Fargo took over Wachovia. And in the battle for Wachovia Citigroup aggressively fought Wells Fargo not because Wachovia was a sound banks (it was indeed insolvent and bust); it did so because taking over Wachovia would have made a too-big-to-fail Citi an even-bigger-to-fail bank with greater likelihood of government bailout. To put two weak - or near-zombie - banks together is like having two drunks trying to hold each other to stand straight. To resolve this even-bigger-to-fail problem a strategy of taking over near-insolvent institutions and then break them up in smaller, systemically-not-important pieces would have been appropriate. Alternatively, charging much higher capital ratios on too-big-to-fail banks - as optimal according to economic theory - would incentivize them to break themselves up in smaller pieces. But neither approach has been so far followed by US policy makers; and we have thus created the mother of all moral-hazard driven bailout distortions. 

Eighth, the figures published by the US regulators are estimates of losses and capital/equity needs of the top 19 banks (those with assets above $100bn). Smaller US banks will have similar losses and capital needs. Based on the results of the stress tests some bank analysts have estimated that 60% of top 100 US banks (beyond the 19 ones in the stress tests) will need more capital/equity. Note that while large US banks (those with more than $4 billion in assets) have about 49% of their total assets into real estate assets the percentage of real estate assets for small US bank (those with assets below $4 bn) is about 63%. Thus, the losses for such smaller banks may end up being larger (as a % of their total assets) than the ones of large banks. The IMF recently estimated the additional capital needs of all US banks to be $275 bn if the TCE ratio is to increased to 4% and $500 bn if the TCE ratio has to go back to 6% (it average level for all US banks before the credit bubble of the last decade). 

Ninth, the current muddle through approach to the banking crisis is predicated on the assumption that forbearance and time will heal most wounds of most systemically important banks: generous assumptions on net retained earnings before writedowns - and hope that the economy will rapidly recover - will allow banks to earn their way out of their current massive capital shortages. But while the government will now let banks found to need more equity to raise such equity in the next six months the ability of such banks to do that will be very limited: very few private investors would want to provide capital to a bank with massive expected writedowns, large capital needs and where such private capital investments will be further significantly diluted by a government that will need to increasingly convert its preferred shares into common equity. As it is the government will already soon own 36% of Citigroup and more in the future if Citi needs much more capital and is unable to raise it from private sources. A similar fate awaits Bank of America that now needs to fill an equity gap of almost $35bn. 

Tenth, to avoid creating Japanese-style zombie large banks that are near insolvent and kept alive by trillions of dollars of government bailout support it would have been better to take different approaches that minimize the long-term government ownership or control of the financial system. There were three possible alternative approaches that made more sense. 

One option would be a temporary nationalization of such near insolvent large banks: take them over, wipe out common and preferred shareholders, have unsecured creditors take some of the losses (haircuts on their claims and/or conversion of their claims into equity), separate good and bad assets and sell a clean-up bank - possible after breaking it up to create smaller pieces that are not too big to fail - as fast as possible to the private sector. This was the strategy followed for Indy Mac that was taken over last summer by the FDIC and sold back to a group of private investors in about six months. Such temporary nationalization option is feasible and orderly even for systemically important banks as long as Congress is willing to pass soon the new insolvency regime for large financial institutions. 

A second option would be the approach favored by a number of economists of separating each troubled bank into a good bank and a bad bank and placing bad assets and unsecured claims into the bad bank while providing significant equity into the good bank to the unsecured creditors that would have losses on their bad bank claims. This solution combines separating good and bad assets and converting unsecured claims into equity and it minimizes the fiscal costs of a distressed bank resolution. 

A third option would be to induce unsecured creditors - under the threat of a receivership that becomes credible once a special insolvency regime for too-big-to -fail banks is implemented - to convert their claims into equity. Then, the bad assets of the bank can be taken off the balance sheet of the bank via the PPIP program or a number of other alternative ways to separate good and toxic assets. 

Each one of these three proposed solutions implies that unsecured creditors of banks take some losses and convert their claims into equity. Instead, the paradoxical result of the current US approach is that - in order to avoid a temporary nationalization of insolvent banks and in order to prevent unsecured creditors of banks from taking any losses - the result is a creeping and increasing partial nationalization of the financial system: the government will have to inject more preferred shares into troubled banks and convert more of its preferred shares into common equity. So, even without a temporary government takeover of the insolvent banks, we will end up with a longer-term partial government ownership of many large banks. To avoid this creeping partial nationalization inducing the banks creditors to convert their claims into equity would be a more sensible solution that minimizes the fiscal costs of the crisis, reduces the moral hazard of government bailouts and keeps more of the banking system into private hands. 

The logic of the current muddle through approach is clear (leaving aside the fact that Wall Street is still partially capturing the US regulators and policy makers): providing unlimited liquidity and deposit guarantees to avoid bank runs and refinancing risks; subsidize banks and their rebuild of capital via near zero funding rates, a steep intermediation curve and rising net interest rate margins; hope that the economy recovers faster than otherwise expected (as the green shoots are rising) so that eventual bank losses are lower; hope that forbearance and time will heal most wounds by reducing the eventual level of charge-offs and writedowns and letting bank rebuilt capital via earnings before provisions; ignore moral hazard distortions in the short run while the banking crisis is still simmering and try to reduce such distortions in the medium term with a new and better regime of supervision and regulation of financial institutions; avoid takeovers of large institutions that would be disorderly in the absence of a special insolvency regime for such large banks; avoid the risk that, even in the presence of such special insolvency regime, unintended consequences of a takeover of a large bank lead to Lehman-like consequences; hope that fiscal costs of massive subsidies and bailouts of banks are contained if a virtuous cycle of economic recovery and restoration of confidence in the financial system rapidly emerges; subsidize restoration of securitization (with the TALF) and subsidize the separation of toxic assets from the banks' balance sheet via government leverage and non-recourse loans (PPIP); avoid a more severe credit crunch via sensible supervisory and regulatory forbearance (mark-to-market suspension of FASB rules; closing regulators' eyes on the true value of loans and assets; avoid forcing banks to recapitalize too fast and let capital adequacy ratios to slip in the short run; etc.); deal with the too-big-to-fail problem only if/when the crisis is over with higher capital charges once banks can better afford them ; eventually reform the system of regulation and supervision of the financial system. 

However, the current muddle through approach of colossal regulatory forbearance and bailout of the financial system has some serious risks and shortcomings (see my two recent op-eds with Matt Richardson in the WSJ and the FT for an elaboration): it significantly increases the fiscal costs to the taxpayer of bailing out financial institutions (their shareholders and creditors); it creates the mother of all moral hazard distortions as literally trillions of dollars of financial resources have been used to backstop the financial system and bailout reckless bankers and traders and investors; it ends up with a persistent and possibly long-term government control and partial ownership of parts of the financial system; it does not resolve the too-big-to-fail problem as big banks are not broken up or given incentives to break themselves up; it risks to keep alive zombie banks leading to a more persistent credit crunch, economic stagnation, deflation and debt deflation; it leads to problems of medium term fiscal sustainability as the large fiscal cost of the bailout of the financial system creates serious public debt dynamics problems over time; it creates a serious exit strategy problem for monetary policy as the tripling of the monetary base and the central bank purchase of toxic and illiquid assets risks to eventually lead to price inflation or to another asset and credit bubble unless the massive creation of liquidity is mopped up as soon as the real economy recovers; and it may end up with a cosmetic reform of the regime of regulation and supervision of the financial system as soon as the financial crisis looks like beginning to bottoming out. 

Indeed many Wall Street voices are starting to argue that the crisis is over, that bull times are back, that they don't need further government support (while still being on the government dole in twenty different Fed/FDIC/Treasury bailout/subsidy programs/funds), that they can repay TARP money (using the $350 bn of funds that they borrowed at near 0% interest rates with a FDIC full guarantee of interest and principal), that the government should not over-regulate the financial system, that controls on bankers compensation are misguided, that no fundamental change of the financial system and of its regulation is needed. This is the self-serving chatter that we are starting to hear from the same reckless lenders, bankers and investors whose greed and wildly distorted bonus/compensation schemes - together with regulators that were asleep at the wheel and believing in self-regulation that means no regulation - caused the worst economic recession and financial crisis since the Great Depression. This is the new spin of those whose fake (as not being risk-adjusted) gains/profits/bonuses were privatized in the bubble times when fake wealth and bubble profits were created and whose trillions of dollars of losses have now been fully socialized and paid for by the taxpayer. Their arrogance is only second to their shameless Chutzpah. 

One can only hope that policy makers will resist these siren calls can and design a reform of the regime of regulation and supervision of financial institutions (more capital, less leverage, more liquidity, incentive compatible compensation with a bonus/malus system, higher capital charges to deal with - and possibly break-up - too-big-to-fail financial institutions, global regulatory standards that prevent jurisdictional arbitrage, etc.) that reduce the risk that a financial crisis of this proportion will happen again. 


----------------------

내용(뉴스기사)

크루그먼 "오바마, 금융위기 대충 지나가려 해" 

크루그먼 교수는 이날 < 뉴욕타임스(NYT) > 에 기고한 칼럼을 통해 "7일 사기극에 가까운 스트레스 테스트 결과가 마침내 발표됐지만, 그 결과가 전달하려는 의미는 알만한 사람들은 이미 다 알고 있었다. 일부 대형은행들은 자본을 확충할 필요가 있지만, 어쨌든 괜찮다는 것"이라며 "하지만 이런 결과를 보고 안심해도 좋다고 할 사람은 은행 관계자들일 것"이라고 힐난했다. 

그는 이어 "이번 스트레스 결과가 보여주는 중요한 사실은 오바마 대통령과 경제팀이 은행들이 스스로 회생하길 기대하면서 금융위기를 그럭저럭 넘기기로 결정했다는 점"이라며 오바마 정권에 직격탄을 날렸다. 

그는 향후 전망과 관련, "잘못된 방향으로 사태가 진전될 수 있다. 미연준, 패니메이, 프레디맥의 대출이 건전한 금융시스템을 충분히 대체할 수 있을지는 확실하지 않다"며 "이들이 대체물이 될 수 없다면, '대충 넘어가기 전략'은 일본 경제처럼 높은 실업률과 저성장이 장기화되는 결과를 초래할 것"이라며 90년대 일본이 경험했던 장기복합불황을 경고했다. 

그는 이어 "어떤 방식을 택하든 향후 몇 년 동안 경제는 취약한 상태가 될 가능성이 높고, 경제가 더 이상 추락하지 않더라도 진정한 경기회복을 보기는 매우 어려울 것"이라며 "경제가 장기간 저조한 상태에 처한다면 은행들은 이번 스트레스 테스트에서 상정했던 시나리오보다 훨씬 더 심각한 곤경에 처할 것"이라고 지적했다. 

그는 또한 "미국 정부가 은행들을 국유화하거나 파산하는 것을 명백히 꺼리는 방식을 취함으로써 경제 여건이 좋아지면 은행들이 이익을 취하고, 현재의 전략이 실패하면 납세자들이 또다시 공적자금을 추가 부담해야될 상황이 되고 있다"며 "오바마 정부는 금융에 대한 규제와 감독을 강화하겠다는 입장에는 변함이 없다고 강조하고 있지만, 월가 내부자들은 오바마 정부의 유화적인 금융정책을 조만간 예전과 똑같은 게임을 즐길 수 있을 것이라는 신호로 간주하고 있다"며, 오바마가 월가에 포위돼 있음을 꼬집었다. 

루비니 "은행들 결국 좀비은행 될 것" 

누리엘 루비니 뉴욕대 교수도 이날 자신의 홈페이지에 올린 장문의 글을 통해 스트레스 테스트의 10가지 문제점을 조목조목 지적하며 맹공을 퍼부었다. 

루비니 교수는 "스트레스 테스트 결과는 과연 믿을만한가"라는 물음을 던진 뒤, "너무 많은 이유에서 그 결과는 19개 대형은행들의 자본확충 필요성을 과소평가했다"고 지적했다. 그는 "손실 과소평가 및 은행-금융위기에 대한 어정쩡한 접근은 미국 금융시스템의 부분적 국유화를 가속화하면서 도덕적 해이를 심화시키고대마불사 문제를 풀지 못하면서 이번 금융위기에 대한 재정부담을 늘리고, 결국은 지금도 거의 지급불능 상태인 은행들을 '좀비은행들'로 만들 것"이라고 단언했다. 

이어 그는 스트레스 테스트의 10가지 문제점을 조목조목 지적하기 시작했는데, 가장 큰 문제점으로 지적한 것은 미 정부가 향후 경기를 지나치게 낙관적으로 전망한 뒤 이에 기초해 은행 부실들을 축소평가했다는 것이었다. 그는 구체적으로 미국 실업률이 연말에 10.5%까지 높아지고 내년엔 11%까지 높아질 것으로 전망하며, 그러나 미 정부는 이번에 실업률을 올해가 아닌 내년에 10.3%가 될 것이란 낙관적 전망아래 스트레스 테스트를 했다고 비판했다. 

그는 또 국제통화기금(IMF)이 2009~2010년 미국의 모든 은행들이 벌어들일 세후 수익을 3천억달러로 추산하고 있는 반면, 이번에 미 정부는 19개 대형은행들이 같은 기간 벌어들일 수익을 3천620억달러로 추산했다고 힐난했다. 그는 19개 대형은행이 미국 은행 전체자산의 절반가량을 차지하고 있다는 점을 감안할 경우 IMF 계산대로 하면 이들의 수익은 1천500억달러에 그칠 것이라고 덧붙였다. 

그는 더 나아가 월가의 로비로 미 정부가 필요 확충자본을 크게 축소했다고 비판하기도 했다. 그는 대표적 예로 씨티그룹을 꼽으며, 보도에 따르면 당초 씨티에 필요한 확충자본은300억달러였으나 씨티와의 협상 결과 50억달러로 축소 발표했다고 지적했다. 

루비니의 주장은 한마디로 잠재부실과 필요 확충자본은 최대한 줄이고 예상이익은 눈덩이처럼 부풀리는 방식을 통해 마치 금융위기가 끝난 양, 상황을 호도하고 있다는 지적이었다. 

과연 이들의 지적이 얼마나 적중할지는 지켜볼 일이나, 크루그먼은 1997년 한국 등 아시아 금융위기를, 루비니는 지난해 미국발 세계금융위기를 몇해 전에 정확히 예견했던 세계적 경제석학들이라는 점에서 이들의 경고를 흘려들어선 안될 것으로 보인다.