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11 08, 2023

Reuters, Friday, August 11, 2023

2023-08-11T16:15:52-04:00August 11th, 2023|Press Clips|

SVB’s failure has led US regulators to see higher capital as solution to future crises

The failure of Silicon Valley Bank and a few others has led regulators to swing the pendulum too far toward more draconian capital solutions. U.S. bank regulators recently unveiled sweeping proposals to raise capital for the country’s largest banks by around 16%, or about $200 billion. The proposed capital charges stunned many in the banking industry and prompted dissent among policymakers at the U.S. Federal Reserve and the Federal Deposit Insurance Corporation (FDIC) — something one rarely sees….The question that emerges is why such draconian capital charges are needed when regulators have long said that the U.S. banking system is resilient and well-capitalized. “The banking agencies are in the same bind parents are with their children,” said Karen Petrou, managing partner of Federal Financial Analytics, a Washington, D.C. consultancy. “They want to tell the world how clever their kids are so no one thinks the kid is at-risk or the parent is neglectful. But, at home, they demand lots more homework and far better grades. The agencies’ rhetorical dance results from their desire to reassure financial markets yet chastise banks.”

https://www.thomsonreuters.com/en-us/posts/investigation-fraud-and-risk/svbs-failure-future-crises/

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11 08, 2023

FedFin on : Stablecoin/Tokenization Activities

2023-08-11T16:25:47-04:00August 11th, 2023|The Vault|

In conjunction with issuing a new supervisory policy for “novel” activities, the FRB has instituted a new process requiring non-objection letters before state member banks proceed with stablecoin or dollar-tokenization activities.  Although the new non-objection process makes it clear that Fed approval will require clear adherence to a raft of policy and legal obligations, the non-objection process clears the way for state member banks to offer products with a growing role in retail and wholesale payment, settlement, and clearing activities.

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

10 08, 2023

FedFin on: 9th Inning Results

2023-08-11T16:25:22-04:00August 10th, 2023|The Vault|

FHFA today released the results of the ninth stress test it’s run on Fannie and Freddie since Dodd-Frank demanded this in 2010.  Using pretty much the same flawed models as the Fed, FHFA finds Fannie and Freddie pretty much as they are even under acute stress.

The full report is available to subscription clients. To find out how you can sign up for the service, click here.…

10 08, 2023

FedFin on: Operational Risk-Based Capital Standards

2023-08-11T16:25:34-04:00August 10th, 2023|The Vault|

Noting that operational risk is present at all banks due to most activities, the U.S. regulatory-capital rewrite would end the current approach to operational risk-based capital (ORBC).  This now subjects only categories I and II banks to ORBC and then only to the advanced measurement approach (AMA) premised on each bank’s internal models.  Consistent with the overall decision to end internal-model reliance, this section of the proposal subjects categories I, II, III, and IV banks to a new operational-risk standardized approach (SA).  This would result in very steep capital requirements based on a bank’s experience over the past ten years compared to various sources of revenue over the past three years, perhaps taking business-model changes over the course of the last three years into account if regulatory standards are met for doing so….

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

8 08, 2023

FedFin on: Say It’s Simple

2023-08-09T14:19:41-04:00August 8th, 2023|The Vault|

Our most recent analysis of the inter-agency capital proposal focuses on significant changes to the rules for securitization and credit-risk transfer positions. In short, super-traditional securitizations have an easier path to the secondary market, but GSEs still beat banks. Complex ABS face often-formidable obstacles, as does CRT given or taken by banks.

The full report is available to subscription clients. To find out how you can sign up for the service, click here.…

8 08, 2023

FedFin on: Equity and Securitization Capital Standards

2023-08-08T13:44:33-04:00August 8th, 2023|The Vault|

Based on our analysis of the inter-agency capital proposal’s framework and its credit-risk provisions, FedFin turns now to the proposed approach to equities as well as to that for securitization exposures (i.e., those that are tranched rather than simple secondary-market issuances of packages of loans or other assets backed as needed by a single credit enhancement). The proposal in some cases liberalizes the current, “general” standardized approach (SA), but more often toughens it to account for elimination of the advanced approach…

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

4 08, 2023

FedFin on: Credit-Risk Capital Rewrite

2023-08-04T13:41:04-04:00August 4th, 2023|The Vault|

In this report, we proceed from our assessment of the proposed regulatory capital framework to an analysis of the rules governing credit risk.  In addition to eliminating the advanced approach, the proposal imposes higher standards for some assets than under the old standardized approach (SA) via new “expanded” requirements.  As detailed here, many expanded risk weightings are higher than current requirements either due to specific risk-weighted assessments (RWAs) or definitions and additional restrictions.  This contributes to the added capital costs identified by the banking agencies in their impact assessment, suggesting that lower risk weightings in the expanded approach reflected the reduced risks described in the proposal for other assets and will ultimately have little bearing on regulatory-capital requirements and thus ….

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

3 08, 2023

FedFin on: Hugging Home Loan Banks

2023-08-03T16:55:11-04:00August 3rd, 2023|The Vault|

As we plow on with our in-depth analysis of the new capital proposal, we will continue to advise of key provisions in the massive rewrite with important implications for residential-mortgage finance. Late last week, we looked at the overall treatment of mortgage assets, with more to come as we parse how the mortgage-specific capital rules fit into the incentives created by the proposal as a whole….

The full report is available to subscription clients. To find out how you can sign up for the service, click here.…

1 08, 2023

FedFin on: U.S. Regulatory-Capital Rewrite: Framework

2023-08-02T12:18:58-04:00August 1st, 2023|The Vault|

In this in-depth report, we begin our analysis of the 1089-page capital proposal released by the U.S. banking agencies not only to make U.S. standards more consistent with Basel’s 2017  “end-game” rules, but also to correct failings in the current capital framework the agencies believed were laid bare by recent bank failures. The new standards rewrite the 2019 “tailoring” rule with regard to application of the toughest capital standards, now covering all BHCs with assets over $100 billion along with their insured depository institutions (IDIs) regardless of size. For smaller BHCs, the most significant impact of the new approach requires recognition of …

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

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