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So far William Cross has created 22 blog entries.
4 10, 2022


2022-10-05T10:38:31-04:00October 4th, 2022|4- GSE Activity Report|

The Sweet Smell of Success?

Although one witness at the FHFA listening session on the Home Loan Banks took strong issue with their mission and meaning, another who called them the “most successful program of the last hundred years” pretty much summed up today’s testimony.


3 10, 2022


2022-10-03T11:11:55-04:00October 3rd, 2022|4- GSE Activity Report|


Our take on the first two days of FHFA’s FHLB “listening session” last week is that battle lines are shaping up much as we expected with the exception of a couple of powerful groups with new ideas about how the System could be put to better use for themselves and/or the public interest.  As noted when these sessions were announced, our strategic thinking centers around what FHFA can do on its own under current law or how far it decides to stretch it.  Key questions and our forecasts for next steps follow.



27 09, 2022


2022-09-27T10:47:33-04:00September 27th, 2022|1- Financial Services Management|

Equality-Oriented Mortgage Finance

The CFPB has asked for views on the extent to which it can facilitate certain refinancing (refi) products it believes enhance economic justice.  It has also identified refi features it believes put consumers – and especially vulnerable ones – at undue risk, identifying alternative products that it believes would significantly advantage these households.  The agency is also looking to encourage or even require automatic forbearance to increase borrower protection in the event of widely shared stress or personal hardship, although it could also be costly to servicers and investors depending on how any such program is designed.


23 09, 2022


2022-09-30T12:06:31-04:00September 23rd, 2022|3- This Week|

Digital Must-Dos

Last week, we plumbed the depths of Treasury’s paradigm-shifting reports on the future of digital assets in the U.S. and thus also with regard to the dollar.  As befits reports in compliance with the President’s caustic executive order (see Client Report CRYPTO26), Treasury took a very dim view of pretty much all things digital with the signal exception of CBDC.


22 09, 2022


2022-09-22T16:38:18-04:00September 22nd, 2022|5- Client Report|

Senate Republicans Tackle Woke Banking; Democrats Turn Again to Zelle, Fees

Senate Banking’s hearing with big-bank CEOs proved much more combative than HFSC’s session yesterday (see Client Report REFORM212).  From the outset, Republican Senators condemned what they characterized as serious threats of banking politicization around social and cultural issues, with Ranking Member Toomey (R-PA) predicting a Republican counter-offensive should his party regain control.  He also said that the Fed’s decision to join other central banks and supervisors in implementing climate scenario analysis is a precursor to regulatory edicts pressuring banks to divest from energy companies.  Republicans also emphasized that high regulatory-capital requirements have undue macroeconomic effects.  As predicted, Democratic focused extensively on Zelle and bank fees.


20 09, 2022


2022-09-20T16:13:08-04:00September 20th, 2022|5- Client Report|

Senate Banking Questions Sanctions Impact

Today’s Senate Banking hearing on Russian sanctions showcased bipartisan concern that anti-Russian sanctions have yet to have meaningful impact and doubts about the extent to which oil-price caps will reverse this. Ranking Member Toomey (R-PA), joined by Sen. Van Hollen (D-MD), have thus introduced a measure to mandate secondary sanctions on financial institutions involved in a transaction with Russian oil above the price cap.


19 09, 2022


2022-09-30T12:17:17-04:00September 19th, 2022|5- Client Report|

FedFin Analysis: Treasury Presses CBDC, Nonbank Payment Powers

In this in-depth report, we follow through as promised on our initial analysis of key sections in last Friday’s Treasury report on CBDC and changes to the payment system.  In this and subsequent in-depth reports, we go beyond our focus on Treasury’s recommendations to analyze the rationale behind them and lay out our forecast for next steps.  We noted last week that the Treasury report cannot force the Fed to adopt a CBDC but clearly seeks to press the U.S. central bank quickly to undertake the policy and technology action steps necessary to achieve the numerous benefits attributed to what Treasury would consider a well-designed CBDC.



15 09, 2022


2022-09-15T16:48:41-04:00September 15th, 2022|5- Client Report|

After Senate Banking Session, SEC Stays on Course

The Senate Banking hearing with Chairman Gensler today went as expected:  Democrats generally praised his work while Republicans strongly opposed it on both substantive and procedural grounds.  As a result, we expect the chairman to continue as he has in the wake of prior, comparable hearings – pretty much as he pleases and as the rest of the commission will support.  This will clearly change if Republicans gain control of both Houses of Congress after the midterm. Unless or until it does, the SEC will continue its enforcement-focused approach to cryptoasset regulation and climate disclosures.  Chairman Brown (D-OH) also confirmed our forecast:  he will defend not only his jurisdiction, but also a much more stringent approach to crypto regulation than contemplated  by the Senate Agriculture Committee’s bipartisan legislation.


17 08, 2022


2022-08-17T11:19:44-04:00August 17th, 2022|1- Financial Services Management|

Data-Safeguard Legal/Reputational Risk

Using another of its tools to set policy without prior public comment, the CFPB has released a circular stating that inadequate consumer-data safeguards may constitute a breach of the unfair, deceptive, or abusive acts or practices (UDAAP) protection standards subject to Bureau enforcement action.   This is the case even if no consumers have been harmed, if only one consumer is adversely affected, or if a small amount of actual or potential damage puts many consumers at risk.  The Bureau also prescribes data-safeguard standards firms and service providers must ensure to comply with CFPB expectations.


11 08, 2022


2022-08-11T10:43:26-04:00August 11th, 2022|1- Financial Services Management|

Credit-Card Networks

Two senators have reopened questions about the manner in which card-related payments are handled, tackling those applicable to credit cards with a bill mandating that merchants must be given a network choice that is not either Visa or Mastercard in order to, the sponsors argue, increase competition and lower credit-card transaction costs.  Although the multi-network requirement would apply only to banks with assets over $100 billion, it would likely have the effect of lowering swipe fees across the sector because exempt banks would be compelled by market forces to find lower-cost networks.  The extent to which these lower-cost networks are also sound and resilient under stress is uncertain as no safety-and-soundness or operational requirements directly apply to card-processing networks.


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