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So far William Cross has created 7 blog entries.
23 05, 2022


2022-05-23T10:51:36-04:00May 23rd, 2022|1- Financial Services Management|

FDIC-Insurance Status Representation

Using a new approach to issuing enforcement edicts – a circular – the CFPB has made use of its controversial decision to bring nonbanks under its ambit to bolster the FDIC’s efforts to enhance consumer understanding of which funds are entrusted to FDIC-insured depositories and which may be at greater risk in other hands. Even inadvertent violations that may suggest FDIC insurance where it does not apply could result in significant legal risk under either federal or state action.


20 05, 2022


2022-05-20T16:59:22-04:00May 20th, 2022|3- This Week|

Seeing CBDC

When HFSC takes up digital assets later this week, its ostensible focus will be on whether the U.S. should have a CBDC.  However, given distress across the virtual-currency landscape, the focus will surely be broader.   Democrats will use the session to press hard for stablecoin standards, perhaps prompting Rep. Josh Gottheimer (D-NJ) to advance his draft before measures such as one pending from Sen. Toomey (R-PA) take precedence (see FSM Report CRYPTO27).  House Republicans will surely press the CBDC principles they reiterated last week to argue that stablecoins should be given far more of a chance than Democrats think sound.  We expect Members also to push and pull at the assumptions embedded in the Fed’s discussion draft (see FSM Report CBDC10) and at the benefits CBDC might or might not provide to financial inclusion and for cutting big banks down to the size progressives prefer.


6 05, 2022


2022-05-06T16:28:16-04:00May 6th, 2022|3- This Week|

Socking It to FSOC

As the schedule below notes, this week will again bring FSOC’s record and agenda before Senate Banking and the House Financial Services Committee.  Much of the session will, as usual, wander into areas outside FSOC’s ambit – inflation and sanctions are sure-fire examples of non-FSOC issues on which Treasury alone exercises considerable sway and about which Congress is intensely curious.  However, there’s a lot to talk about when it comes to high-priority financial policy and, even in Washington, talk often leads to action.


1 05, 2022


2022-05-01T16:41:35-04:00May 1st, 2022|3- This Week|

Waiting in the Wings

Although the Senate last week confirmed Lael Brainard as the Fed’s new vice chair, Mr. Powell, Mr. Jefferson, and Ms. Cook remain on hold. The reason is political and powerful: the White House needs all the Democratic votes it can get to confirm Ms. Cook, several Democrats are out with Covid, and Mr. Powell’s confirmation is being held hostage to hers. All this will work itself out and all of the nominees will get confirmed, but it will take time. Similarly, Michael Barr will soon get his confirmation hearing to serve as Fed supervisory vice chair and then on to confirmation absent any untoward remarks or unknown facts Republicans can use to block him.


20 04, 2022


2022-04-20T17:35:23-04:00April 20th, 2022|4- GSE Activity Report|

Fintechs on the Firing Line

As we noted yesterday, the IMF’s financial-stability report includes a searing assessment of fintech risk.  In this report, we drill down into one of the study’s case studies, which assesses mortgage fintech and concludes that this business model poses a raft of risks to financial stability.  We note several methodological concerns with this conclusion, but it will nonetheless have significant bearing on what FSOC, FHFA, and Ginnie come to do about the nonbank business model.


8 04, 2022


2022-04-08T20:44:49-04:00April 8th, 2022|2- Daily Briefing|

CFPB Tackles Core-Service Providers
Late yesterday, CFPB director Chopra told community banks and credit unions that he wants to be sure that entities that he described as focused on relationship banking are included in CFPB decision-making, in contrast to the large banks that had previously influenced its actions.

Hsu Supports Special-Purpose Stablecoin Charter
Picking up on both Secretary Yellen’s comments yesterday and the PWG’s stablecoin report (see Client Report CRYPTO21), Acting Comptroller Hsu today went farther to conclude that cryptocurrency in general poses systemic risk that warrants immediate attention to stablecoin regulation.

FSOC Worries About Commodity-Market Risk
The FSOC readout from its closed meeting today was as inscrutable as usual.  However, we infer that the Council convened principally to assess commodity-market volatility in the wake of the Ukraine invasion.


9 03, 2022


2022-03-10T13:50:56-05:00March 9th, 2022|5- Client Report|

Biden Administration Decides Crypto Here to Stay, Seeks CBDC

We follow our initial client alert here with an in-depth analysis of President Biden’s long-awaited executive order laying down steps intended quickly to construct a U.S. digital-asset policy construct. Although sparked in part by virtual currency’s role in the Ukraine crisis, the executive order (EO) is a watershed event establishing for the first time that the U.S. views digital assets as a fixture of future finance warranting a rapid, far-reaching, and stringent set of governance, law-enforcement, equity, inclusion, and technology policy intervention. In general, the EO establishes a U.S. principle akin to that set by global regulators in this area: same-business same rules. Nothing in the order thus threatens SEC Chairman Gensler’s assertion that current law addresses many investor-protection challenges (see Client Report INVESTOR19) indeed, the EO strengthens the SEC’s hand by validating the chairman’s concerns.


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