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Welcome to The Vault. Every week you’ll find a sample of FedFin opinion and analysis on the most recent issues facing financial services firms. Check back frequently to see what’s new. Click here to contact us.

19 08, 2025

FedFin: A Key Conservatorship Question

2025-08-19T15:12:01-04:00August 19th, 2025|The Vault|

Following a talk last week, FedFin managing partner Karen Petrou was asked her thoughts about how different conservatorship-exit options affect the Treasury market and thereby the dollar’s reserve-currency status. This issue has yet to surface in public debate, but it is top-of-mind for Treasury and thus will govern what Pulte and the President are likely to do….

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

18 08, 2025

Karen Petrou: Why More Deposit Insurance is a Very Bad Idea

2025-08-18T12:06:00-04:00August 18th, 2025|The Vault|

As we recently noted, bipartisan senators are readying an amendment authorizing almost-unlimited FDIC coverage for noninterest-bearing transaction accounts as long as the bank accepting them is smaller than $250 billion. Pressing for this, Sen. Warren said the new FDIC backing should only be available to smaller IDIs because, “The giant banks don’t need another subsidy.” Maybe, but this still leaves open a critical question: why should larger banks pay the premiums that back FDIC-insurance subsidies for their competitors? If this makes sense for FDIC insurance, then why stop here? Let’s have the biggest banks also pick up the tab for small-bank modernization, branch expansion, and maybe nicer signs.

If big banks need to nurse small ones along, then the small-bank business model needs a reboot, not de facto nationalization for smaller banks that can’t find their way. Many do. In fact, smaller banks with marketing acumen have long been able to attract deposits by paying a bit more for them. Further, it’s not as if smaller banks can’t get added coverage if they want more deposits. All that’s different is that smaller banks must pay for this themselves instead of sending the tab over to the rest of the industry and, down the road, to depositors and taxpayers.

As a recent note from the Federal Reserve Bank of Dallas pointed out, reciprocal deposits meet the needs of banks that want more FDIC coverage. All it takes is paying a fee for this privilege, and the $500-$600 million total annual cost …

15 08, 2025

FedFin on: Merchant-Banking Powers

2025-08-15T12:08:48-04:00August 15th, 2025|The Vault|

Senate Banking GOP leadership has introduced legislation grandfathering existing merchant-banking holdings into a new, fifteen-year maximum tenor. Merchant-banking activities have not been widely discussed in many years, but are likely to gain renewed interest now that nonbanks may gain expanded banking powers under pending cryptoasset legislation. Banks have also long suffered under real-estate development and other activity limits they may seek to remove if this legislation advances….

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

11 08, 2025

Karen Petrou: Bureaucracy, Thy Name is Bank

2025-08-15T10:18:56-04:00August 11th, 2025|The Vault|

About 8 weeks ago, FedFin found that a four-figure check had gone astray like so many others have for other people. We thank the USPS inspector who brought to our attention that the name of the depositor wasn’t even close to that of the payee, something one likes to think banks notice, even though none did. Given this initial goof, perhaps I shouldn’t have been surprised by how hard it is not only to remedy the loss but also to strengthen our firm’s payment practices. We agreed with the bank that they needed modernization, but three weeks after gaining the audience necessary to file the claim and ask for help, our administrators are still mired in paperwork, not enjoying the enhanced protection for which we agreed to pay for on the spot. And our lost money? Don’t even ask.

At a time of soaring fraud at ever-higher cost to banks, one might have thought ours would have been eager to facilitate our update. After all, we lose use of stolen funds, but the bank is obliged to repay us and take the loss. Which bank is on the hook is of course a battle between banks, but the payer-facing bank is the one that needs to keep the customer. I am sure the bank at every managerial level knows this, but bank culture is often so immutably mired in rigid processes and procedures that critical jobs never get done. Why is it so hard not just to get fraud remediation …

31 07, 2025

FedFin Assessment: Administration Mandates Massive Banking-Regulatory Crypto Rewrite

2025-08-01T15:19:39-04:00July 31st, 2025|The Vault|

Pursuant to the President’s executive order, the President’s Working Group on Digital Asset Markets (PWG) yesterday released a detailed report outlining specific policies the Administration will now follow or pursue. As we noted yesterday, the report is unreservedly pro‑crypto, emphasizing the benefits of these assets to the United States while also reaffirming the Administration’s strong opposition to a CBDC.  The recommendations for banking agencies are most specific when it comes to new capital standards, with the report detailing how it believes cryptoassets should be treated in new standards the agencies are to issue as quickly as possible…

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

28 07, 2025

FedFin Assessment: Crypto-Clarity Bills Recraft Bank Powers, Ownership

2025-07-28T13:50:43-04:00July 28th, 2025|The Vault|

In this report, we assess provisions in the House-passed CLARITY Act, the Senate discussion draft, and a new Senate Banking GOP request for information on provisions in these measures affecting financial-industry structure and banking  activities. The measures are focused on recrafting the regulatory framework governing digital assets to promote rapid innovation, as well as to redefine SEC and CFTC authority.  However, the bills also alter provisions affecting what banking organizations may do and who may own them, with the Senate Gop’s draft bill suggesting still greater restructuring might advance in that chamber’s legislation. This report focuses on these provisions, which could radically reshape which types of companies are allowed to own IDIs and what IDI parent companies may do….

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

 …

28 07, 2025

Karen Petrou: The High Cost to Competitiveness of the Bankers’ Quest for Certainty

2025-07-28T09:27:41-04:00July 28th, 2025|The Vault|

FedFin reports since at least 2011 have identified the comparative advantage nonbanks enjoy thanks to lots of costly bank-only standards.  However, we missed one big nonbank advantage sure to prove even more decisive in the stablecoin wars:  bankers crave regulatory certainty even as their competitors aggressively exploit the battlefield advantage that uncertainty gives to those who dare.

Bankers aren’t dare-devils because they’re not supposed to be.  Indeed, anyone who takes someone else’s money should be very, very careful.  Decades of accepting deposits under strict rules without meaningful competition meant that most bankers rightly asked a lot of questions before doing anything even a little bit novel.  To be sure, high-flying bankers abused taxpayer benefits thanks to negligent or even captive supervisors and rules weren’t always right.  Still, rules and the supervisors who enforced them generally kept bankers in their lane since there wasn’t any faster traffic.

This comfy balance between caution and competitiveness was fiercely challenged for the first time when money-market funds dawned in the late 1970s, luring bank deposits at a time when anachronistic rules barred banks from offering competitive interest rates.  High-flying bankers then sought to evade these constraints by making high-risk loans, thus bringing about the 1980s S&L crisis and the banking debacle that followed in the early 1990s.  Both of these were systemic in terms of taxpayer cost, but neither had macroeconomic or financial-stability impact.

Newer, better rules succeeded these crises, but they were outflanked as “nonbank banks” became the first commercial firms to exploit …

21 07, 2025

Karen Petrou: How New-Age ILCs Will Bust the Old Banking Paradigm

2025-07-22T12:54:27-04:00July 21st, 2025|The Vault|

As our forthcoming in-depth analysis will make clear, the FDIC’s request for information (RFI) on industrial loan company charters is a critical document to which one must respond in order to have any say in the future of banking as it may soon be set. This is easy to miss — RFIs are usually little more than a duck and cover. See for example the recent inter-agency RFI on payment fraud, from which one can deduce little but that the agencies think fraud is bad — questions asked, decisions deferred, discretion preserved. That is definitely not what the FDIC is about when it comes to ILCs – it is asking tough questions it will begin to answer even before RFI comments are submitted later this year. Who gets an ILC charter will determine winners and losers for decades to come, or so history teaches us.

Due to decisions deferred, the ILC charter has been an unresolved question since the 1980s. Congress then enacted the “Competitive Banking Act” which was anything but since all it did was grandfather the banking/commerce mixes achieved through ILCs through 1987 without quashing all those that came thereafter. As the FDIC notes, ILC and similarly chartered assets grew from $4 billion in 1987 to $213 billion by 2006, when more than a few of the most aggressive ILCs were in high-flying nonbanks that were then bailed out during the 2008 crisis.

One might have thought Congress, or the FDIC would then decide what to do with …

14 07, 2025

Karen Petrou: How the For-Cause Firing Squad Lines Up

2025-07-14T10:13:23-04:00July 14th, 2025|The Vault|

Due to the din of demands from the Trump Administration, many observers disregarded Thursday’s letter on behalf of the President from OMB Director Vought to Fed Chair Powell. They shouldn’t. Mr. Trump is not one to let his enemies off lightly. Even as he continued his anti-Powell vendetta on Friday, his officials are readying a way to rid the President of his Fed chair in a way they hope the Supreme Court must accept.

The OMB letter built on accusations that first surfaced at a Senate Banking Committee hearing late last month. These concern renovations at the Fed’s Eccles Building, a dump of grim brutalist architecture that never saw better days but was at least once in reasonable repair. Over the last decade or so, one couldn’t even say that. It is in fact a prime example of the awful architecture the President wants to blot from the face of the nation’s capital.

The Senate GOP inquiry and the OMB letter thus do not question the need for renovation but accused Mr. Powell of allowing gross over-budget spending on luxuries such as “Italian” – not all-American – beehives, “water features”, oodles of high-end marble, and a secluded art gallery. Mr. Powell acknowledges over-spending but said it wasn’t the Fed’s fault and denied any undue expenses for high-end appurtenances.  But, questioned in a follow-up GOP letter, Mr. Powell promised only a staff briefing, doubtless hoping to bury the issue but in fact giving his enemies an open field. Realizing this, the …

8 07, 2025

FedFin on: SLR Reform

2025-07-08T10:09:26-04:00July 8th, 2025|The Vault|

Reflecting a new approach to bank regulation and the strong hand of the Treasury Secretary, federal banking agencies have proposed a sweeping rewrite of the enhanced supplementary leverage ratio (eSLR) applicable to the eight U.S. banking organizations designated as global systemically important banks (GSIBs). The proposal does not expressly exempt Treasury obligations from the eSLR denominator, but it alters the manner in which the ratio is calculated….

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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