26 10, 2018

Karen Petrou: A Volcker Rule to Live By

2018-10-26T19:57:18-04:00October 26th, 2018|Other|

I guess I’m not the only one with the willies over how procyclical the financial system has become.  In an interview surrounding his new book, Paul Volcker has sharply departed from current conventional central-bank wisdom, pointing importantly to the potent risk cocktail now mixing a decade of quantitative easing with the top of the business cycle and a sharp increase in market risk-taking.  He’s also argued that the U.S. is now a “plutocracy.”  He’s right – U.S. income and wealth inequality has hit new highs.  And, when inequality is as bad it is, it exacerbates the risk of financial crises.  Could our boom expire in a gentle, gradual way?  Or, as Mr. Volcker fears, will markets restructured by a decade of central-bank and regulatory actions into arbitraging and yield-chasing run for cover if they take fright?  And, if they do, how fast does this rout turn into another systemic crisis given that America is even less equal now than it was in 2007?

Mr. Volcker is almost alone among current and former regulators in his prescient grasp of the ways post-crisis policy fires up procyclicality in concert with ever-worse economic inequality.  As we noted in our assessment earlier this week of the FSB’s forward-looking work plan, global central bankers and regulators are totally pleased with themselves about the bastion into which they’ve made the world’s biggest banks by dint of all the post-crisis standards.  They’ve been worrying for years that costly bank rules realign finance into a “shadow-bank”

7 12, 2012

Privacy Policy

2012-12-07T04:54:35-05:00December 7th, 2012|Other|

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

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We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.…

2 03, 2010

Risk Management FSMs

2020-08-12T13:59:29-04:00March 2nd, 2010|Other|


Investment Adviser Custody
January 29, 2010

  • SEC final rules to promote the use of independent custodians by investment advisers.

Credit-Score Notices
FSM Report: FCRA27
January 28, 2010

  • FRB, FDIC final rule on notice requirements for creditors if risk-based pricing derived from credit scores results in consumer borrowing costs that are materially higher than the most favorable terms generally available.

Global Liquidity-Risk Management Standards
January 27, 2010

  • Basel Committee consultative paper to impose two new ratios to assess how liquid banking organizations are and how well they can withstand severe short- and long-term stress.

Compensation-Related FDIC Premiums

January 25, 2010

  • FDIC ANPR outlining ways that compensation practices could be reflected in the risk assessments that determine deposit-insurance premiums.

Interest-Rate Risk Management
FSM Report: IRR4
January 22, 201

  • Banking Agencies’ guidance that banks must not only manage interest-rate risk, but also take action to ensure emerging problems are anticipated and corrected.

Global Regulatory-Capital Rules-Procyclicality/Capital Conservation
FSM Report: CAPITAL161
January 15, 2010

  • Basel Committee’s consultative paper on changes designed to reduce the procyclical implications of the current capital regime and ensure that banks conserve capital when stress occurs.

Global Regulatory-Capital Rules-Leverage Standards
FSM Report: CAPITAL160
January 14, 2010

  • Basel Committee’s consultative paper rewriting global regulatory-capital requirements that assesses the leverage standard.

Global Regulatory-Capital Rules
FSM Report: CAPITAL159
January 13, 2010

  • Basel Committee’s consultative paper that would change the capital requirements assigned to an array of on-and off-balance sheet obligations.

Global Regulatory-Capital Rules
FSM Report:

9 01, 2009

Government Links

2009-01-09T02:41:48-05:00January 9th, 2009|Other|

Use these links to government web sites for information
and downloads of regulations, legislation, and other documents.

3 01, 2009

Cost of Services

2009-01-03T21:29:28-05:00January 3rd, 2009|Other|

Analytical Services: $19,500 annually

Retainer analytical services clients receive Daily Briefings, Weekly summary reports, Client Reports, and Financial Services Management analyses, all via e-mail. They also receive the weekly commentary from Karen Petrou.  These services are site-licensed; that is, the initial recipient may share them without limit within his or her organization. However, transmittal or other reproduction outside the firm is authorized only upon receipt of written permission.

Governmental agencies may receive any of these services on a freestanding subscription.  Retainer clients generally receive all their analytical services under our standard agreement. Send us an e-mail to receive one for your review. Payment periods can be customized — annually or quarterly, as desired.

GSE Activity Report

Subscriptions cost $12,000 annually. Clients generally pay monthly, although other terms are set to meet client need.  CLICK FOR MORE INFO

GSE Activity Reports are not site-licensed, and full copyright protection applies to internal and external transfer. Cost-effective arrangements for distribution within a client institution can be structured to ensure that all client officers who need the service receive it.

Consulting Services

Federal Financial Analytics in general provides consulting services only on a project or retainer basis. Small freestanding assignments billed on an hourly fee basis are accepted only for existing clients, based on our view that we cannot provide effective advice without the full understanding of client need that can only be established on an ongoing basis.


3 01, 2009

Conflict of Interest Policy

2009-01-03T21:28:45-05:00January 3rd, 2009|Other|

When potential conflicts of interest arise, Federal Financial Analytics makes the initial judgment as to whether a conflict may occur. Should one appear likely and material, the assignment is declined, with an indication to the prospective client only that such a conflict has been determined. No information on the nature of the conflict or with whom it may occur is provided. When managing partners determine that a conflict may be manageable, the current client is advised of the prospective assignment, without release of any confidential information on the prospective client. Should a full conflict determination be possible only with confidential information (such as the name of the prospective client), FedFin receives permission to provide this information from the prospective client to the current one prior to doing so. If the current client believes a conflict exists, then the prospective assignment is declined or revisions to it are made. The prospective client is advised of all information necessary for it also to determine if a conflict may exist, based on the willingness of the current client to provide any proprietary information required for it to do so.

3 01, 2009

Copyright Infringement Policy

2009-01-03T21:28:09-05:00January 3rd, 2009|Other|

We have and will continue to discontinue access when, in our judgment, the copyright(s) have been infringed upon. Any fees outstanding at such time remain due, but no further fees shall be charged regardless of any contract that may be in place at the time copyright violations were detected. Federal Financial Analytics reserves its right to pursue additional remedies in such cases.

3 01, 2009


2009-01-03T21:27:24-05:00January 3rd, 2009|Other|

Clients seeking Consulting Services are asked to provide a clear statement of need. In this way, Federal Financial Analytics can determine if our skills ensure successful completion and if the project presents any conflicts of interest. As a small firm, Federal Financial Analytics accepts only those assignments that are compatible with staff expertise. We are also able to accept only projects where the deadline can be met in light of prior commitments. Federal Financial Analytics has an unbroken record of on-time delivery of all consulting projects, and we accept only those assignments consistent with this commitment.

Projects also are vetted for potential conflicts of interest with existing assignments or clients.

See Conflict of Interest policy


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