In this report, we update our analysis yesterday of U.S. economic authority addressing the COVID crisis (see Client Report COVID3) to evaluate the various regulatory changes under active consideration at the Fed, OCC, and FDIC. A caution: anything we anticipate now is based on discussions and analysis subject to immediate change under these crisis conditions. However, as noted, banking agencies yesterday took limited action to ease buffer use and redefine retained earnings for capital-distribution purposes. We also noted the increasing odds of CECL relief and relaxation of the AOCI filter for GSIBs. Now, we turn to additional options, considering actions such as GSIB-surcharge, stress-test, and capital relief in the context of Congressional efforts to craft sweeping fiscal-policy remedies to growing macroeconomic stress.
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