Capital

16 10, 2023

Karen Petrou: The Apples-to-Martians Comparison of PE Capital to That Demanded of Banks

2023-11-13T15:47:14-05:00October 16th, 2023|The Vault|

What is capital?  We talk a lot about how much banks should hold and what more bank capital means to whom.  But few have said much about what regulatory capital actually is.  That’s a signal, strategic omission as private-equity firms spin a tale of capital resilience without actually having anything comparable to what banks must raise even as nonbanks take over more and more financial markets key to stability, economic equality, and macroeconomic growth.  Let nonbanks compete wherever they can, but suggestions that private equity hold more capital than banks is a whopper that cannot go unchallenged as lending migrates to these powerful firms.

In a New York Times article over the weekend, Apollo’s chief executive reiterated a point he’s made before:  that his firm’s lending activities are backed by “more Tier 1 capital” than banks are required to hold.  As the Times article then observes, the assets that “constitute” Apollo’s capital and that of other PE firms are low-risk and thus a source of “permanent capital.”  Or so it is said.

But the assets Apollo calls capital are just assets – not capital of any tier – under banking rules.  Assets they also are when one remembers how balance-sheets work.  The billion-dollar balance-sheet question is always what stands between assets and liabilities if asset valuations drop.  For banks and, indeed, anyone else with a balance sheet, that’s capital – not more assets deepening the void between assets and liabilities.

The term “permanent capital” actually derives from insurance regulation.  It …

16 10, 2023

M101623

2023-10-16T09:21:55-04:00October 16th, 2023|6- Client Memo|

The Apples-to-Martians Comparison of PE Capital to That Demanded of Banks

What is capital?  We talk a lot about how much banks should hold and what more bank capital means to whom.  But few have said much about what regulatory capital actually is.  That’s a signal, strategic omission as private-equity firms spin a tale of capital resilience without actually having anything comparable to what banks must raise even as nonbanks take over more and more financial markets key to stability, economic equality, and macroeconomic growth.  Let nonbanks compete wherever they can, but suggestions that private equity hold more capital than banks is a whopper that cannot go unchallenged as lending migrates to these powerful firms.

M101623.pdf

18 08, 2023

Al082123

2023-08-22T09:52:13-04:00August 18th, 2023|3- This Week|

Capital Regulation Deconstructed

Last week, we provided clients with several more in-depth analyses of the interagency capital proposal.  Of particular note is our wrap-up report (see Client Report CAPITAL234) which looks hard at the agencies’ own quantitative and qualitative impact assessments to see what the raw numbers say, how the numbers comport with current data and market realities, and – most importantly – how to interpret the agencies’ qualitative conclusions in light of these analytics, as well as our understanding of many of the studies on which key assumptions are premised.  As the report details, we agree that the agencies’ rationale for every possible capital woe – that anything is better than a financial crisis – is right.  But it’s only right if the result of the rules is to make financial crises less likely and that, as our reports make clear, is far from assured.  Many provisions of each key section combined with overall quantitative results could well prove profoundly destabilizing.

Al082123.pdf

1 08, 2023

FedFin on: Capital Winners – GSEs – and Losers – MI

2023-08-04T09:44:41-04:00August 1st, 2023|The Vault|

We’ve much more to do to determine the strategic and policy impact of the new credit-, market-, and operational-risk capital rules singly and collectively – a complex task given the 1,089-page rulemaking made harder by some extremely-arcane language that may either mask what the agencies mean or differ from what they meant to mean.  Still, several conclusions about mortgage finance are clear:  the rules would be less demanding than those at present for many mid-LTV loans, the GSEs’ risk weighting continue to give them a considerable advantage over bank originators and securitizes, and MI lost the limited luster the banking agencies were forced to concede in 2013.

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

1 08, 2023

FedFin Analysis: U.S. Regulatory-Capital Rewrite: Framework

2023-08-01T16:31:19-04:00August 1st, 2023|The Vault|

In this in-depth report, we begin our analysis of the 1089-page capital proposal released by the U.S. banking agencies not only to make U.S. standards more consistent with Basel’s 2017  “end-game” rules, but also to correct failings in the current capital framework the agencies believed were laid bare by recent bank failures. The new standards rewrite the 2019 “tailoring” rule with regard to application of the toughest capital standards, now covering all BHCs with assets over $100 billion along with their insured depository institutions (IDIs) regardless of size. For smaller BHCs, the most significant impact of the new approach requires recognition of accumulated other comprehensive income (AOCI) unrealized gains and losses related to available-for-sale (AFS) and held-to-maturity (HTM) securities; the agencies recognize this cost but believe the proposed three-year transition reduces any adverse impact.

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, 2023

GSE-072823

2023-08-14T10:29:36-04:00July 28th, 2023|4- GSE Activity Report|

Capital Winners – GSEs – and Losers – MI

We’ve much more to do to determine the strategic and policy impact of the new credit-, market-, and operational-risk capital rules singly and collectively – a complex task given the 1,089-page rulemaking made harder by some extremely-arcane language that may either mask what the agencies mean or differ from what they meant to mean.  Still, several conclusions about mortgage finance are clear:  the rules would be less demanding than those at present for many mid-LTV loans, the GSEs’ risk weighting continue to give them a considerable advantage over bank originators and securitizes, and MI lost the limited luster the banking agencies were forced to concede in 2013.

GSE-072823.pdf

17 07, 2023

Karen Petrou: Counter-Cyclicality is One Critical Missing Piece of Barr’s Unholistic Construct

2023-07-17T16:55:22-04:00July 17th, 2023|The Vault|

Banks and Republicans are beating up on Michael Barr for much in his new capital construct.  The furor focuses on the high cost of the new capital rules, cost glossed over in Mr. Barr’s talk via an over-arching assumption that banks can readily do without two years of post-dividend retained earnings.  Maybe they can; investors not so much.  This is a big problem, but a little-noticed one also warrants more scrutiny:  the decision to leave untouched and apparently not even considered the U.S. version of the counter-cyclical capital buffer (CCyB).  This makes the new framework still more procyclical and even less holistic.  CCyBs have worked well around the world and a well-designed one in the U.S. would obviate the need for some – not all, but some – of Mr. Barr’s most counter-productive ideas even as it makes banks more resilient, the financial system safer, and the economy less volatile.

What are CCyBs?  The basic idea is that these are capital charges triggered in good times that are released under stress, making banks and the economies they serve better able to ride out macroeconomic boom-bust cycles.  The final U.S. version of the global CCyB framework acknowledges this global standard, but it goes on to say only that the Federal Reserve will know a boom or bust when it sees it and will do something about it via some sort of CCyB should it feel inclined to do so possibly after a rulemaking process on the up- and down-sides that …

17 07, 2023

M071723

2023-07-17T09:36:14-04:00July 17th, 2023|6- Client Memo|

Counter-Cyclicality is One Critical Missing Piece of Barr’s Unholistic Construct

Banks and Republicans are beating up on Michael Barr for much in his new capital construct.  The furor focuses on the high cost of the new capital rules, cost glossed over in Mr. Barr’s talk via an over-arching assumption that banks can readily do without two years of post-dividend retained earnings.  Maybe they can; investors not so much.  This is a big problem, but a little-noticed one also warrants more scrutiny:  the decision to leave untouched and apparently not even considered the U.S. version of the counter-cyclical capital buffer (CCyB).  This makes the new framework still more procyclical and even less holistic.  CCyBs have worked well around the world and a well-designed one in the U.S. would obviate the need for some – not all, but some – of Mr. Barr’s most counter-productive ideas even as it makes banks more resilient, the financial system safer, and the economy less volatile.

M071723.pdf

21 06, 2023

FEDERALRESERVE74

2023-06-21T17:06:47-04:00June 21st, 2023|5- Client Report|

Powell Tries to Deflect GOP Capital Assault

Chairman Powell’s HFSC appearance today led to unusually substantive discussion of pending financial-policy actions.  As detailed in this report, Republicans renewed their vigorous campaign against new capital rules, refusing to be put off by Mr. Powell’s assurances that they would apply only to the largest banks, would be phased in, and will have less impact on growth than interest rates.  Even though Mr. Powell also said he recognized capital trade-offs and had taken no position on new rules, Chairman McHenry  (R-NC) is so opposed to these and other recent proposals from Vice Chairman Barr that his opening statement includes the suggestion of legislation to separate monetary from regulatory policy, presumably moving regulation to another agency perhaps in the manner recently proposed by Sen. J.D. Vance (R-OH).  However, neither Mr. McHenry nor other Republicans raised this idea in their questioning, suggesting it is not a near-term legislative-agenda item.  What is near-term are mark-ups announced today for the HFSC/Ag bill on crypto jurisdiction strongly opposed by Democrats and the stablecoin bill to which they are considerably more amenable.

FEDERALRESERVE74.pdf

17 03, 2023

AI032023

2023-03-17T16:53:34-04:00March 17th, 2023|3- This Week|

What A Week That Was

As the flood of FedFin reports, alerts, and client calls makes clear, the last ten days have not only been busy – they are a threshold moment.  Now, U.S. and global bank regulation will proceed to much unfinished business after 2008 along with targeted changes to address hard lessons from SVB, SBNY, Credit Suisse, and broader market stress as this seems still to be evolving.  FedFin is continuing to advise clients of each twist and turn in U.S. and global financial policy, but we are also stepping back to provide forward-looking in-depth reports as the shape of things to come becomes clear.

AI032023.pdf

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