#CRA – Federal Financial Analytics

28 09, 2023

DAILY092823

Eliza Allen2023-09-28T16:44:03-04:00September 28th, 2023|2- Daily Briefing|

White House Resilience Plan Focuses on Physical Infrastructure, Not Finance

The White House today released a National Climate Framework focused principally on promoting climate resilience in non-financial sectors such as building and energy use, improving federal agency climate preparedness, ensuring land and water resilience, and increasing climate-related community benefits and job opportunities.

BIS Conducts Successful Wholesale CBDC FX Pilot

Looking at the wholesale CBDCs of most interest in the U.S., the BIS today announced the conclusion of Project Marina, a wholesale CBDC FX pilot with DeFi elements among the central banks of France, Switzerland, and Singapore.

OCC Moves Interest-Rate Risk to Supervisory Priority List

The OCC today released its 2024 bank supervision operating plan announcing that there will be heightened supervision focus on interest-rate risk, AML/CFT, payments, DLT, and CRA.

All But The Smallest, Simplest Regional Banks Face Tougher Supervision

Signaling tougher supervisory standards for most regional banks, the long-anticipated Federal Reserve OIG report on SVB’s failure largely reiterates findings in Vice Chair Barr’s SVB report (see Client Report REFORM221) on failures by Board and FRB-SF supervisory staff quickly to adapt to SVB’s rapidly-changing risk profile.

Gruenberg Again Calls for Targeted Deposit Insurance Reform

In remarks today, FDIC Chair Gruenberg said that cross-border cooperation enhanced resolution of SVB’s international subsidiaries, using a talk to global deposit insurers also to reiterate prior recommendations on deposit-insurance reform (see Client Report DEPOSITINSURANCE119).

Daily092823.pdf…

22 09, 2023

DAILY092223

Eliza Allen2023-09-22T17:19:47-04:00September 22nd, 2023|2- Daily Briefing|

Bowman Stands Firm Opposing Pending Rules

Making clear that her concerns with pending rules have in no way abated, FRB Governor Bowman today stated that any proposal considered by the Board or jointly with the other banking agencies must be focused on remediating the identified concerns, informed by data and genuine discussion within each participating agency and with policymakers, and developed through a transparent process that is open to public comment. Citing the FRB’s recent proposals including the Basel III endgame (see Client Report CAPITAL234), LTD requirements (see FSM Report TLAC9), and the CRA rewrite (see FSM Report CRA32), she acknowledges that multiple interrelated proposals may complicate submitting meaningful comments, emphasizing the importance of stakeholder feedback.

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14 09, 2023

CAPITAL235

Eliza Allen2023-09-14T14:23:57-04:00September 14th, 2023|5- Client Report|

GOP Blasts Basel End-Game Regs, Dems Seek a Few Changes

With HFSC Chairman McHenry (R-NC) leading the way, GOP Members of the panel’s Financial Institutions Subcommittee today blasted the banking agencies’ end-game proposal (see Client Report CAPITAL234). Republicans were unanimous in joining leadership’s attack on the proposal’s process and substance, pointing to what they called incomplete impact analyses, an inexplicably short comment period, and adverse macroeconomic and regional-bank implications. Democrats led by Ranking Member Waters (D-CA) were more restrained and in some cases supported the proposal, but concerns were also noted with specific provisions (e.g., re the treatment of certain mortgage and securitization assets) and the interface with the pending CRA final rule. We continue to expect the banking agencies to hold firm to the proposal in broad terms and make minimal, if any, changes to the comment deadline. However, pressure from Republicans and the industry could well force renewed and what many would consider improved impact analyses designed not only to allay political opposition, but also the courts if litigation challenges the final rule.

CAPITAL235.pdf…

1 08, 2023

DAILY080123

Eliza Allen2023-08-01T16:49:48-04:00August 1st, 2023|2- Daily Briefing|

Curtain Falls on Fintech-Charter Hopeful

In a blow to the waning chartering prospects for fintech and crypto banks, the OCC today announced that Figure – a fintech platform that applied in 2020 for a strikingly-novel national bank charter (see Client Report CHARTER28) – has officially withdrawn its application. As noted, Figure’s application followed OCC revisions to federal-charter activities making any activity authorized for national banks possible via electronic, not just traditional, means (see FSM Report CHARTER27).

Discount-Window Stigma Persists

The Fed today released the results of its May 2023 Senior Financial Officer Survey, with most banks continuing to fear public disclosure of discount window advances. As noted, the banking agencies last week told banks not only to improve contingency-funding planning, but also to look more favorably on the discount window. This seems unlikely absent a change in current market perception or repeal of the disclosure requirements.

Daily080123.pdf…

21 07, 2023

Al072423

Eliza Allen2023-07-21T17:08:03-04:00July 21st, 2023|3- This Week|

Here It Comes…

As anticipated, the banking agencies will get their capital proposals out before the August recess but close enough to it to avoid – or so they hope – a withering gauntlet of House hearings. By the time Congress reconvenes in September, the agencies expect – and with good reason – that the new rules will escape notice because attention will have turned to the most vexing issues confronting this divided Congress, most notably keeping the federal government open at the end of the fiscal year. Acting now also ensures that, even if the agencies give ground and concede to the industry’s 120-day comment deadline, at least one month of that will fly by in August, putting the timeline for issuing a final capital rule into the first quarter of 2024 and thus beyond the reach of Congressional Review Act repeal should Republicans muster enough support and the President somehow recants.

Al072423.pdf…

10 07, 2023

DAILY071023

Eliza Allen2023-07-10T16:43:24-04:00July 10th, 2023|2- Daily Briefing|

HFSC Lays Out Its ESG Priorities

The majority staff memo ahead of Wednesday’s HFSC hearing on ESG follows the outline anticipated last week and that laid out in the GOP agenda for ESG-related action (see Client Report ESG4).

OCC Concurs On Capital, Tries For The Merger Middle

Acting Comptroller Hsu today confirmed our assessment of Vice Chair Barr’s comments earlier today (see Client Report CAPITAL228) that the three banking agencies are aligned on the new capital construct to be shortly released for public comment.

Barr, Foster Demand Delay to Capital Rewrite

Anticipating Vice Chair Barr’s remarks this morning detailing near-term capital policy changes (see Client Report CAPITAL228), HFSC Financial Institutions Subcommittee Chair Barr (R-KY) and Ranking Member Foster (D-IL) sent a letter late Friday demanding that he appear before the Subcommittee to present the conclusions of his capital review and upcoming Basel III implementation plans prior to public release, asking also for details and likely outcomes for industry consolidation.

House Republicans Keep Spotlight On FRB-SF

Continuing the GOP’s attack on the San Francisco Fed’s supervision of SVB in the wake of what many believe are “woke” priorities, House Oversight Committee Chairman Comer (R-KY) was joined today by Financial Services Subcommittee Chairwoman McClain (R-MI) in sending a letter to FRB Chairman Powell taking serious issue with the Federal Reserve Bank of San Francisco and the Fed for what they describe as SVB-related transparency and communication failures.

BIS Survey: Most Central Banks Considering CBDCs

The BIS …

10 07, 2023

M071023

Eliza Allen2023-07-10T14:18:21-04:00July 10th, 2023|6- Client Memo|

The Bankruptcy of Bank-Merger Policy

On Wednesday, a Senate Banking subcommittee will consider bank-merger policy, surely providing a platform for its chair, Sen. Warren’s pronounced views opposing all but the smallest bank mergers and maybe not even those. Many other senators are not as adamant, but even pro-business Republicans – see J.D. Vance – think bank mergers beyond the itty-bitty are at best problematic. The politics of this debate is obvious; the substance not so much. As with many other questions, bank-merger policy is best set with a keen understanding of recent, objective research and what it actually says about concentration as it occurs outside the gaze of those fearful only of still bigger big banks.

M071023.pdf…

10 07, 2023

Karen Petrou: The Bankruptcy of Bank-Merger Policy

Eliza Allen2023-07-10T14:18:07-04:00July 10th, 2023|The Vault|

On Wednesday, a Senate Banking subcommittee will consider bank-merger policy, surely providing a platform for its chair, Sen. Warren’s pronounced views opposing all but the smallest bank mergers and maybe not even those. Many other senators are not as adamant, but even pro-business Republicans – see J.D. Vance – think bank mergers beyond the itty-bitty are at best problematic. The politics of this debate is obvious; the substance not so much. As with many other questions, bank-merger policy is best set with a keen understanding of recent, objective research and what it actually says about concentration as it occurs outside the gaze of those fearful only of still bigger big banks.

That there is undue market power in a financialized economy that brings a raft of woes is all too clear. I thus hoped that Assistant Attorney General Kanter’s remarks last month would be a meaningful update of the Department of Justice’s anachronistic 1995 policy. It helped, but only a bit because Mr. Kanter focused principally on enforcement, leaving “broader” questions solely to the banking agencies.

They in turn have long promised a transparent merger policy, but it’s still deal-by-deal, case-by-case, crisis-by-crisis. More than a few mid-sized banks will wither away as deliberations continue because the sheer uncertainty and delays of most bank mergers undermine their economic value, particularly at a time of high interest rates, slow or no growth, tough new rules, and withering competition.

Recent antitrust research does not substantiate easy, blanket assertions about the benefits or …

28 06, 2023

DAILY062823

Eliza Allen2023-06-28T17:21:14-04:00June 28th, 2023|2- Daily Briefing|

Biden Predicts End to Overdrafts

In a speech today detailing “Bidenomics”, President Biden continued his administration’s campaign against “junk fees,” specifically targeting overdrafts.

Fed Branch Approval Faced Unusual Bowman Protest

With a cryptic statement, FRB Gov. Bowman has taken the unusual step of protesting a branch application which she and all other governors approved. The issue appears to be the fact that two commenters objected to the branch application on grounds that the bank (Vantage in Texas) discriminates against African American borrowers. The Fed’s formal approval notes only these comments and otherwise approves of the bank’s fair-lending record, also noting its satisfactory CRA rating and the fact that the bank is principally a commercial lender.

Fed Finds Big Banks Resilient, Still Wants More Rules

The Fed’s stress-test release today attempts to meld both the Board’s finding that banks are not only resilient, but also “well-positioned” for a severe recession with Vice Chairman Barr’s plans to rewrite an array of new rules (see Client Report FEDERALRESERVE72) that stress tests are only one measure of strength the “resilient” evidence itself.

Daily062823.pdf…

9 06, 2023

DAILY060923

Eliza Allen2023-06-09T16:39:43-04:00June 9th, 2023|2- Daily Briefing|

HFSC GOP Press Crypto Rewrites

The HFSC majority memo for Tuesday’s full committee hearing on digital assets reinforces Chairman McHenry’s (R-NC) determination to press ahead with legislation redesigning the federal crypto-regulatory ecosystem. As noted, the draft bill constructed with House Ag is generally unacceptable to HFSC Democrats, ensuring a more acrimonious hearing than last week’s Ag session. The witnesses all represent the private sector and generally support the new bill.

OCC Launches Consumer-Trust Campaign

The OCC last night launched a new customer-trust initiative with a new survey proposal and RFI. In accompanying remarks, Acting Comptroller Hsu emphasized that consumer trust in banks must be earned by banks that responsibly and fairly use their market power. Bolstering this new campaign, Mr. Hsu also argues that consumer trust reduces reliance on higher-risk nonbanks and gives banks the funding with which to provide through-the-cycle community lending. For its part, the OCC is working to finalize the longstanding CRA rewrite (see FSM Report CRA32), with Mr. Hsu noting the need through these rules and the OCC’s recent fair-lending rewrite to ensure fairness and LMI-household access to national banks.

Daily060923.pdf…