#credit risk – Page 3 – Federal Financial Analytics

26 07, 2023

CAPITAL229

Eliza Allen2023-07-26T14:30:18-04:00July 26th, 2023|5- Client Report|

FedFin Assessment: What to Watch in the Regulatory-Capital Rewrite

As promised, we plan in-depth coverage of the Fed and FDIC meetings tomorrow as well as of the capital rewrites they are set to propose no matter all the warning shots from Congressional Republicans. In this report, we provide an overview of each of the rules the agencies will propose based on key issues in the Basel end-game standards they will finally advance. We do not focus on details or how the U.S. may adapt these rules except where public releases have provided advance insight. Instead, we highlight key issues to provide vital background and context of tomorrow’s actions as well as key decision points on which comment and political advocacy are sure to center.

CAPITAL229.pdf…

5 07, 2023

DAILY070523

Eliza Allen2023-07-05T16:15:35-04:00July 5th, 2023|2- Daily Briefing|

Basel Targets Credit-Risk Models, Assumptions

The Basel Committee yesterday issued a newsletter highlighting recent internal credit-risk discussions as well as supervisory action and remaining concerns in this area. Although few specifics are provided, national supervisors’ main priorities include governance controls around model risk management, capturing economic uncertainty, and identifying credit deterioration in vulnerable sectors and borrowers. The newsletter also notes that supervisors have issued guidance on IRB models and taken remedial action for some banks with under-calibrated probability-of-default models—issues not yet addressed in the U.S. that may come in concert with the pending end-game capital rules.

FSB/IOSCO Focus on OEF Redemption Risk

Departing from the SEC’s swing-pricing approach to open-end fund risk, global regulators today proposed a new exit-fee construct. If the U.S. chooses to advance this – as it well may given the SEC’s role on these bodies – it will almost surely require a new SEC proposal, significantly delaying U.S. action in this controversial area. The FSB’s consultation proposes three OEF “buckets” intended to reduce liquidity mismatch risk by mandating new “anti-dilutive” liquidity-risk mitigation tools that not only create new daily-redemption obstacles as OEF assets become increasingly illiquid, but also impose new fees stipulated in the accompanying the IOSCO consultation.

Daily070523.pdf…

8 02, 2023

FedFin on: Credit-Card Late Fee Regulation

Arezou Rafikian2023-02-09T09:43:39-05:00February 8th, 2023|The Vault|

Following on a controversial advance notice of proposed rulemaking, the CFPB has now released an NPR setting specific standards for credit-card late fees that also eliminates the inflation adjustments established by the Federal Reserve when implementing the 2009 credit-card law. The NPR also seeks comment on still more stringent late-fee restraints and limits on some or all of the other penalty fees now charged by some credit-card issuers. When issuing the ANPR, the Bureau also noted that it plans to advance other initiatives under its “junk-fee” standards, likely starting with those pursuant to ….

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

8 02, 2023

CREDITCARD36

Eliza Allen2023-02-08T13:00:21-05:00February 8th, 2023|1- Financial Services Management|

Credit-Card Late Fee Regulation

Following on a controversial advance notice of proposed rulemaking, the CFPB has now released an NPR setting specific standards for credit-card late fees that also eliminates the inflation adjustments established by the Federal Reserve when implementing the 2009 credit-card law. The NPR also seeks comment on still more stringent late-fee restraints and limits on some or all of the other penalty fees now charged by some credit-card issuers. When issuing the ANPR, the Bureau also noted that it plans to advance other initiatives under its “junk-fee” standards, likely starting with those pursuant to the Electronic Funds Transfer Act affecting a wide range of payment and transaction-account products. Should it then follow the model proposed here for credit cards, significant alterations in current business practice could occur with uncertain consumer benefits despite nominal upfront savings.

CREDITCARD36.pdf…

5 12, 2022

DAILY120522

Eliza Allen2022-12-05T16:58:52-05:00December 5th, 2022|2- Daily Briefing|

Hsu Reiterates Importance of Credit Risk Management, Diversity

Remarks today from Acting Comptroller Hsu break no new ground on credit risk management or diversity, two topics discussed before a group of bank risk managers. Mr. Hsu again emphasizes the importance of effective credit risk management, noting in particular that risk managers should look to produce accurate risk identification and ratings, focus on concentrated portfolios and vulnerable borrowers, and conduct stress tests and sensitivity analyses as interest rates and inflation continue to change.

Daily120522.pdf…

25 07, 2022

DAILY072522

Eliza Allen2023-01-04T15:47:24-05:00July 25th, 2022|2- Daily Briefing|

Stablecoin Bill Still in Limbo

As we noted last week, the fate of stablecoin legislation at this week’s HFSC mark-up has been uncertain. The committee staff memo today does not include a bill in this area; it is our understanding that negotiations continue on a draft amenable to both Chairwoman Waters (D-CA) and Ranking Member McHenry (R-NC).

OCC Seeks Fintech, Nonbank Analyses

The OCC today calls for academic and policy-focused papers on the impact of fintech and nonbanks on banking and the markets for lending, deposit-taking, and payment services. This sweeping inquiry is designed to inform the agency as policy continues to take shape in these high-profile areas, with the announcement today providing no insight into whether these papers – which will doubtless come also from trade associations and other advocacy groups – will do more than provide a symposium’s worth of discussion.

Stablecoin Rules – or Lack Thereof – Likely to Remain

As noted in media this afternoon, HFSC will in fact not mark up a stablecoin bill on Wednesday. Instead, some staff indicate that a discussion draft will be released so that the process of crafting a bill can continue in August in hopes of a September vote. However, even if one were to occur, the odds of legislation in this Congress are slim to none at so late a date in the absence of any meaningful Senate Banking action in this arena.

Daily072522.pdf…

3 06, 2022

DAILY060322

Eliza Allen2023-02-10T16:02:13-05:00June 3rd, 2022|2- Daily Briefing|

Agency Heads Stress Need for CRA Reform

Acting Comptroller Hsu, Fed Vice Chair Brainard, and Acting FDIC Chairman Gruenberg today took questions on the controversial, far-reaching inter-agency CRA regulatory rewrite (see FSM Report CRA32).

FRB-Cleveland Study: Small-Business Lending Continues Race/Ethnic Disparities

A new paper published by the Federal Reserve Bank of Cleveland finds evidence that race-based lending disparities persisted through the pandemic, concluding that Black business owners in particular struggled to receive loans compared to whites, fintechs have not overcome credit disparities, and minority-owned businesses were less likely to receive the PPP amounts for which they applied.

Waller Seeks Balance in Crypto Rules

FRB Gov. Waller today described the advantages of innovative, unregulated markets such as that created by cryptography at its outset.

FinCEN Takes Baby Step to No-Action Letters

Reflecting demands from Congress in recent AML law (see FSM Report AML133), FinCEN today issued an advance notice of proposed rulemaking outlining how a no-action letter process might work.

Daily060322.pdf…

27 05, 2022

GSE-052722

Eliza Allen2023-02-21T13:34:07-05:00May 27th, 2022|4- GSE Activity Report|

Now You Know

FHFA has finalized its October proposal to create a new qualitative capital and governance disclosure regime, going well beyond the disclosures initially mandated in the final capital rule to instill market discipline long associated with private companies, not conservatorships. FHFA’s goal is to ready Fannie and Freddie for a return to private markets without implicit-guarantee guardrails, but the chances of that in the near future seem small. Minor pricing differences on debt and derivatives are thus the new rule’s most likely result.

GSE-052722.pdf…

12 04, 2022

DAILY041222

Eliza Allen2023-03-02T11:23:53-05:00April 12th, 2022|2- Daily Briefing|

FRB-Dallas Targets Renewable Energy Credit Risk

Venturing farther into politically-contentious territory, the Federal Reserve Bank of Dallas today issued a report finding that lenders with credit exposure to commercial renewable energy projects face unique and evolving risks that may adversely affect credit performance. It bases this conclusion on numerous risk factors such as a lack of vertical integration seen in traditionally regulated markets, underperformance relative to forecasts, counterparty and merchant risk, and transmission challenges.

CFPB Takes Promised Tough Enforcement Action

Acting promptly on his recent threat to sanction “repeat offenders,” the CFPB today went after TransUnion and a former executive for what it asserts are continuing violations of law that warrant civil money penalties, injunctive relief, and consumer compensation. This is the first significant enforcement action filed by Director Chopra and signals that, as we forecasted, the Bureau will act quickly on his new policies.

BIS Presses CBDC’s Financial-Inclusion Upside

Continuing its advocacy for “two-tier” CBDCs (see Client Report CBDC6), the BIS today released a study arguing that financial inclusion benefits are among the most important that should lead central banks to offer a fiat digital currency.

Toomey Continues Calls for Reserve Bank Reform

Renewing his attack against Neal Kashkari, head of the Minneapolis Federal Reserve Bank, Senate Banking Committee Ranking Member Toomey (R-PA) today also ramped up demands for structural Federal Reserve System reform.

Daily041222.pdf…

14 02, 2022

DAILY021422

Eliza Allen2023-04-04T16:02:06-04:00February 14th, 2022|2- Daily Briefing|

Gensler Stands by Climate-Risk Disclosures
In a Twitter thread this weekend, SEC Chairman Gensler pushed back at Sen. Warren’s (D-MA) criticisms that the Commission is moving too slowly on climate-risk disclosures.

Renew Attack on ERISA Waivers
Joined by Sen. Tina Smith (D-NH), Sen. Warren (D-MA) has renewed a longstanding Democratic demand that the Department of Labor deny ERISA waivers to large banks found to have engaged in illegal or unethical behavior.

SEC Wins a Big One
Making it clear that, despite GOP pushback, the SEC can and will go after crypto products, the Commission today reached a high-profile, multi-million dollar settlement with BlockFi Lending LLC that essentially prohibits its lending products and, by inference, any others unwilling to undergo protracted litigation leading to still more costly sanctions.

Hsu Targets Bank LMI Lending for CRA Push
In remarks today, Acting Comptroller Hsu stated that, while banks have done considerably better by LMI communities in recent years, deep gaps remain that, at least for Black households, may now be worse than ever.

Daily021422.pdf…