#DIHC – Federal Financial Analytics

24 03, 2023

FedFin Analysis: Whom and What the FDIC and Fed Can Save How

Arezou Rafikian2023-03-24T17:05:38-04:00March 24th, 2023|The Vault|

Recent editorials and other media have often said that the FRB and/or FDIC have powers or taken actions that is not the factual case as we understand it. Members of Congress also appear sometimes willing to make assertions about what agencies can do now even if it is unclear if there is statutory authority to do so. We have provided individual clients with key clarifications, but do so now more generally to support strategic and advocacy decision-making. Of particular importance is the authority the FDIC is said to have or lack related to uninsured deposits; as detailed below, the agency actually has significant authority to do so as well as even to back BHC debt, as long as certain stringent conditions are met. As detailed in FSM Report RESCUE65, Congress limited both the FDIC and Fed in hopes that….

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

24 03, 2023

RESCUE79

Eliza Allen2023-03-24T16:30:20-04:00March 24th, 2023|5- Client Report|

FedFin Analysis: Whom and What the FDIC and Fed Can Save How

Recent editorials and other media have often said that the FRB and/or FDIC have powers or taken actions that is not the factual case as we understand it. Members of Congress also appear sometimes willing to make assertions about what agencies can do now even if it is unclear if there is statutory authority to do so. We have provided individual clients with key clarifications, but do so now more generally to support strategic and advocacy decision-making. Of particular importance is the authority the FDIC is said to have or lack related to uninsured deposits; as detailed below, the agency actually has significant authority to do so as well as even to back BHC debt, as long as certain stringent conditions are met. As detailed in FSM Report RESCUE65, Congress limited both the FDIC and Fed in hopes that the Dodd-Frank orderly-liquidation authority (OLA, see FSM Report SYSTEMIC30) would permit orderly resolution of even the largest banks and nonbanks without long-term federal support; a subsequent FedFin report will bring the assessment of OLA powers into the current crises’ context given that Congress will surely seek to determine why the FDIC and its sister authorities chose to provide taxpayer support rather than deploy OLA.

RESCUE79.pdf…

4 10, 2022

DAILY100422

Eliza Allen2022-10-05T10:36:14-04:00October 4th, 2022|2- Daily Briefing|

IMF Calls for Open-End Fund Swing Pricing

The IMF today released a study of open-end funds sure to guide the action promised by SEC Chairman Gensler (see Client Report INVESTOR20).

Fed Study: Climate-Risk Insurance Cross-Subsidies Pose Moral Hazard, Financial Risk

Using homeowners’ insurance as a proxy for climate-risk insurance, a Fed staff study finds that the decoupling of rates and risk raises moral hazard and causes policy-holders in lower-risk and less restrictively regulated states to subsidize those in riskier states, where rates have been outpaced by losses.

Yellen Highlights Need for Crypto Reg at Racial Equity Roundtable

At a Treasury roundtable on racial equity and economic inequality, Treasury Secretary Yellen today reiterated the importance of the cryptoasset standards recommended yesterday by the Financial Stability Oversight Council.

Fed Sets Supervisory Standards for a Non-Traditional IDI Parent

The Federal Register today includes the Federal Reserve’s final supervisory framework for DIHCs controlled by insurance companies.

Final FHLB Listening Session Brings System Praise, Resistance to Change

We will shortly provide clients with an in-depth report on the last session FHFA held today listening to dozens of views on the future of the Federal Home Loan Bank System.

Daily100422.pdf…

25 03, 2022

Daily032522

Arezou Rafikian2023-03-27T16:04:54-04:00March 25th, 2022|2- Daily Briefing|

Fed Puts Off Finalizing New DIHC Framework
The FRB today extended the comment deadline on a longstanding proposal crafting a new regulatory framework for depository institution holding companies principally engaged in insurance services.

CFPB Wants to Hear More re Pricing Practices
Saying it has been swamped with consumer tales about “junk fees,” the CFPB today extended the comment deadline until April 11 on its request for views on this hot topic.

Bipartisan Crypto Construct Harder to Build than Describe
On a Politico webcast last night, Sens. Kirsten Gillibrand (D-NY) and Cynthia Lummis (R-WY) announced a bipartisan alliance to craft cryptoasset standards they expect to see on the Senate floor by year-end.

Waller Still Wants Little to Do with a CBDC
At a feisty panel today, FRB Gov. Chris Waller stood by his view that a CBDC is “a solution in search of a problem.”

Senate Democrats Demand Overdraft-Fee Fix
Sen. Rev. Warnock (D-GA) and Chairman Brown (D-OH) joined other Democrats demanding lower or eliminated overdraft fees.

FDIC Starts Process of Revising Bank-Merger Policy

The FDIC today has officially released the bank-merger RFI that now-Acting Chairman Gruenberg and CFPB Director Chopra sought to release under Chair Jelena McWilliams.

Daily032522.pdf…

28 01, 2022

Daily012822

Eliza Allen2023-04-11T15:59:03-04:00January 28th, 2022|2- Daily Briefing|

Toomey Raises New Objections to Fed Slate
Adding to his objections to Fed nominees other than Mr. Powell, Senate Banking Ranking Member Toomey (R-PA) today cited missing paperwork.

Board Advances Longstanding DIHC/Insurance Construct
The Federal Reserve today proposed new supervisory guidance for DIHCs principally engaged in insurance activities, also detailing a new supervisory rating system.

Daily012822.pdf…

8 10, 2021

FedFin on: Bank Merger Restrictions

Arezou Rafikian2023-06-20T15:33:46-04:00October 8th, 2021|The Vault|

Progressive Democrats in the House and Senate have introduced legislation demanding an array of new decision factors governing bank M&A transactions and new or even revised BHC activities. President Biden’s executive order demanding more competitive U.S. markets includes numerous bank-related provisions, but does so largely through requests of independent agencies such as the Federal Reserve to work with the Department of Justice to reduce bank consolidation and enhance community service. This legislation backs up these goals with binding requirements that dramatically alter the public-interest, financial, and competitive analyses on which M&A or BHC activities have long been assessed. Many more acquisitions, especially by or among large banks, would almost surely be rejected and the process might also become so public as to undermine the confidentiality essential to initial M&A agreement.

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

8 10, 2021

MERGER8

Arezou Rafikian2023-06-20T15:33:35-04:00October 8th, 2021|1- Financial Services Management|

Bank Merger Restrictions

Progressive Democrats in the House and Senate have introduced legislation demanding an array of new decision factors governing bank M&A transactions and new or even revised BHC activities. President Biden’s executive order demanding more competitive U.S. markets includes numerous bank-related provisions, but does so largely through requests of independent agencies such as the Federal Reserve to work with the Department of Justice to reduce bank consolidation and enhance community service. This legislation backs up these goals with binding requirements that dramatically alter the public-interest, financial, and competitive analyses on which M&A or BHC activities have long been assessed. Many more acquisitions, especially by or among large banks, would almost surely be rejected and the process might also become so public as to undermine the confidentiality essential to initial M&A agreement.

MERGER8.pdf…