20 06, 2023


2023-06-20T17:15:39-04:00June 20th, 2023|2- Daily Briefing|

ECB Targets Bank Risk to NBFIs

A speech earlier today from the ECB’s top bank supervisor makes it clear that the EU is pressing ahead with FSOC’s proposed limits on bank inter-connections with NBFIs (see FSM Report SYSTEMIC95).  Karen Petrou’s memo today also addresses this issue.

New M&A Policy Sets High Bar For Banking-Agency Approval, Increases Odds Of DOJ Rejection

Making M&A a good deal harder to pull off, Assistant Attorney General Jonathan Kanter today redefined U.S. bank-merger policy in light of comments on a recent RFI (see FSM Report MERGER10) and dramatic changes since current policy was set in 1995.  The new approach reflects Biden Administration competition policy (see Client Report MERGER6) and will make it considerably more difficult for banks of all sizes to win DOJ approval if the banking agencies approve their proposed transaction after getting a new, likely more dire competitive-factor report from the Department of Justice.

FRB-KC: Community Banks Better Capitalized than GSIBs

The Kansas City Fed today released an analysis of 2022 bank capital, finding that community banks continued to hold higher levels of capital compared to G-SIBS: ten percent to six percent, respectively.  The study also found that G-SIB supplementary leverage ratios (SLR) increased thirty basis points to 5.94 percent, the first increase since the beginning of the pandemic, excluding the impact of the Fed’s temporary capital relief.


3 11, 2022


2022-11-03T17:15:32-04:00November 3rd, 2022|2- Daily Briefing|

Gruenberg Backs Bank On

In remarks late yesterday, FDIC Acting Chairman Gruenberg pointed to the importance of Bank On accounts to retain previously un- or under-banked households brought into the system following large government payments early in the pandemic.

ECB Presses Climate-Risk Capital Regs

Moving far ahead of the Fed, the ECB has announced strict plans to ensure that EU banks not only improve governance and express climate-risk stress testing, but also hold sufficient internal-capital allocations for physical and transition risk.

Data Standard-Setters to Come Under CFPB Regs

In remarks late yesterday updating the CFPB’s open-banking rulemaking efforts, Director Chopra indicated that the new consumer-data rules (see forthcoming in-depth FedFin report) will also address   how best to set public and private-sector standards to ensure industry-wide fairness and access to critical infrastructure.

IMF Climate-Risk Priorities Include GSIB Buffers

The IMF’s Deputy Managing Director Bo Li today set priorities for central banks and bank regulators addressing financial-system climate resilience.


12 10, 2022


2022-10-12T16:58:59-04:00October 12th, 2022|2- Daily Briefing|

ECB Staff: Retail CBDC Success May Hang on Interest-Rate Inducements

A new paper from European Central Bank staff looks not so much at CBDC policy objectives, but at whether central banks can achieve them and still satisfy the needs of retail depositors and businesses.  Based in part on two small, failed CBDC ventures, the paper concludes that CBDC adoption will prove harder than policy focused CBDC analyses suggest.

Barr Accepts Crypto Activities In Banks But Demands New Safety Rules, Consumer Standards

Although he did not adopt Acting Comptroller Hsu’s attack yesterday on cryptoassets, Fed Vice Chair Barr today made it clear that the Fed believes, as it and global regulators repeatedly say, that the same risks should be covered by the same rules.  Mr. Barr does believe that cryptoasset activities may be appropriate for banks if appropriate standards and internal controls are in place, noting that the Fed is now moving past its own supervisory guidance (see FSM Report CRYPTO31) to work with the FDIC and OCC to craft additional standards.

IOSCO Releases Global Online Marketing, Enforcement Standards

IOSCO today increased its focus on digitalization, moving away from longstanding edicts regarding monitoring to a set of specific standards for supervision and enforcement.  IOSCO urges supervisors to require firms to have online marketing-and-distribution standards as well as protocols governing online onboarding.


3 08, 2022


2023-01-04T13:29:59-05:00August 3rd, 2022|2- Daily Briefing|

Senate Ag Crypto Bill Lauds CFTC, Faces Many Obstacles

As we anticipated as the crypto debate continues, the Senate Agriculture Committee has sought to claim jurisdiction with a new, bipartisan bill granting the CFTC broad regulatory, supervisory, and enforcement powers over most digital-asset platforms and the assets traded on them.

ECB Study Favors CBDCs Over Private Crypto for Cross-Border Payments

study released by the ECB today argues that CBDCs would be a cheaper, safer, and more effective vehicle for cross border payments for global transactions than privately-issued cryptoassets or stablecoins.  Based on assessment of global, not just EU markets, the study thus has implications for those in the U.S. opposing a CBDC.

FRB-Minneapolis Renews Attack on Big-Bank Capital Resilience

Renewing its attack on big-bank capital ratios, the Federal Reserve Bank of Minneapolis today released its own stress-test conclusions, reinforcing its president’s longstanding view that the largest U.S. banks are woefully under-capitalized even though test results show considerable variance on a bank-by-bank basis as well as overall resilience.

FRB Philadelphia President Touts Fintech’s Financial Inclusion Potential

FRB Philadelphia President Patrick Harker today stated that fintech can increase financial inclusion, specifically citing buy-now pay-later products because they offer financial services to low- to moderate-income customers who would otherwise be locked out of traditional lending because they are more likely to be non-White, lower earning, and younger.


11 07, 2022


2023-01-24T15:11:32-05:00July 11th, 2022|2- Daily Briefing|

FSB Highlights Crypto, Stablecoin Risk

The FSB today issued an unusual statement warning of cryptoasset risk.  Rejecting the BIS’s more sanguine view that stablecoins and other digital assets have yet to prove, the FSB warns that inter-connectivity with the financial system already poses grave hazard.

HFSC to Consider CRA Reform, Rewrite

As noted, the HFSC Consumer Protection and Financial Institutions Subcommittee on Wednesday will consider the inter-agency CRA rule (see FSM Report CRA32).

Basel Committee Will Be Slow to Advance Climate-Risk Capital, Disclosure Standards

The head of the Basel Committee, Pablo Hernández de Cos, today reiterated that global bank regulators are dedicated to a cautious but determined set of climate-risk standards.

BIS Group Charts Course to Cross-Border CBDC

As part of the G20 cross-border payments roadmap, the BIS, IMF, and World Bank released a joint report today urging governments working on a CBDC to coordinate their designs and account for cross-border functionality early in their process.

FRB Atlanta Blog Refutes Dem’s Zelle Allegations

Coming in the wake of a letter sent by Senate Democrats alleging Zelle of mishandling fraud, FRB Atlanta today published a blog post defending the payments industry in cases where customers willingly authorize a fraudulent payment.

Chopra Promises to Promote Fierce Competition

CFPB director Chopra today reasserted his agency’s authority over ensuring financial-market competitiveness, describing recent actions against credit-card companies (see FSM Report CREDITCARD35), bigtech, and “junk fees” (see FSM Report CONSUMER38).


1 06, 2022


2023-02-21T12:47:30-05:00June 1st, 2022|2- Daily Briefing|

IMF Charts USD Decline

The IMF today published a blog in its Chart-of-the-Week series portraying the declining status of the US dollar as the global reserve currency.   As noted last week (see Client Report CBDC13), the dollar’s dominance is a core Congressional and FRB criterion when considering the need for a U.S. CBDC and this report may increase calls by some in Congress for more rapid action (see FSM Report CBDC4).  The post highlights the dollar’s dip below 59 percent of global foreign-exchange reserves in the final quarter of 2021, but also states that the euro, yen, and pound have not replaced it, nor has the renminbi, which now accounts for only a quarter of the shift from the dollar in recent years due in part to Russia’s holding of nearly a third of global renminbi reserves.

IMF Presses Central Banks to Go Green

A senior IMF advisor, Tobias Adrian, today argued that central banks should include sustainability considerations not only in their financial-stability and monetary-policy analyses, but also in their balance sheets.  This follows comments earlier today from President Lagarde that the ECB has an “open mind” about using the central bank’s lending facilities to foster the transition to carbon neutrality.


28 03, 2022

Karen Petrou: Why the Fed Might Bail Out the Commodity Market

2023-03-27T15:57:01-04:00March 28th, 2022|The Vault|

In the midst of chaos, volatility always makes matters worse and this is very much the case with the commodities sector.  This has led to growing speculation that central banks will step in should unprecedented price swings show signs of systemic impact.  As we noted, we don’t know a central banker that wants to bail out commodities.  But none of them wanted to bail out anyone else either.  If market stress turns systemic, then central banks will step in.  Indeed, they may intervene even if stress seems manageable if they also believe that public welfare is at risk when core commodities go from pricey to prohibitive.

In the U.S., the Fed will resist calls to backstop commodities companies or traders for as long as it can by citing what it believes to be its limited mandate even as it argues that its anti-inflation policies will stabilize markets – just you wait.  However, whatever the Fed is able to do about inflation will take time and whatever it does about its portfolio to address inflation will exacerbate commodity-market stress.

Three possible sources of extreme volatility are already on the horizon.

First, there’s the liquidity stress sparked by CCP margin demands.  This was the culprit in the letter from energy traders to the European Central Bank and it’s at least as much of a factor in the U.S.  The more commodity-market volatility, the higher clearinghouse initial and variation margin demands and the harder it is to post eligible assets already scarce …

22 03, 2022


2023-04-03T13:01:29-04:00March 22nd, 2022|2- Daily Briefing|

BIS Advances Cross-Border CBDC Settlement

The BIS today announced significant progress accelerating the ability of CBDCs to handle cross-border payments.  Working with central banks in Australia, Singapore, Malaysia, and South Africa, the BIS described two prototype platforms for multi-currency international settlement that in their view prove that central banks can transact directly with each other using a shared platform.

ECB Head Criticizes Crypto, Calls for CBDC

Although we have not been able to confirm this by official remarks, press reports today indicate that ECB head Christine Lagarde has concluded that crypto-assets and -currency are significant factors in Russian-sanctions evasion.

CFPB Attaches UDAAP Label to Product-Review Practices

Building on FTC action, the CFPB today issued guidance stipulating that contractual-gag orders and certain other practices (e.g., employee or paid reviews) affecting the integrity of consumer reviews are illegal in credit-card, mortgage, or other consumer-finance marketing.  The law on which this view is premised is a provision in the CFPB’s authorizing statute providing enforcement power for unfair, deceptive, or abusive acts or practices (UDAAP).

Treasury Lays out Digital-Asset Work Plan

In remarks today, Treasury Under-Secretary Liang laid out her agency’s plans to execute President Biden’s digital-asset order (see Client Report CRYPTO26).  Treasury’s report on money and the payment system will address current weaknesses (e.g., high fees for low-balance accounts, slow and costly remittances), recognize the strength of FDIC insurance and other safeguards, build on FedNow, and establish a way for stablecoins to access the payment system.


18 03, 2022


2023-04-03T14:21:59-04:00March 18th, 2022|2- Daily Briefing|

Commodity-Market Backstop Prospects, Impact

In this alert, we update clients on our assessment of policy consequences related to commodity-market strains.  Notably, a letter from European energy traders to the ECB has been made public indicating stress in this sector is so severe that traders are seeking emergency liquidity support.  While directed to the ECB, the letter calls upon all central banks to provide this support, making it likely that a similar plea has been sent to the Federal Reserve.

Congress Wants More, Tougher Sanctions

Although witnesses at yesterday’s Senate Banking Committee sought to assure Congress that digital currency does not promote sanctions evasion (see Client Report SANCTION17), legislation continues to advance to curtail any form of sanctions evasion.  As we noted yesterday, senior Senate Democrats have introduced a bill expressly targeting digital assets and exchanges while HFSC marked up numerous bills tightening more conventional financial-transmission and policy channels.


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