#EO

28 02, 2024

DAILY022824

2024-02-29T11:26:05-05:00February 28th, 2024|2- Daily Briefing|

HFSC Dems Press for New Bank-Merger Policy

Although she issued a statement strongly opposed to the CapOne/Discover merger after it was announced, HFSC Ranking Member Waters (D-CA) today led a letter instead focusing on the need for the banking agencies and DOJ to quickly issue updated merger policies.

US Standards Complicate Transborder Personal-Financial Data Flows

The President plans later today to issue an executive order banning the transfer of sensitive data to “countries of concern” and certain persons subject to their jurisdiction.

Fed Worries About Regional-Bank Risk

Anna Kovner, Director of Financial Stability Policy Research at the New York Fed, today outlined four sources of systemic risk that worry the central bank even though the Fed still sees risks as manageable according to the analyses released last October (see Client Report SYSTEMIC97).

Daily022824.pdf

22 12, 2023

DAILY122223

2023-12-29T10:01:49-05:00December 22nd, 2023|2- Daily Briefing|

President Imposes Sweeping Secondary Sanctions

Responding to ongoing evidence that sanctions are not working as hoped despite recent Treasury assurances they are, the President today issued a sweeping executive order and Treasury laid out secondary sanctions for financial institutions found to facilitate Russian Federation finances related to its “war machine.”  We will shortly provide clients with an in-depth analysis of these actions which pose significant threats to dollar-clearing access for financial institutions that have so far been largely outside the reach of existing sanctions.

Treasury Requests Feedback for Financial Inclusion Strategy

Following a statutory directive, Treasury today issued an RFI to develop a national strategy for financial inclusion.  We will shortly provide clients with an in-depth report on the RFI.  Noting significant disparities in banking-system access for LMI, low-wealth, Black, and Hispanic households as well as discrepancies in rates of stock and business ownership between white, Black, and Hispanic households, the RFI invites recommendations for policy, government programs, financial products, technology, and other tools and market infrastructure.

Brown Prioritizes Housing, ILC Bill, AI in 2024

The Senate Banking Committee today released its policy outlook entering 2024 prioritizing affordable housing, enacting the ILC-powers bill (see FSM Report ILC17), and AI financial-sector policy (likely here picking up the Warner-Kennedy bill we will shortly assess in depth).

Daily122223.pdf

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31 10, 2023

FedFin Assessment: New White House AI Policy Promises New KYC Requirements, Banking-Agency Guidance

2023-10-31T13:33:25-04:00October 31st, 2023|The Vault|

In this report, we assess the detailed executive order (EO) issued late Monday afternoon after days of private showings of selected versions. Much in the EO’s binding provisions address near-term AI-related threats to national-security, pandemic-risk, and infrastructure vulnerabilities and much related to AI-related opportunities derive from internal procedures Mr. Biden urges the federal government to develop along with workforce protections and biomedical research. The EO also reiterates the Administration’s values and presses agencies to work still harder on voluntary industry standards that many have been drafting or disagreeing on since the White House and Congress first called attention to AI risk. What comes of these provisions in the EO remains to be seen, but the Administration has also used tools such as the Defense Production Act’s authorization for direct economic intervention to mandate an array of new AI commercial and technology safeguards.

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

31 10, 2023

AI3

2023-10-31T10:58:11-04:00October 31st, 2023|5- Client Report|

FedFin Assessment:  New White House AI Policy Promises New KYC Requirements, Banking-Agency Guidance

In this report, we assess the detailed executive order (EO) issued late Monday afternoon after days of private showings of selected versions.  Much in the EO’s binding provisions address near-term AI-related threats to national-security, pandemic-risk, and infrastructure vulnerabilities and much related to AI-related opportunities derive from internal procedures Mr. Biden urges the federal government to develop along with workforce protections and biomedical research.  The EO also reiterates the Administration’s values and presses agencies to work still harder on voluntary industry standards that many have been drafting or disagreeing on since the White House and Congress first called attention to AI risk.  What comes of these provisions in the EO remains to be seen, but the Administration has also used tools such as the Defense Production Act’s authorization for direct economic intervention to mandate an array of new AI commercial and technology safeguards.

AI3.pdf

22 09, 2022

FedFin on: The Cryptoverse Has A Big Black Hole

2022-09-30T12:03:14-04:00September 22nd, 2022|The Vault|

In this report, we follow our earlier analysis of Treasury’s CBDC recommendations and housing finance  with an analysis of another Treasury report in response the President’s executive order focused on the overall construct of cryptoassets in the U.S.  Treasury here makes its views even clearer than it did when favoring a CBDC.  It simply sees no “natural use case” for…

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

22 09, 2022

GSE-092222

2022-09-26T08:43:50-04:00September 22nd, 2022|4- GSE Activity Report|

The Cryptoverse Has A Big Black Hole

In this report, we follow our earlier analysis of Treasury’s CBDC recommendations and housing finance  with an analysis of another Treasury report in response the President’s executive order focused on the overall construct of cryptoassets in the U.S.  Treasury here makes its views even clearer than it did when favoring a CBDC.  It simply sees no “natural use case” for cryptoassets or cryptocurrency beyond speculation in the lending and investment arenas where, it states, very stringent rules should quickly spoil the funding.  This isn’t to say that Treasury disses digital assets – quite the contrary – but its views on cryptoassets make clear that crypto-mortgages are a long, long way away if they are anywhere at all.

GSE-092222.pdf

15 09, 2022

DAILY091522

2022-10-13T11:49:04-04:00September 15th, 2022|2- Daily Briefing|

Financial Transactions to Get More Stringent CFIUS Scrutiny

The President today issued an executive order (EO) redefining key criteria used by the Committee on Foreign Investment in the U.S. (CFIUS).

BNPL Faces DOA Consumer Standards

In conjunction with issuing a lengthy report, CFPB Director Chopra today announced that he has directed staff to work on new interpretive rules or guidance for the BNPL sector.

Basel Battles On

Acting as anticipated following instructions from on-high, the Basel Committee today “exchanged views” on pending crypto regulation (see FSM Report CRYPTO29) – terminology suggesting the committee has yet to reach agreement on this controversial consultation despite a request by central bankers and supervisory heads to finalize standards by year end.

Fed Joins Agencies with CRE Workout Policy

After a delay doubtless reflecting the need to run policies by Michael Barr, the FRB today proposed the same CRE-workout policies released for comment in early August by the OCC, FDIC, and NCUA.

Waters Tries Late-Game CRA Tackle

Chairwoman Waters (D-CA) today announced that she has introduced legislation to update the CRA, making the standards tougher for banks but – as far as known so far – failing to extend the law’s reach to nonbanks as urged by CFPB Director Chopra and Sen. Warren (D-CA), among others.

Daily091522.pdf

21 03, 2022

m032122

2023-04-03T13:18:30-04:00March 21st, 2022|6- Client Memo|

How to Set Course to a Digital Future

Last week, we laid out the macrofinancial implications of the Ukraine crisis – i.e., its impact on the global financial-and-regulatory order.  Some of this analysis is founded on President Biden’s digital-asset executive order, which also has profound and immediate impact on critical macroprudential issues at the border of innovation and regulation to which we now turn.  To forecast how digitalization will come upon us, the digital-asset order must be read in the Administration’s broader context in which high-impact political issues, such as racial equity, weigh at least as heavily as the complexities of CBDC or even the benefit of a future financial crises foregone.

m032122.pdf

21 03, 2022

Karen Petrou: How to Set Course to a Digital Future

2023-04-03T13:18:42-04:00March 21st, 2022|The Vault|

Last week, we laid out the macrofinancial implications of the Ukraine crisis – i.e., its impact on the global financial-and-regulatory order.  Some of this analysis is founded on President Biden’s digital-asset executive order, which also has profound and immediate impact on critical macroprudential issues at the border of innovation and regulation to which we now turn.  To forecast how digitalization will come upon us, the digital-asset order must be read in the Administration’s broader context in which high-impact political issues, such as racial equity, weigh at least as heavily as the complexities of CBDC or even the benefit of a future financial crises foregone.

Administration policy based on Democratic politics is set not only by the digital-asset order, but also by other White House directives that will define the boundaries of what Treasury and the agencies – the Fed included at least to a point – will do.  To forecast digital-asset policy, one must thus also divine the outcome of two other executive orders.

First, there’s the President’s competition directive.  Every critical consumer-protection question under the CFPB’s purview is now considered first and foremost in terms of competition, with the agency’s director making it manifestly clear that almost anything done by any big bank is a target for structural reform.  Director Chopra doesn’t like fintech or biotech much better than most banks do, but his approach to digital assets is likely only to squelch big banks as much as he can and thus to drive cryptoassets further into …

14 03, 2022

Al031422

2023-04-03T15:12:45-04:00March 14th, 2022|3- This Week|

A FULL-FORCE CRYPTO CRACKDOWN

Spurred in part by the critical role cryptocurrency is playing in the Ukraine crisis, the Biden Administration last week finalized a long awaited “whole-of-government policy construct (see Client Report CRYPTO26) with far-reaching, immediate implications not only for the Executive-Branch agencies that must now do as they are told, but also the more-or-less independent banking agencies that will try to make the White House as happy as possible.  Touching on another key question — who has payment-system access — the Fed last week revised its 2021 proposal with a replacement request for comment (see FSM Report PAYMENT24) that now opines just a bit more on which companies will get the most scrutiny if they seek Reserve Bank master accounts and services.

Al031422.pdf

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