#Gruenberg – Federal Financial Analytics

15 03, 2023

FedFin Assessment: Post-SVB Deposit Insurance Reform

Arezou Rafikian2023-03-15T16:58:47-04:00March 15th, 2023|The Vault|

Cementing prior denouncements of 2018 Dodd-Frank “rollbacks” into legislative action, 17 Democratic senators and 31 House Members today took direct aim at Trump-era banking policy by introducing legislation that would repeal Title IV of the Economic Growth, Regulatory Relief, and Consumer Protection Act. But, while this initiative is gaining considerable attention, its legislative prospects are dim – indeed, even Senate Banking Committee Chairman Brown (D-OH) suggested as much…

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

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15 03, 2023

DEPOSITINSURANCE118

Eliza Allen2023-03-15T12:48:33-04:00March 15th, 2023|5- Client Report|

FedFin Assessment: Post-SVB Deposit Insurance Reform

As promised in our first post-SVB impact assessment (see Client Report RESOLVE49), this report begins a series of analyses of specific policy issues. We start here with possible changes to FDIC insurance based on comments from Reps. Maxine Waters (D-CA), Blaine Luetkemeyer (R-MO), and other arguing either that the $250,000 limit for FDIC coverage needs to be eliminated or sharply increased. We also analyze the prospects for shifting the burden of higher DIF premiums to large banks as recommended by the ICBA, ending the FHLB’s super-lien due to the resulting, significant increase in FDIC resolution costs in recent failures, changes to the treatment of brokered deposits, and revisions to the FDIC’s overall risk-based assessment system (see FSM Report DEPOSITINSURANCE96). Other resolution issues – e.g., the future of proposed regional-bank standards (see FSM Report RESOLVE48) and bank merger policy will be covered in future reports along with the prospects for significant changes in bank capital, liquidity, and other prudential standards.

DEPOSITINSURANCE118.pdf…

28 02, 2023

DAILY022823

Eliza Allen2023-02-28T17:16:34-05:00February 28th, 2023|2- Daily Briefing|

CFPB Treads Gingerly on Mortgage-Disclosure Exceptions

In a notice emphasizing the CFPB’s distaste for allowing regulatory exceptions, the Bureau asks for comment on an application for one to which it seems a bit more sympathetic.

FDIC Sees Sunny Side of Bank Earnings Data

In its review of banking-industry fourth-quarter results, the FDIC today notes a sharp increase in the gap between bank loan yield and deposit interest costs.

Basel Forecasts End-Game Capital Shortfalls

The Basel Committee today issued its latest monitoring report, finding that large global banks saw capital decreases to pre-pandemic levels even as liquidity ratios continued to improve.

Bipartisan China Bills Fly Through HFSC Markup

As anticipated, HFSC today reported five bills to censure China and protect Taiwan, along with bills addressing drug-trafficking financing, biomedical security and bank service company examinations.

Democrats Stand Firm versus Privacy Preemption

Following an orderly and bipartisan start to today’s HFSC markup, Democrats and Republicans today came to verbal blows over the Chairman’s data privacy bill.

Daily022823.pdf…

24 01, 2023

DAILY012423

Eliza Allen2023-01-24T16:47:35-05:00January 24th, 2023|2- Daily Briefing|

FSB Chair Presses Need to Finalize Global Crypto Standards

In remarks today, FSB Chair Klaas Knot reiterated FSB’s 2023 priorities regarding NBFI, crypto, and climate change risks, also emphasizing that the FSB seeks to improve financial resilience rather than predicting the cause of the next financial crisis.

McHenry, Hill Suggest Crypto Action Plan

In a new tweet, HFSC Chairman McHenry (R-NC) emphasized the crypto plan he discussed earlier in a media interview.

Brown, Van Hollen Press Tough TLAC, Regional-Bank Resolvability Rule

Senate Banking Committee Chairman Brown (D-OH) and Sen. Van Hollen (D-MD) sent a letter to FDIC Chairman Gruenberg and FRB Vice Chair Barr late yesterday praising the agencies’ recent ANPR on large bank resolution standards (see FSM Report RESOLVE48), calling for TLAC that prevents taxpayer bailouts in the event of failure.

CFPB Kicks Off Credit Card Regulatory Rewrite

Following its credit card late-fee notice of proposed rulemaking (see FSM Report CREDITCARD35), the CFPB today sought comment on the credit card sector as a whole for its biennial review of the industry.

Daily012423.pdf…

12 01, 2023

FedFin on: Financial-Policy Consequences of Silvergate’s Travails

Eliza Allen2023-01-12T11:04:34-05:00January 12th, 2023|The Vault|

Karen Petrou’s memo earlier this week and her comments to the American Banker about Silvergate have sparked many client questions. In this report, we provide additional context for aspects of this bank’s condition with policy consequences. High-profile cases such as this have a long history of suddenly shifting long-pending policies; depending on outcomes, this bank’s challenges and those of any other crypto-heavy banks will almost surely do so. In general, the case already confirms U.S. regulators of the wisdom of additional capital for crypto-exposed banks along the lines recently finalized by global regulators (see FSM Report CRYPTO37). However, it also raises significant questions about the role of the Federal Home Loan Banks, brokered deposits, resolution policy, and AOCI recognition – and these are just for starters as the bank struggles to stay afloat.

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

11 01, 2023

CRYPTO38

William Cross2023-01-12T11:03:19-05:00January 11th, 2023|5- Client Report|

Financial-Policy Consequences of Silvergate’s Travails

Karen Petrou’s memo earlier this week and her comments to the American Banker about Silvergate have sparked many client questions. In this report, we provide additional context for aspects of this bank’s condition with policy consequences. High-profile cases such as this have a long history of suddenly shifting long-pending policies; depending on outcomes, this bank’s challenges and those of any other crypto-heavy banks will almost surely do so. In general, the case already confirms U.S. regulators of the wisdom of additional capital for crypto-exposed banks along the lines recently finalized by global regulators (see FSM Report CRYPTO37). However, it also raises significant questions about the role of the Federal Home Loan Banks, brokered deposits, resolution policy, and AOCI recognition – and these are just for starters as the bank struggles to stay afloat.

CRYPTO38.pdf…

5 01, 2023

GSE-010523

Eliza Allen2023-01-05T12:37:19-05:00January 5th, 2023|4- GSE Activity Report|

End-Game Standards in the End-Time

As we previously noted, the U.S. banking agencies will finally, finally, finally get around to proposing their version of the Basel IV capital rules more recently dubbed the “end-game” standards. These will come with new, unique U.S. fillips due to the tough approach to big-bank capital announced by Fed Vice Chairman Barr strongly supported by Acting Comptroller Hsu and FDIC Chairman Gruenberg along with staff at all three agencies who have been doing this a long time and seen more than a financial crisis or two. This report identifies key mortgage-finance issues with strategic impact along with what’s to become of them in the end-game.

GSE-010522.pdf…

13 12, 2022

DAILY121322

Eliza Allen2022-12-13T17:08:34-05:00December 13th, 2022|2- Daily Briefing|

Glimmers of 2023 Policy Emerge in HFSC FTX Autopsy

As anticipated, today’s HFSC session fixated on the intricacies of FTX’s bankruptcy and former CEO Sam Bankman-Fried’s arrest. Incoming Chairman McHenry (R-NC) supported the need for extensive regulation and new law but stressed separating the promise of crypto innovation from fraud committed by bad actors and again slammed the SEC’s strategy of “regulation by enforcement.”

FDIC Again Targets False Advertising, Logo Usage

Moving beyond its last effort at ending misrepresentation of deposit-insurance status (see FSM Report DEPOSITINSURANCE112), the FDIC Board today voted unanimously to issue for public comment a proposed modernization of how the FDIC logo is to be displayed and expand on prior efforts to block crypto firms from implying that they are insured. We will soon provide clients with an in-depth analysis of the NPR, which also follows a CFPB circular (see FSM Report DEPOSITINSURANCE113) on FDIC insurance status misrepresentations in May.

Gruenberg, FDIC Nominees Set for Confirmation

As anticipated, Senate Banking today confirmed the Administration’s slate of FDIC directors, positioning them for approval before adjournment and thus giving the agency a full board for the first time in years. Acting Chairman Gruenberg was approved 13-11, with Sen. Toomey (R-PA) voting for him despite strong objections likely to ensure final action this year on the entire slate.

Daily121322.pdf…

1 12, 2022

DAILY120122

Eliza Allen2022-12-01T17:57:37-05:00December 1st, 2022|2- Daily Briefing|

FDIC, FRB-NY Highlight AOCI Losses

In remarks accompanying the banking-sector 3Q report, Acting FDIC Chairman Gruenberg noted that unrealized losses on AFS/HTM securities now total $690 billion, up 47 percent from just the second quarter. This issue is also highlighted in remarks today from the head of supervision at the Federal Reserve Bank of New York, but neither she nor Mr. Gruenberg indicates if the agencies plan any action in this arena.

Brown Talks Civil Rights, GOP Attacks CFPB

Although Chairman Brown (D-OH) used today’s Fair Lending hearing to renew discussion of his 2020 legislation bringing financial institutions under the Civil Rights Act (see FSM Report FAIRLEND9), most of the focus at the session was on the CFPB.

House Panel Blasts Fintech PPP Practices, Seeks Investigation

A new report from the Select Committee on the Coronavirus investigating the role of fintechs in PPP fraud concludes that fintechs failed to implement appropriate oversight and fraud-prevention strategies despite accruing “massive” profits from administration fees.

Barr Talks Even Tougher on Bank Capital Rewrite

Although Vice Chairman Barr today confirmed statements to the Senate Banking Committee (see Client Report REFORM214) that his holistic-capital review is under way without any immediate conclusions, he also emphasized that it will ensure that ample capitalization is sufficient for severe stress and creates incentives for prudent lending. Current capital levels are, he said, at the low end of what research suggests they should be.

Daily120122.pdf…

30 11, 2022

DAILY113022

Eliza Allen2022-11-30T17:09:02-05:00November 30th, 2022|2- Daily Briefing|

Brown Again Asks Treasury for Crypto Action, Recommendations

In a letter today, Senate Banking Chairman Brown (D-OH) continued his press for regulators to do something soon about cryptoassets. He called on Secretary Yellen to work quickly with regulators to advance the policy recommendations in recent Treasury reports (see Client Report CRYPTO32), noting in particular his concerns with vertical integration, calling for rules as well as recommendations regarding any needed statutory changes.

Confirmation Seems Assured for Full FDIC Board

At today’s confirmation hearing, Republicans raised numerous concerns with Acting Chairman Gruenberg, but appear reconciled to accepting his nomination in order to win confirmation for the two Republican nominees who would fill out the board. Ranking Member Toomey (R-PA) blasted Mr. Gruenberg over the alleged “power grab” last year and his support for climate risk initiatives, but the bulk of questioning centered around cryptoassets.

Brown Presses CFPB to Stop Silent Second Foreclosures

Chairman Brown (D-OH) today sent a letter today to CFPB Director Chopra urging the Bureau to sanction servicers foreclosing on “zombie” second liens. These are second liens that were often piggybacks in pre-2008 high-LTV mortgages designed to ensure that first loans could be sold to the GSEs without private mortgage insurance.

Daily113022.pdf…