#GSIB capital requirements

22 01, 2024

M012224

2024-01-22T09:40:25-05:00January 22nd, 2024|6- Client Memo|

How the Banking Agencies Dealt Themselves Such a Weak End-Game Hand

We said from the start that finalizing the capital rules as proposed would be difficult because I have truly never seen a sweeping rule buttressed by such shoddy analytics.  It’s of course true that lots of rules make little sense, but rules that cost companies as much as the capital rules are uniquely vulnerable to substantive and legal challen­­­ges.  This is even more likely when, as now, the proposal’s victims know how to temper political claims with well-founded assertions of analytical flaws and unintended consequences.  When regulatory credibility is effectively undermined, even those who might otherwise side with the regulators become cautious, if not actually averse to doing so.  And thus, it has come to pass for the end-game rules.

m012224.pdf

21 11, 2023

Daily112123

2023-11-21T16:48:20-05:00November 21st, 2023|2- Daily Briefing|

BIS Study: Low-Profit GSIBs are High-Risk GSIBs

A new BIS paper assesses the systemic consequences of GSIBs with low market capitalization, an issue with immediate relevance given investor concerns about the long-term earnings impact of numerous pending rules.  The methodology leads the authors to focus on price-to-book ratios (PTBRs) which are found to be directly linked to investor-predicted return on equity.  Although GSIB capital requirements dramatically increased over the course of the study, there is said to be no significant impact on franchise value.

CFTC Realigns Client-Fund Segregation Standards

The CFTC today proposed to make significant changes to client-fund segregation rules governing futures commission merchants and derivatives clearing organizations covering both how FCMs and DCOs handle client funds and the manner in which they may be deposited with banks.  The proposal redefines permissible investments that must still be housed at a bank or similar entity, adding foreign sovereigns, limiting MMFs to government funds, and removing certain corporate bonds and similar instruments.

Basel Points to Problematic Climate-Risk Implementation

The Basel Committee today issued a “newsletter” addressing issues raised since it finalized global climate-risk management principles (see Client Report CLIMATE14), now codified for large U.S. banking organizations (see Client Report CLIMATE17).

FDIC Sets Up Special Committee to Address Widespread Concerns

In a major concession surely necessary to appease at least some in Congress and ensure continuing agency function, the FDIC board today announced formation of a special committee to be chaired by Acting Comptroller Michael Hsu and Director …

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