#IDI – Page 3 – Federal Financial Analytics

8 09, 2023

Al091123

Eliza Allen2023-09-08T16:03:06-04:00September 8th, 2023|3- This Week|

We’re Flummoxed

FedFin’s in-depth analyses continue to plumb the strategic import of the post-SVB regulatory rewrite U.S. agencies have initiated and are determined to finish no matter industry and Congressional concern. As with our impact assessment of the capital proposal (see FSM Report CAPITAL230), our resolution-standard analyses look at key strategic points in what the agencies say they are doing and then also at what they leave out, what seems not to make as much sense as the agencies suggest, and where the sanguine impact analyses that always accompany these proposals may be at fault.

Al091123.pdf…

7 09, 2023

FedFin on: Living-Will Requirements

Arezou Rafikian2023-09-07T16:39:01-04:00September 7th, 2023|The Vault|

In conjunction with proposing a new long-term debt (LTD) requirement for categories II, III, and IV banks, the Fed and FDIC are pursuing other ways to enhance resolvability. Among these is new guidance for large domestic and foreign banking organizations that requires U.S. banking organizations and foreign banking organization (FBO) intermediate holding companies (IHCs) along with all their insured depositories when any is over $100 billion to file resolution plans. These are also redesigned to make the plans much closer in substance to those mandated for GSIBs.

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

7 09, 2023

LIVINGWILL22

Eliza Allen2023-09-07T16:03:26-04:00September 7th, 2023|1- Financial Services Management|

Living-Will Requirements

In conjunction with proposing a new long-term debt (LTD) requirement for categories II, III, and IV banks, the Fed and FDIC are pursuing other ways to enhance resolvability. Among these is new guidance for large domestic and foreign banking organizations that requires U.S. banking organizations and foreign banking organization (FBO) intermediate holding companies (IHCs) along with all their insured depositories when any is over $100 billion to file resolution plans. These are also redesigned to make the plans much closer in substance to those mandated for GSIBs. However, in a leading indicator of what the FRB is also likely to demand of GSIBs, smaller companies would be required to ensure severability – that is, the ability to cut off a weak limb to save the rest of the banking organization or ensure ready resolution without undue cost to the FDIC or systemic risk. However, easing one aspect of current planning, banking organizations are expressly allowed to count on use of discount-window or other Fed lending facilities to avert failure if – and this is a significant new if – the plan rests atop sound collateral valuation and data-management systems.

LIVINGWILL22.pdf…

29 08, 2023

DAILY082923

Eliza Allen2023-08-29T16:55:20-04:00August 29th, 2023|2- Daily Briefing|

Agencies Advance Controversial Long-Term Debt, Resolution Proposals

The FDIC, OCC, and FRB today tackled several critical resolution issues in the wake of recent bank failures, proposals that raise strong objections from regional banks despite FDIC and FRB unanimity today on at least one of them. As anticipated, the FDIC and FRB approved an NPR that would impose minimum long-term debt requirements for banks and BHCs with assets over $100 billion, with the FDIC and Fed boards voting unanimously in favor even as FRB Gov. Bowman strongly dissented despite a three-year transition period. Similar to the ANPR floating this rule (see FSM Report RESOLVE48), the proposal would require large banks to hold a minimum amount of eligible long-term debt equal to the greater of six percent of risk weighted assets, 3.5% of average total consolidated assets, or 2.5% of total leverage exposure for banks subject to the SLR.

Daily082923.pdf…

14 08, 2023

DAILY081423

Eliza Allen2023-08-14T16:36:42-04:00August 14th, 2023|2- Daily Briefing|

FDIC Finds Banks Well-Capitalized, Resilient

Today’s FDIC 2023 Risk Review concludes that banks were well capitalized as of Q1 2023 and have demonstrated resilience through weaker economic conditions, rising interest rates, high inflation, and this year’s financial turmoil even though industry performance moderated from 2022. Key risks on which the FDIC will focus include liquidity risks as well as the effects of bank failures on overall banking conditions and stability.

FDIC Plans Major Resolution, Insurance Rewrite

As anticipated, FDIC Chair Gruenberg’s speech today confirms that his agency and the Fed will soon propose a TLAC framework for regional banks akin to the long-term debt TLAC standards imposed on GSIBs (see FSM Report RESOLVE48). Mr. Gruenberg also indicated that the FDIC will soon propose a new version of its 2011 IDI resolution rules (see FSM Report LIVINGWILL8).

Daily081423.pdf…

27 06, 2023

FedFin on: Failed-Bank Compensation, Resolution

Arezou Rafikian2023-06-27T16:13:11-04:00June 27th, 2023|The Vault|

The Senate Banking Committee has overwhelmingly approved bipartisan legislation to reform executive compensation following larger insured-depository institution (IDI) failures, with parent-company executive compensation also at risk in some circumstances. Unlike previous bipartisan claw-back legislation, this measure is targeted to incentive compensation, not salary, expressly exempts “white knights,” institution-affiliated persons and directors, and gives the FDIC discretion also to allow senior officers to retain affected compensation in certain other circumstances…

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

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27 06, 2023

COMPENSATION37

Eliza Allen2023-06-27T16:00:07-04:00June 27th, 2023|1- Financial Services Management|

Failed-Bank Compensation, Resolution

The Senate Banking Committee has overwhelmingly approved bipartisan legislation to reform executive compensation following larger insured-depository institution (IDI) failures, with parent-company executive compensation also at risk in some circumstances. Unlike previous bipartisan claw-back legislation, this measure is targeted to incentive compensation, not salary, expressly exempts “white knights,” institution-affiliated persons and directors, and gives the FDIC discretion also to allow senior officers to retain affected compensation in certain other circumstances. Also unlike the prior bill, this measure would make it more difficult for the FDIC to resolve a failing IDI as it did for First Republic via an assisted acquisition by JPMorgan despite the overall prohibition on any U.S. institution holding more than ten percent of national deposits. The Senate bill also mandates that IDIs and parent companies adopt governance standards that give the firm power to claw back compensation in the event of weak condition or poor management practice.

COMPENSATION37.pdf…

8 06, 2023

DAILY060823

Eliza Allen2023-06-08T16:56:17-04:00June 8th, 2023|2- Daily Briefing|

Bills Advanced re Emergency M&A, FDIC Ceiling

The Congressional Record today includes two Democratic bills with possible prospects despite House GOP control.

CFPB Extends Data Broker RFI Deadline

The CFPB today extended the comment deadline on its RFI inquiring about the business models and practices of data brokers.

Treasury Fairness/Compliance Initiative Targets Government Payments

Treasury today issued a new policy on promoting fair and effective compliance via a memorandum from Deputy Secretary Adeyemo.

Gensler Doubles Down On SEC Crypto Policy

In remarks today implicitly rebutting GOP assertions that the SEC has gone too far and new law expanding CFTC authority is needed, SEC Chairman Gensler strongly reasserted that most cryptoassets are securities subject to SEC oversight.

Bank Regulators, CFPB Encourage Appraisal Revaluation

Reflecting ongoing efforts to address appraisal bias, the banking agencies and the CFPB today proposed new interagency guidance on reconsiderations of value (ROV) for residential real estate, outlining the risks of deficient valuations and highlighting policies addressing them.

Daily060823.pdf…

1 06, 2023

Daily060123

Eliza Allen2023-06-01T16:58:53-04:00June 1st, 2023|2- Daily Briefing|

BIS Head Presses for New-Age, Tough Bank Supervision

BIS General Manager Carstens today absolved central banks in general and the Fed by clear inference from fault in recent bank failures by way of recent interest-rate hikes. Noting also that the Basel III construct is very resilient in design and should have prevented these collapses and then the secondary systemic risk that resulted around the world, Mr. Carstens points instead to failures by bank senior management and directors to execute basic risk-management obligations.

Exec-Comp Clawback Bill Takes Shape

With additional GOP support now also on the Banking Committee, Sen. Warren (D-MA) today introduced a revised version of the earlier, also-bipartisan bill on executive-compensation clawbacks following mid-March bank failures (see FSM Report COMPENSATION35). The new bill covers only banks with assets above $10 billion and direct and indirect compensation over three years, a change from the prior bill’s attempt to capture all compensation.

CFPB Sounds P2P Alarm

Building on its 2022 deposit-insurance representations circular (see FSM Report DEPOSITINSURANCE113), the CFPB today released an issue spotlight warning consumers that funds are at risk with payment apps such as Venmo. The FDIC is heightening pressure on nonbanks that gather funds which consumers may confuse with insured deposits (see FSM Report DEPOSITINSURANCE117), but doing so for payment apps is far more challenging because funds move quickly in and out of insured accounts.

Daily060123.pdf…

14 04, 2023

DAILY041423

Eliza Allen2023-04-14T16:36:06-04:00April 14th, 2023|2- Daily Briefing|

Waller Defends Fed SVB Policy

FRB Gov. Waller today defended recent Fed actions, reiterating that SVB was an idiosyncratic risk but it also posed systemic run risk, the most fundamental threat to financial stability.

FHFA Opens the Suggestion Box

FHFA today sought views on its corpus of GSE regulation.

FRB-NY Proposes Novel Way To Prevent Bank Runs

A new post from FRB-NY staff adapts the minimum-balance-at-risk (MBR) policy long discussed for MMFs (see FSM Report MMF16) to bank deposits to determine the extent to which it would quell uninsured-deposit runs.

CFPB Announces Revisions To APOR Methodology

The CFPB today announced a revised version of its Methodology for Determining Average Prime Offer Rates (APOR).

Bowman Rejects Calls For New Rules

In remarks today, FRB Gov. Bowman again differed from Vice Chairman Barr, emphasizing that recent failures are likely not an “indictment” of current rules and that judgment should await the Fed’s report and those from others.

Daily041423.pdf…