6 10, 2023

FedFin Assessment: Basel Lays Big Plans for Basel V

2023-10-06T14:47:18-04:00October 6th, 2023|The Vault|

As we noted yesterday, the Basel Committee’s October meeting concluded not only with plans for new disclosure consultations, but also a report on lessons learned from the 2023 crisis.  We have long considered the “end-game” standards so substantive as to constitute Basel IV; now, as this report details, Basel is laying plans for Basel V via new liquidity, interest-rate, capital, and structural changes to the current construct.  We thus focus on the supervisory and regulatory action steps Basel posits as necessary responses to the financial-market volatility sparked earlier this year by SVB, SBNY, FRC, and CS’s failures.  While Basel states that none of its recommendations necessarily presages near-term global standards, …

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

11 09, 2023

Karen Petrou: The PCA Cure for Much That Ails New Banking Rules

2023-09-11T09:40:05-04:00September 11th, 2023|The Vault|

It’s a cliché, but it’s also true that one can’t beat something with nothing, especially in Washington.  This is an axiom well worth remembering when it comes to all of the new capital and resolution rules befalling the nation’s biggest banks.  I don’t think they need to be beaten back in their entirety – much in the proposals fixes vital flaws.  But the agencies have done a remarkably poor job conjuring the impact of each of these sweeping proposals, let alone their cumulative impact in the context of all the other rules and the grievous supervisory lapses that contributed to recent failures no matter all the rules that could well have sufficed if enforced.  Thus, the most obvious problems with this new construct are opacity, complexity, and most importantly reasonable doubts that, even with all these sharpened arrows, supervisors will still fail to draw their bows and then fire early and often.  All too much in the new rules is false science, as even a cursory read of the impact analyses makes painfully clear.  Instead of setting standards on lofty, unproven models, safeguards should rely on an engineering axiom:  use warning lights that force prompt and corrective action.  Think of the ground warning in an airplane followed by urgent “pull-up” commands and then go to work on the banking dashboard with clear, enforceable rules and new PCA thresholds forcing supervisory action and accountability.

The need for new PCA triggers is even more urgent than I thought when I first outlined

13 04, 2023

FedFin Assessment: Implications Of An IRR Capital Charge, New Liquidity Rules

2023-04-13T14:02:25-04:00April 13th, 2023|The Vault|

As we noted yesterday, the head of the Basel Committee has targeted two capital and liquidity  compromises included in the current Basel III construct not addressed in the end-game rules to which the U.S. plans shortly to turn.  Actions whether by Basel or, even without it, the U.S. to return to Basel’s initial proposals have significant strategic consequence.  Thus, this report assesses these options and how the U.S. might act on them.  We conclude that the U.S. will quickly impose a de facto interest-rate risk (IRR) capital charge and tighten LCR assumptions related to uninsured deposits.

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

17 10, 2022

Karen Petrou: Fed Financial Losses and Big-Bank Political risk

2022-10-17T15:39:27-04:00October 17th, 2022|The Vault|

Congress will do nothing about anything until the midterm election seals each Member’s fate.  Thus, I expect nothing to come from Congress in 2022 responding to the Fed’s sudden turn for the financial worst.  However, when Congress again comes to thinking about the Fed, it will not go unnoticed despite all the acrimony about monetary-policy miscues that taxpayers are in some ways now far more clearly subsidizing payments to banks, MMFs, and other financial companies holding deposits with the central bank or using its standing market windows.  The last time Congress thought about interest rates on reserves (IRR), more than a few Members wanted it back.  Given that these payments are now at what seems direct taxpayer cost, they’ll have a lot of new friends in the next Congress unless someone quickly shows why these interest payments are an artifact of Fed confusion, not big-bank malfeasance.

Yes, I know – the $2.9 billion loss the Fed reported in terms of Treasury remittances for the first week of October isn’t a direct taxpayer subsidy any more than the hundreds of billions the Fed has sent to the Treasury since 2008 are funds directly taken from taxpayers.  The ups and downs of Fed remittances are the result of balance-sheet operations comprised of liabilities owed to financial companies and earnings on assets in the Fed’s portfolio.  Neither is direct spending nor revenue raising.  This is, though, a technicality for Members of Congress who have become used to having the Fed – and …

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