#Regional Bank

15 05, 2023

Karen Petrou: How An Ill-Designed Special Assessment Is Sure To Scramble The Structure Of Federal Deposit Insurance

2023-05-15T11:52:36-04:00May 15th, 2023|The Vault|

As our forthcoming in-depth analysis will detail, the FDIC’s proposed special assessment raises a raft of policy problems not contemplated by the FDIC despite a steep price tag warranting careful thought at a time of financial instability and recessionary risk.  The FedFin analysis will detail the proposal, what the FDIC thinks, and what the proposal might do to whom, but here’s my opinion:  the FDIC’s decision to allocate blame for SVB and Signature’s failures to a select group of surviving larger banks is a politically-expedient violation of the principal of insurance and a terrible precedent for the future of federal deposit coverage.

First problem: the FDIC assigns blame to a large group of bigger banks even though its own analysis of the SVB and SBNY failures points to a different underlying reason for the systemic designation.  In the proposal, the FDIC targets large holdings of uninsured deposits even though both its post-mortem and the Fed’s of the two systemic failures cites bad management as the most important cause of death.  Both agencies do note the new risks posed by social-media runs that hastened the banks’ passing, but each also makes it clear that these new-age runs are an endemic challenge to bank resilience, not a risk unique to SVB and Signature or other banks with large amounts of uninsured deposits.  The FDIC proposal contains no explanation of why uninsured-depositories are the systemic rescue’s fall guys even though these deposits aren’t the cause of the two bank failures and the risks …

15 03, 2023

FedFin Assessment: Post-SVB Deposit Insurance Reform

2023-03-15T16:58:47-04:00March 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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4 10, 2022

American Banker, Wednesday, October 4, 2022

2022-10-05T11:40:58-04:00October 4th, 2022|Press Clips|

Fed, FDIC plan for living wills sparks debate about best approach

By Kyle Campbell

New guidelines are coming for how large regional banks should prepare themselves for bankruptcies, but some policy experts are already questioning if they will go far enough. The Federal Reserve and the Federal Deposit Insurance Corp. issued a joint statement Friday that they will provide guidance on resolution planning for banks that have at least $250 billion in assets but do not qualify as too-big-to-fail….Karen Petrou, co-founder of Federal Financial Analytics, said it is difficult to read too much into what the Fed and FDIC have in mind about specific changes to their resolution plan policies. She said it is likely that Category II and Category III banks will face more scrutiny than they currently do, albeit not as much as the G-SIBs, but little is clear beyond that. Overall, Petrou said she supports a resolution planning framework that is conducted in an orderly fashion for all relevant institutions, which the agencies seem to be calling for, rather than the current regime, which places greater scrutiny on merging firms. “That is an appropriate approach, it’s good governance,” Petrou said. “If you were doing it on a deal-by-deal basis, based on a policy issue that cuts across regional banks, it’s really unfair to target one or another bank. This needs to be done across the sector.”

https://www.americanbanker.com/news/fed-fdic-plan-for-living-wills-sparks-debate-about-best-approach

 

 

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22 08, 2022

FedFin on: FRB Crypto-Activity Constraints

2023-01-04T10:52:55-05:00August 22nd, 2022|The Vault|

Reflecting the concerns voiced in a recent executive order from President Biden and a subsequent request for views from Treasury, the Federal Reserve has joined the OCC in demanding prior notice from banking organizations that wish to undertake cryptoasset activities.  The OCC also warned national banks already engaged in these activities to ensure that they are safe and sound, but the Fed has gone farther.  It also demands that state member banks and BHCs already engaged in this sector notify their lead supervisor and ensure that…

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

18 08, 2022

FedFin on: Payment System Access

2023-01-04T11:31:21-05:00August 18th, 2022|The Vault|

Following considerable controversy surrounding how Federal Reserve Banks grant master accounts, it has finalized a somewhat more explicit set of guidelines along lines proposed the second time the Fed attempted to set guidelines via a “supplemental” proposal earlier this year amending its 2021 effort.3 Doubtless expecting the controversy which followed these final guidelines, the Fed was at pains in both the preamble and release to emphasize that the new standards are “transparent and equitable.” However, as noted below, some changes to the supplemental in fact increase…

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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