#rfi – Page 3 – Federal Financial Analytics

17 12, 2021

Daily121721

Arezou Rafikian2023-05-22T15:52:04-04:00December 17th, 2021|2- Daily Briefing|

Partisan Battle to Have Lasting FDIC Impact– HFSC Chairwoman Waters (D-CA) reiterated her opposition to FDIC Chair McWilliams’ decision to quash the merger RFI circulated by FDIC Board Democrats (see FSM Report MERGER9), highlighting her recent letter to bank regulators calling for a moratorium on all bank mergers over $100 billion and saying again that these threaten community banks, small businesses, and consumers.

FSOC: Systemic Risk Elevated, Much Work in Progress
FSOC met to consider its annual stability report, which strikingly differs with the Fed’s more sanguine view of systemic risk (see Client Report SYSTEMIC92).

DOJ Redefines M&A Outlook
Even as partisan warfare continues over the Democratic merger RFI (see FSM Report MERGER9), the Department of Justice has irrevocably altered the M&A outlook by reopening its 2020 request for comment (see Client Report MERGER5).

GAO: Alternative Data’s Potential Stymied by Risks, Uncertainties
The GAO issued a report on the potential for alternative data to expand mortgage access for borrowers with minimal credit histories, concluding that current uncertainties and risks limit fair and effective use.

Daily121721.pdf…

16 12, 2021

FedFin: Bank Merger Policy

Arezou Rafikian2023-05-22T16:11:59-04:00December 16th, 2021|The Vault|

Released in a highly-controversial fashion (see below) by two Democrats on the FDIC’s board, this RFI posits the need for a significant review of mergers involving insured depository institutions (IDIs) due to many changes in the financial industry and, so it says, the lack of substantive competitive analysis over past decades even of the largest transactions.

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

16 12, 2021

MERGER9

Arezou Rafikian2023-05-22T16:12:11-04:00December 16th, 2021|1- Financial Services Management|

Bank Merger Policy

Released in a highly-controversial fashion (see below) by two Democrats on the FDIC’s board, this RFI posits the need for a significant review of mergers involving insured depository institutions (IDIs) due to many changes in the financial industry and, so it says, the lack of substantive competitive analysis over past decades even of the largest transactions.

MERGER9.pdf…

14 12, 2021

Daily121421

Arezou Rafikian2023-05-23T12:27:52-04:00December 14th, 2021|2- Daily Briefing|

Thompson Takes the Prize
As we anticipated, President Biden today nominated Acting FHFA Director Sandra Thompson to a full term. We expect this appointment to be roundly praised by Democrats and community-advocacy groups. It will draw GOP fire, but likely not serious enough to deter her confirmation next year absent any new facts.

RFI in Limbo, Substantive FDIC Decisions Up in Air
Although fireworks were anticipated at today’s FDIC open meeting, Board members kept discussion regarding the merger RFI to procedure before moving into an executive session at which the matter was surely debated.

OCC Restores Prior CRA Framework Over Industry Objections
Largely as proposed, the OCC today finalized its rule rescinding its controversial 2020 CRA rewrite (see Client Report CRA28) and reverting to the prior CRA framework. The agency generally rejected industry arguments that recission is burdensome given that banks have already implemented the revised framework and expect soon to implement yet another revised interagency framework (see FSM Report CRA30).

FinCEN Slow Walks Structural AML/CFT Rewrite
As required by law earlier this year (see FSM Report AML133), FinCEN today issued an RFI seeking views on ways to enhance AML/CFT regulation. We will shortly provide clients with an in-depth analysis of this RFI, which highlights the importance of a risk-based U.S. system that adapts to emerging illicit-finance trends.

IMF Demands Tough Rules for Stablecoin, Other E-Money
A new IMF blog post calls for comprehensive standards akin to those Democrats today demanded (see …

13 12, 2021

Al121321

Arezou Rafikian2023-05-23T12:39:00-04:00December 13th, 2021|3- This Week|

THE FRACAS AT THE FDIC

As we noted on Thursday, the FDIC’s decision-making process broke wide-open when Directors Gruenberg and Chopra announced that the FDIC had a request for input (RFI) on bank M&A primed to go out for public comment. Indeed, a text of the RFI was posted, but only on the CFPB’s website along with a statement from Mr. Chopra pressing the RFI’s points on grounds that bank mergers are a “privilege, not a right.” But, after just a couple of hours, it became clear that what purported to be an FDIC action wasn’t an FDIC action at least as far as FDIC Chair McWilliams is concerned. A statement from the agency – not directly from her – not only refuted the RFI, but also soundly condemned the process by which it surfaced.

Al121321.pdf…

10 12, 2021

Daily121021

Arezou Rafikian2023-05-23T12:44:10-04:00December 10th, 2021|2- Daily Briefing|

FRB Stipulates Archegos-Risk Remedies
As forecast when Archegos broke (see Client Report HEDGE59), the FRB today issued new, tough guidance detailing its supervisory expectations for large-bank exposures to investment funds.

FSB Advances Cross-Border Payment Revamp
Building on its new cross-border payment policy (see FSM Report PAYMENT23), the FSB today sought comment on how national and regional data frameworks affect the cost, speed, access, security, and the interoperability of cross-border payments.

Aborted Merger Paper Hits Partisan Battle Lines
Following yesterday’s battle over an RFI on bank mergers, senators are squaring off on both process and policy. Banking Chair Brown (D-OH) agreed with it, arguing that what he calls M&A “rubber stamping” hurts communities and creates banking deserts.

Waters Demands Regional-Bank Merger Moratorium
Uping the ante on bank mergers after the FDIC fracas over an RFI, HFSC Chairwoman Waters (D-CA) late this afternoon called on the FRB, OCC, and FDIC to hold all M&A over $100 billion until completion of this review, one under way by the FRB and Department of Justice, and any similar OCC assessments.

Daily121021.pdf…

9 12, 2021

Daily120921

Arezou Rafikian2023-05-23T12:50:03-04:00December 9th, 2021|2- Daily Briefing|

IMF Presses for Fast, Hard Global Crypto Standards
The IMF today reiterated its commitment to work with global regulators to craft crypto regulation due to inherent risks in the sector exacerbated by disorderly capital flows resulting from regulatory arbitrage.

FRB-NY Tackles Maternal-Health Inequity
Although Reserve Banks are facing harsh criticism from Senate Banking Ranking Member Toomey (R-PA) about “woke” actions he believes beyond the Fed’s mission, the New York Federal Reserve today released a study of maternal health that – despite public concern in this area – may spark renewed criticism with problematic implications for Vice-Chair nominee Brainard.

LIBOR Fix Powers Through House
By an overwhelming 415-9 vote, the House late yesterday passed H.R. 4616, the Sherman (D-CA) bill providing legal certainty for legacy LIBOR contracts (see FSM Report LIBOR6). The bill finally reached the House floor following a revision to the reported bill ensuring that rate resets are not taxable events.

BIS: Bond Funds Need Radical Regulatory Rewrite
Today, we follow our analysis yesterday of the BIS paper on DeFi regulatory policy with an assessment of another high-impact analysis of open-end funds.

FDIC Does, Doesn’t, May Advance New Bank M&A Policy
In a most unusual move, the FDIC today announced it did not release an RFI on bank merger policy hours after two directors – Messrs. Gruenberg and Chopra – said it had.

HFSC Ducks Tough Asset-Management Diversity Demands
Although the majority staff report released ahead of today’s HFSC Diversity and Inclusion Subcommittee hearing highlighted several legislative proposals, Members …

18 11, 2021

FAIRLEND10

Arezou Rafikian2023-05-26T10:30:48-04:00November 18th, 2021|1- Financial Services Management|

HMDA Rewrite

The CFPB has followed a study earlier this year finding significant mortgage product and price discrepancies based on race or ethnicity with a request for input (RFI) on the HMDA data on which the study was based. This is a preliminary effort with no immediate regulatory or supervisory consequences, but it likely presages a significant HMDA-regulatory rewrite in no later than 2023 to provide still more firepower for ongoing CFPB, Department of Justice, and bank-regulatory actions against credit discrimination and redlining.

FAIRLEND10.pdf…

18 11, 2021

FedFin Analysis of: HMDA Rewrite

Arezou Rafikian2023-05-26T10:31:04-04:00November 18th, 2021|The Vault|

The CFPB has followed a study earlier this year finding significant mortgage product and price discrepancies based on race or ethnicity with a request for input (RFI) on the HMDA data on which the study was based. This is a preliminary effort with no immediate regulatory or supervisory consequences, but it likely presages a significant HMDA-regulatory rewrite in no later than 2023 to provide still more firepower for ongoing CFPB, Department of Justice, and bank-regulatory actions against credit discrimination and redlining.

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

17 11, 2021

GSE-111721

Arezou Rafikian2023-05-26T10:50:27-04:00November 17th, 2021|4- GSE Activity Report|

The Anti-Discrimination Data Drive

As noted yesterday, the CFPB has opened its HMDA rules to a raft of changes. None of these is likely to come fast, but more than a few of them could change mortgage origination, underwriting, and securitization for the better in terms of inclusion and the worse in terms of cost.

GSE-111721.pdf…