#special assessments

15 05, 2023

M051523

2023-05-15T11:52:42-04:00May 15th, 2023|6- Client Memo|

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

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.

M051523.pdf

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 …

12 05, 2023

Al051523

2023-05-12T17:07:36-04:00May 12th, 2023|3- This Week|

Warm-Up Acts Over, Congress Readies for Rowdy Performance

We’ll be busy this week giving you in-depth analyses of all of the key hearings scheduled this week and next on what went wrong on bank failures past, present, and hopefully not future.  Last week saw two opening numbers:  HFSC’s Financial Institutions Subcommittee heard from bank lawyers, an investment bank CEO, and a professor and its Oversight Subcommittee reviewed GAO’s in-depth take-down (see Client Report REFORM223) of what the Fed and FDIC did at SVB and Signature and, by inference, what they said about it.  As our analyses described, Republicans are firmly convinced that the banking agencies dropped very big, obvious balls; Democrats aren’t exactly stout defenders, but they are doing their best to chime in with the agencies by emphasizing how badly bank management behaved and how much of their compensation needs to be recouped as reparations.

Al051523.pdf

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