#Waller – Federal Financial Analytics

15 02, 2024

DAILY021524

Eliza Allen2024-02-15T17:13:22-05:00February 15th, 2024|2- Daily Briefing|

Bowman Focuses on Inclusive Cross-Border Payments

FRB Gov. Bowman today emphasized that national and global payment-system improvements must not only work for the financial system and payment providers, but also for end-users and broader inclusive growth. This is a policy challenge that, she said, cannot be resolved only by technology.

Senate Dems Resume Attack on Zelle

Retreating from his stand during a recent hearing that seemed to absolve Zelle (see Client Report PAYMENT28), Senate Banking Chairman Brown, (D-OH) along with Sens. Warren (D-MA) and Reed (D-RI), today sent a letter reiterating calls for Zelle to clarify its reimbursement policy for impostor scams. The letter also demands that Zelle revise its reimbursement policy to cover other scams and to and streamline its reporting process, demanding a new public commitment to doing so.

Waller Sees Impregnable Dollar Dominance

FRB Gov. Waller today mounted a strong defense not only of the dollar as the globe’s reserve currency under current conditions, but also even as digital currencies become more widely deployed. This stand is consistent with those at the FRB opposing proposals in Congress to advance a CBDC on grounds that it is essential to preserve reserve-currency status (see FSM Report CBDC10) and signals no interest in the U.S. central bank to making any other payment-system changes to press sanctions policy with the dollar’s dominance in mind.

Daily021524.pdf…

22 01, 2024

M012224

Shane Smith2024-01-22T09:40:25-05:00January 22nd, 2024|6- Client Memo|

How the Banking Agencies Dealt Themselves Such a Weak End-Game Hand

We said from the start that finalizing the capital rules as proposed would be difficult because I have truly never seen a sweeping rule buttressed by such shoddy analytics. It’s of course true that lots of rules make little sense, but rules that cost companies as much as the capital rules are uniquely vulnerable to substantive and legal challenges. This is even more likely when, as now, the proposal’s victims know how to temper political claims with well-founded assertions of analytical flaws and unintended consequences. When regulatory credibility is effectively undermined, even those who might otherwise side with the regulators become cautious, if not actually averse to doing so. And thus, it has come to pass for the end-game rules.

m012224.pdf…

22 01, 2024

Karen Petrou: How the Banking Agencies Dealt Themselves Such a Weak End-Game Hand

Shane Smith2024-01-22T09:22:56-05:00January 22nd, 2024|The Vault|

We said from the start that finalizing the capital rules as proposed would be difficult because I have truly never seen a sweeping rule buttressed by such shoddy analytics. It’s of course true that lots of rules make little sense, but rules that cost companies as much as the capital rules are uniquely vulnerable to substantive and legal challenges. This is even more likely when, as now, the proposal’s victims know how to temper political claims with well-founded assertions of analytical flaws and unintended consequences. When regulatory credibility is effectively undermined, even those who might otherwise side with the regulators become cautious, if not actually averse to doing so. And thus, it has come to pass for the end-game rules.

As our analyses of all of the comment letters filed last week by dozens of Democrats make clear, only a few super-progressive Democrats now stand firmly with the regulators and even they have a few qualms. Maybe the agencies will try to bull it out – we thought so as recently as early this month in our outlook. We were clear there that major changes would need to be made to finalize the end-game rules; now, we’re not sure even these will do. The odds now are considerably higher for the re-proposal pressed last week by FRB Govs. Waller and Bowman.

The agencies are of course not naïve. They knew that the final rule would have to show a few concessions to its critics. As a result, …

16 01, 2024

DAILY011624

Eliza Allen2024-01-16T16:33:43-05:00January 16th, 2024|2- Daily Briefing|

Waller Raises Stakes for End-Game Finalization

Going beyond his longstanding critique of the end-game rules, FRB Gov. Waller today reflected industry comments and litigation plans, saying that he now thinks the proposal needs a “major overhaul” or should be withdrawn and reissued. As we noted in our recent 2024 outlook, Gov. Bowman will surely side with this view, but Chair Powell holds the gavel when it comes to the end-game outcome at the Federal Reserve. Mr. Waller also is personally opposed to the pending rewrite of debit-card interchange fees (see FSM Report INTERCHANGE12) because it forces the Fed to pick winners and losers.

Global Regulators Try Transparency as Cure to CCP-Margin Risk

The Basel Committee, CPMI, and IOSCO today released a long-planned consultation on CCP and clearing-member margining practices. These are designed to limit the volatile and potentially-systemic liquidity stresses due to margining practices evident in 2020 and again after the Ukraine invasion, with the extent to which these further shift cost burdens from CCPs to clearing members their most controversial aspect. Largely focused on transparency, the new approach would require CCPs to provide clearing members with margin-simulation tools that members would then make available to end-users to enhance margin-call preparedness.

Daily011624.pdf…

24 10, 2023

DAILY102423

Eliza Allen2023-10-24T17:18:54-04:00October 24th, 2023|2- Daily Briefing|

McHenry, Barr Blast Basel Adherence in End-Game Regs

Although today’s hearing challenging regulatory actions aligned with global regulators was postponed, HFSC Chairman McHenry (R-NC) and Financial Institutions Subcommittee Chairman Barr (R-KY) today kept up the pressure, releasing a letter to the GAO commissioning a study of the end-game rules.

New CRA Reg Sets Controversial, Complex Standards

Leading the way to certain inter-agency approval, the Federal Reserve today voted 6-1 to approve a final version of their 2022 controversial proposal (see FSM Report CRA32).

FDIC OIG: Supervisors Missed So Much, Acted So Slowly re SBNY

The FDIC’s OIG report today on SBNY’s failure follows much of the line the Fed’s OIG took when it came on the material-loss review of SVB’s collapse.

House Republicans Pressure Biden on $6 Billion Iran Ransom

Although HFSC continues to cancel all its hearings as the speakership battle continues, its Oversight Subcommittee today optimistically released a memo outlining goals for Thursday’s Iran-sanctions hearing.

Treasury Presses CSPs to Negotiate With Banks

Treasury Assistant Secretary for Financial Institutions Graham Steele today highlighted Treasury’s work with cloud service providers (CSPs) to improve transparency and security.

Divided FDIC Advances CRA Rewrite, Climate-Risk Principles

As anticipated, the FDIC on a 3-2 vote joined the Fed in approving a 1400+ page final CRA rule.

Daily102423.pdf…

20 10, 2023

Al102323

Eliza Allen2023-11-13T15:46:12-05:00October 20th, 2023|3- This Week|

Relentless Pressure and Resulting Concession

On Friday, the Federal Reserve offered an olive branch – small and partial, but still a branch – to Republican critics of pending standards and the big banks powering up all this pain. As we noted, the comment deadlines for the capital and GSIB-surcharge rules have been extended to January 16, a move also designed to thwart litigation based on procedural considerations. The Fed has also announced a new data-gathering exercise in which stakeholders can send in “data” but due to which much more input will also surely flow. This exercise also answers procedural critics and protects the bill, with the deadline here also January 16.

Al102323.pdf…

6 10, 2023

DAILY100623

Eliza Allen2023-10-06T14:46:53-04:00October 6th, 2023|2- Daily Briefing|

Chopra Has Big Plans for Payments

Likely assuming the coast is clear after the Supreme Court seemed reluctant to undo its charter earlier this week, CFPB Director Chopra today announced a series of steps designed to give the Bureau considerably more control over the payment system. First, the agency plans to issue supplemental orders to “certain” bigtech companies – doubtless PayPal – to ascertain stablecoin plans and how this affects consumer data.

Waller Still Sees Little Need for CBDC

Governor Waller today continued his skeptical CBDC stance, noting that Fed work on the product is largely motivated by preparedness concerns. Nonetheless, any US CBDC will be two-tier with direct retail CBDC requiring Fed master account access not permitted under current law. Mr. Waller also strongly disputed claims that CBDCs such as those in China pose a threat to the US dollar and countered suggestions that FedNow is a CBDC-precursor, emphasizing that its primary purpose is to speed payments.

Daily100623.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…

10 08, 2023

FedFin on: Operational Risk-Based Capital Standards

Arezou Rafikian2023-08-11T16:25:34-04:00August 10th, 2023|The Vault|

Noting that operational risk is present at all banks due to most activities, the U.S. regulatory-capital rewrite would end the current approach to operational risk-based capital (ORBC). This now subjects only categories I and II banks to ORBC and then only to the advanced measurement approach (AMA) premised on each bank’s internal models. Consistent with the overall decision to end internal-model reliance, this section of the proposal subjects categories I, II, III, and IV banks to a new operational-risk standardized approach (SA). This would result in very steep capital requirements based on a bank’s experience over the past ten years compared to various sources of revenue over the past three years, perhaps taking business-model changes over the course of the last three years into account if regulatory standards are met for doing so….

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

10 08, 2023

OPSRISK22

Eliza Allen2023-08-10T16:10:43-04:00August 10th, 2023|1- Financial Services Management|

Operational Risk-Based Capital Standards

Noting that operational risk is present at all banks due to most activities, the U.S. regulatory-capital rewrite would end the current approach to operational risk-based capital (ORBC). This now subjects only categories I and II banks to ORBC and then only to the advanced measurement approach (AMA) premised on each bank’s internal models. Consistent with the overall decision to end internal-model reliance, this section of the proposal subjects categories I, II, III, and IV banks to a new operational-risk standardized approach (SA). This would result in very steep capital requirements based on a bank’s experience over the past ten years compared to various sources of revenue over the past three years, perhaps taking business-model changes over the course of the last three years into account if regulatory standards are met for doing so. Steps banks have taken to prepare and avoid operational risk and respond to prior incidents are also generally not captured in a meaningful ORBC adjustment. As a result, ORBC capital standards may be premised on risks the bank is now unlikely to encounter on a go-forward basis or offsetting the costs essential to preventing and absorbing the operational risks it now might encounter.

OPSRISK22.pdf…