#Waller – Page 2 – Federal Financial Analytics

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…

27 07, 2023

DAILY072723

Eliza Allen2023-07-27T17:47:02-04:00July 27th, 2023|2- Daily Briefing|

FSB Tries to Calm CoCo Confusion

Doubtless responding to the CoCo chaos when Credit Suisse failed, the FSB today issued a report laying out how cross-border crisis-management groups are to handle unallocated TLAC (UTLAC) such as the “alternative Tier 1” bonds popular in the EU.

FDIC 3-2 Vote Presages Knock-Down Basel Battle

As anticipated, the FDIC today voted 3-2 to issue a sweeping rewrite of U.S. regulatory capital requirements.

Divided, Cautious Fed Advances End-Game, GSIB Rewrites

As anticipated, Gov. Bowman today voted against the new capital framework, as did Gov. Waller; as a result, the vote was 4-2.

Stablecoin Bill Advances, Compromises to Come

At a fiery HFSC markup today, Chairman McHenry (R-NC) announced that bipartisan negotiations had broken down largely due to the White House, choosing to proceed to a final package as he remains open to amendment before floor action.

House Republicans Skewer Basel Rules

Hill comment so far in response to the new capital rules is sparse.

Daily072723.pdf…

21 07, 2023

Al072423

Eliza Allen2023-07-21T17:08:03-04:00July 21st, 2023|3- This Week|

Here It Comes…

As anticipated, the banking agencies will get their capital proposals out before the August recess but close enough to it to avoid – or so they hope – a withering gauntlet of House hearings. By the time Congress reconvenes in September, the agencies expect – and with good reason – that the new rules will escape notice because attention will have turned to the most vexing issues confronting this divided Congress, most notably keeping the federal government open at the end of the fiscal year. Acting now also ensures that, even if the agencies give ground and concede to the industry’s 120-day comment deadline, at least one month of that will fly by in August, putting the timeline for issuing a final capital rule into the first quarter of 2024 and thus beyond the reach of Congressional Review Act repeal should Republicans muster enough support and the President somehow recants.

Al072423.pdf…

16 06, 2023

Daily061623

Eliza Allen2023-06-16T16:49:58-04:00June 16th, 2023|2- Daily Briefing|

Waller Separates Monetary, Stability Policy

FRB Gov. Waller today defended recent rate hikes against criticism that they undermine financial stability, noting that monetary and stability policy are inter-related but must generally be addressed with different tools.

Brown-Scott Clawback Bill Adds Enforcement Teeth

In his first legislative mark-up since assuming the chairmanship in 2021, Banking Committee Chairman Brown (D-OH) will convene voting next Wednesday on compromise compensation-reform legislation on which he and Ranking Member Scott (R-SC) have agreed.

Hsu Warns of Tokenized-Settlement, AI Risk

Acting Comptroller Hsu’s speech today highlights both the benefits and risks of tokenization and AI, urging parallel development of new technologies and essential controls.

Democrats Try Again To Mandate TILA, CFPB Small-Business Authority

Banking Committee member Sen. Menendez (D-NJ) yesterday introduced legislation (S. 2021) along with Small Business Committee Ranking Member Velazquez (D-NY) (H.R. 4192) to extend TILA protections to small business lending, also giving the CFPB authority in this sector.

Fed Fears Little Systemic Risk

The financial-stability discussion in today’s report from the Federal Reserve ahead of next week’s hearings generally reiterates conclusions from the most recent Fed financial-stability report (see Client Report SYSTEMIC96): banks are generally sound and resilient and, despite MMF worries, most other vulnerabilities are of only moderate systemic concern.

Fed’s Long-Awaited Master-Account Database Goes Live

Conceding to a long-resisted and now statutory demand (see FSM Report PAYMENT25), the Federal Reserve today published the first database detailing who has or seeks access to Reserve Bank master accounts and services.…

6 06, 2023

DAILY060623

Eliza Allen2023-06-06T16:49:29-04:00June 6th, 2023|2- Daily Briefing|

HFSC Tackles China, CBDC

The committee memo for the HFSC National Security Subcommittee hearing tomorrow makes it clear that China is the main focus of dollar-sovereignty considerations and CBDC will play a central role in this debate.

CFPB Wants Chatbots To Stop Talking

The CFPB today released an “issue spotlight” looking at how AI in general and chatbots in particular may adversely affect retail-finance consumers, concluding that chatbots may be useful for simple inquiries, but effectiveness wanes as complexity rises.

Third-Party Guidance Gets Still More Stringent

After repeatedly saying that third-party risk management is a top priority, the banking agencies today finalized a 2021 proposal (see FSM Report VENDOR9) tightening current requirements.

GOP Questions ONRRP, Treasury RWAs

Although HFSC Financial Institutions Subcommittee Chairman Barr (R-KY) today highlighted the legislation on which today’s hearing was to focus, much of the discussion over Treasury-management policy revisited last week’s debt-ceiling battles.

Daily060623.pdf…

12 05, 2023

DAILY051223

Eliza Allen2023-05-12T17:05:25-04:00May 12th, 2023|2- Daily Briefing|

Bowman Blasts Barr

In another public sign of a growing FRB divide, Gov. Bowman early this morning followed Gov. Waller in taking strong issue with what would otherwise appear to be Board policy.

Fed Nominees Face Tough Confirmation Fight

In response to President Biden’s nomination of Philip Jefferson for Fed Vice Chair and Dr. Adriana Kugler and Lisa Cook to Fed Governor seats, Democrats have voiced strong support while Republicans are biding their time on nominations sure to prove controversial.

GOP Presses Broader FDIC, FRB Backstops

Picking up on the FDIC’s report (see Client Report DEPOSITINSURANCE119), Republicans have introduced legislation to provide limited coverage for transaction accounts and address other issues raised by recent events.

FRB-NY: SVB, Signature are 1930s Redux

Following on its post yesterday regarding changing bank-funding sources, the Federal Reserve Bank of New York today argues that the concentrated, uninsured deposit bases at SVB and SBNY are directly comparable to those of small rural banks in the 1930s.

Daily051223.pdf…

20 04, 2023

DAILY042023

Eliza Allen2023-04-20T17:02:29-04:00April 20th, 2023|2- Daily Briefing|

Reed-Grassley Bill Lays Out Another Clawback Construct

Sens. Reed (D-RI) and Grassley (R-IA) introduced yesterday S. 1181, a bill allowing the FDIC to claw back the prior two years of failed bank executive compensation and prohibits them from working at another financial institution for at least two years.

FRB-NY Staff Find Severe Climate Risk At Big Four U.S. Banks But We Wonder

Based on a more in-depth study, a new FRB-NY post measures the market risk to financial institutions related to climate change.

FSB Report Shows Growing Supervisory Interest In Climate-Related Compensation Frameworks

A new FSB report on climate-related financial risk factors in compensation frameworks across the banking, insurance and asset management sectors concludes that financial institutions will need to continuously revise their climate-related criteria to ensure effective alignment of compensation with prudent risk management.

Brown Presses For Stringent FHLB Mission Standards

Following considerable furor over the role of the FHLBs in recent bank failures, Senate Banking Chairman Brown (D-OH) has written to FHFA Director Thompson requesting that the agency’s planned FHLB report also include a detailed assessment of this issue.

Waller Sees Promise In Tokenization, AI

Following prior comments about crypto risk, FRB Gov. Waller today highlighted two innovations he believes may well have natural use cases if their risks can be contained or mitigated.

Fed Study: Bank Enforcement Action Resolution Improves Minority Lending Outcomes

A new Federal Reserve paper concludes that enhancing bank loan and internal governance policies is critical to improving access to credit for minority …

14 04, 2023

DAILY041423

Eliza Allen2023-04-14T16:36:06-04:00April 14th, 2023|2- Daily Briefing|

Waller Defends Fed SVB Policy

FRB Gov. Waller today defended recent Fed actions, reiterating that SVB was an idiosyncratic risk but it also posed systemic run risk, the most fundamental threat to financial stability.

FHFA Opens the Suggestion Box

FHFA today sought views on its corpus of GSE regulation.

FRB-NY Proposes Novel Way To Prevent Bank Runs

A new post from FRB-NY staff adapts the minimum-balance-at-risk (MBR) policy long discussed for MMFs (see FSM Report MMF16) to bank deposits to determine the extent to which it would quell uninsured-deposit runs.

CFPB Announces Revisions To APOR Methodology

The CFPB today announced a revised version of its Methodology for Determining Average Prime Offer Rates (APOR).

Bowman Rejects Calls For New Rules

In remarks today, FRB Gov. Bowman again differed from Vice Chairman Barr, emphasizing that recent failures are likely not an “indictment” of current rules and that judgment should await the Fed’s report and those from others.

Daily041423.pdf…

14 02, 2023

DAILY021423

Eliza Allen2023-02-14T16:52:49-05:00February 14th, 2023|2- Daily Briefing|

What’s Next At The Post-Brainard Fed

Clients have asked us to advise on what may be next for the Fed if Vice Chair Brainard is indeed named as head of the White House NEC, which now seems certain. In our view, there will be no change to FOMC policy given unanimity on this question and the leadership not only of the vice chair, but also of the Fed chairman and FRB-NY president. However, there could be a significant shift in the likelihood of a U.S. CBDC. Ms. Brainard has been the most outspoken advocate of a CBDC (see Client Report CBDC13), but her successor as head of the Fed payment committee is likely to be either Gov. Waller or Bowman, each of whom is a strong CBDC skeptic.

Daily021423.pdf…

10 02, 2023

DAILY021023

Eliza Allen2023-02-10T17:02:31-05:00February 10th, 2023|2- Daily Briefing|

Waller Reiterates Fed’s Wary Cryptoasset Policy

In remarks today, FRB Governor Waller reiterated the Fed’s wary approach to cryptoassets, repeating the Fed’s requirements (see FSM Report CRYPTO31) for banks that wish to engage with crypto customers or activities. Following the collapse of FTX and its ripple effect on banks such as Silvergate (see Client Report CRYPTO38), Mr. Waller stressed that banks engaging with crypto customers must have a thorough understanding of their client’s business models, risk management systems and corporate governance.

Hsu Reprises, Expands Bank Merger Reform

In remarks today, the OCC Chief Counsel on behalf of Acting Comptroller Hsu stressed the need to update competition metrics, financial stability considerations, and community assessments in bank merger reviews, but gave no indication of when new merger policy may be finalized. Mr. Hsu argued that while HHI is an objective and transparent metric, it is no longer suitable for measuring competition because its deposit share-based approach fails to capture the competitive effect of nonbanks and online banking.

FHFA Outlines Substantive FHLB Reform Agenda

As anticipated earlier this week, FHFA Director Thompson today called the status quo of the FHLB system unacceptable and said that FHFA will make “meaningful” recommendations to improve the sector. This will take shape in a report following completion of FHFA’s roundtable series concluding in March. FHFA’s report will make statutory recommendations to Congress and lay out its own regulatory objectives, perhaps starting with an ANPR and/or regulatory guidance or supervisory actions.

Daily021023.pdf…