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U.S. Bank Regulatory Easing Is Negative For Investors And Taxpayers

Storm clouds behind the exterior of the Federal Reserve building in Washington, DC

Storm clouds behind the exterior of the Federal Reserve building in Washington, DC

In a disappointing decision, the Federal Reserve Board announced yesterday that effective this year, it will limit its use of the “qualitative objection” in Dodd-Frank’s Comprehensive Capital Analysis and Review (CCAR). Under Dodd-Frank’s Title I, banks that are designated as systemically important are required banks to design a model using stress scenarios from the Federal Reserve. In order to pass the stress test, banks need to demonstrate that they would be able to meet Basel III capital and leverage requirements even in a period of stress.  It is in the qualitative portion of CCAR, that the Federal Reserve can identify and communicate to the market if a bank is having problems with its internal controls, model risk management, information technology, risk data aggregation, and whether a bank has the ability to identify, measure, control, and monitor credit, market, liquidity and operational risks even during periods of stress.  Easing this requirement, in combination with all the changes to Dodd-Frank that have been taking place since last year, is dangerous to investors, not to mention taxpayers, especially so late in the credit cycle.

Parts of the test that each firm is subject to this year in addition to the hypothetical scenario.

Parts of the test that each firm is subject to this year in addition to the hypothetical scenario.

*All firms subject to the qualitative objection, except TD Group, will have their fourth year in the 2020 cycle. TD Group’s fourth year will be the 2019 cycle.

According to the Federal Reserve’s press release “The changes eliminate the qualitative objection for most firms due to the improvements in capital planning made by the largest firms.”  Yes, there have been improvements in capital planning precisely, because there were consequences to banks which failed the qualitative portion of CCAR. Banks were prohibited from making capital distributions until they could rectify the problems the Federal Reserve found in the CCAR exercise.  This decision essentially defangs the CCAR qualitative review of banks’ capital planning process.

Nomi Prins

Nomi Prins

Dean Zatkowsky

“It is absolutely reckless of the Fed to relinquish its regulatory authority in such a manner, rather than retain the option of qualitative oversight, which has turned up red flags in the past,” said Nomi Prins former international investment banker. “We are after all, talking about what the banks deem a reporting burden versus necessary oversight that could detect signs of a coming credit or other form of banking related crisis from a capital or internal risk management perspective. Why take that risk on behalf of the rest of our country or the world?”

In writing about the Federal Reserve’s decision, the Wall Street Journal wrote that “Regulators dialed back a practice of publicly shaming the nation’s biggest banks through “stress test” exams, taking one of the biggest steps yet to ease scrutiny put in place after the 2008 crisis.” It is not public shaming. It is called regulators doing their job, that is, providing transparency to markets about what challenges banks may be having. Without transparency, the bank share and bond investors cannot discipline banks.

Just last month, the Federal Reserve Board announced that it would be “providing relief to less-complex firms from stress testing requirements and CCAR by effectively moving the firms to an extended stress test cycle for this year. The relief applies to firms generally with total consolidated assets between $100 billion and $250 billion.”

Christopher Wolfe

Christopher Wolfe

Fitch Ratings

Investors in bank bonds, especially, should be concerned about recent easing of bank regulations. Immediately after the Federal Reserve decision was announced yesterday, Christopher Wolfe, Head of North American Banks and Managing Director at Fitch Ratings stated that “Taken together, these regulatory announcements raising the bar for systemic risk designation and relaxed standard for qualitative objection on the CCAR stress test reinforce our view that the regulatory environment is easing, which is a negative for bank creditors.”  Fitch Rating analysts have written several reports about the easing bank regulatory environment being credit negative for investors in bank bonds and to  counterparties of banks in a wide array of financial transactions.

Dennis Kelleher

Dennis Kelleher

Better Markets

Also, a month ago, the Federal Reserve announced that it will give more information to banks about how it uses banks’ data in its model to determine whether banks are adequately capitalized in a period of stress.  In commenting on the Federal Recent decisions, Better Markets President and CEO Dennis Kelleher stated that “Stress tests and their fulsome disclosure have been one of the key mechanisms used to restore trust in those banks and regulators.  By providing more transparency to the banks in response to their complaints while reducing the transparency to the public risks snatching defeat from the jaws of victory in the Fed’s stress test regime.”

Gregg Gelzinis

Gregg Gelzinis

Center for American Progress

Gregg Gelznis, Policy Analyst at the Center for American Progress also expressed his concern about the Federal Reserve’s recent changes to the CCAR stress tests.  “While Federal Reserve Chairman Jay Powell and Vice Chairman for Supervision Randal Quarles have spoken at length about the need for increased stress testing transparency, this transparency only cuts in one direction.” He elaborated that the Federal Reserve’s decision “benefits Wall Street at the expense of the public. The Fed has advanced rules that would provide banks with more information on the stress testing scenarios and models. At the same time, they have now made the stress testing regime less transparent for the public by removing the qualitative objection—instead evaluating capital planning controls and risk management privately in the supervisory process.”

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Source: U.S. Bank Regulatory Easing Is Negative For Investors And Taxpayers

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A Sad Story Of A Failed Russian Bank And Its Toxic Aftermath – Kenneth Rapoza

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Promsvyazbank, better known as PSB, is the latest post-Soviet lender to get taken over by the Central Bank of Russia (CBR), and now faces shareholder suits in London and Moscow. PSB is one of the 10 largest banks in Russia, as they still describe themselves on their website. PSB was delisted from the Moscow Stock Exchange on Jan. 11, 2018 and later this year recapitalized by the government to service the defense sector…….

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No More Banks or FICO Reports? Economist Describes Ways Blockchain Technology Will Change How We Allocate Credit

In our lifetime we will see many of the traditional banks and credit reporting systems become irrelevant as blockchain technology brings about a radical transformation of the institutional nature of our banking system – a system that is based on a centralized ledger to manage transactions, says Virginia Tech economist David Bieri.

According to Bieri, “the distributed ledger technology of the blockchain offers new ways of economic coordination and governance whereby a information flows are shared almost instantaneously across all participants in a networked system, opening the door for new possibilities such as de-nationalized currencies and a radical democratization of different forms of trust.”

Bieri is an associate professor at Virginia Tech who has also held positions in central banking across the globe.

Quoting Bieri

“The information monopoly of the three credit bureaus is rapidly being dismantled as big data and AI allow fintech companies to engineer something that is much more accurate than the FICO score, from the social media and other personal information they have on you. Several fintech companies are already basing their lending information on this. It has similar logic to FICO, but is based off of their proprietary information.”

“There is significant power in the distributed network because in order for someone to tamper with it they would need to change every copy at the same time and hack every computer separately. Because this is much harder to do than hack a central single location, it makes the data more secure.”

Background and research

Bieri is leading a collaborative research project with two of the largest blockchain-based fintech consortia, R3 and Hyperledger, to develop standards as well as examine how the banking system is reorganizing itself to embrace blockchain, the very thing that might render it obsolete. Project Information – “Disruption, Dislocation or Delusion? Fintech and the Digital Macrofoundations of the Next Global Financial Order” (David Bieri and Giselle Datz)

About Bieri

David Bieri is an associate professor in the School of Public and International Affairs and in the department of economics at Virginia Tech. His current research examines the dynamics of financialization and its role in the process of urbanization. He also writes about regulatory aspects of international finance and global monetary governance. Previously, Bieri held positions in central banking at the Bank for International Settlements in Switzerland and in investment banking in London.

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