The Fincen Whistleblowers
Many developed countries, free from the U.S. impulse to see every product as something to track, do not share its inclination to frown on financial privacy. ... Read full article
Many developed countries, free from the U.S. impulse to see every product as something to track, do not share its inclination to frown on financial privacy. ... Read full article
A recap of the informed opinions (and the discussions they generated) on BankThink and AmericanBanker.com this week. ... Read full article
Federal regulators must not rely on standard measures of differences between outcome rates without considering the way those measures change simply because the frequency of an outcome changes. ... Read full article
Banks are incessantly lobbying the CFTC to hold off on cross-border derivatives rules until other countries write their own regulations. But that could take longer than the next crisis. ... Read full article
The constant pillorying of banks can hardly inspire public confidence in them. Regulators should focus, instead, on peer comparisons and the encouragement of effective policies and procedures. ... Read full article
The FDIC's decision to fund its emergency needs by calling upon banks to prepay future premiums back in 2009 suggests that the line to the Treasury may never be used. ... Read full article
Brown-Vitter is a welcome display of bipartisanship. But its proposed solution to too big to fail, equity capital, is only marginally effective in imposing discipline on management. ... Read full article
Among other problems, Goldman never mentions that one big reason it survived and thrived is that the bailout of AIG enabled it to repay Goldman and other counterparties at par. ... Read full article
Public officials talk as if facilitating anonymous financial transactions is in itself somehow nefarious. But there are legitimate reasons to keep online purchases and other activity private. ... Read full article
Regulators, legislators, bankers, and the public should do everything they can so that Title I of Dodd-Frank works. The goal is to avoid Title II orderly liquidation at all cost. ... Read full article
The nation needs a more informed public discussion of the kind of financial system we really want before we try breaking up the big banks through legislation or regulatory fiat. ... Read full article
The CFPB has made fair lending a top priority. To avoid problems, scrutinize the agencys view of the laws, proactively analyze policies and document the reasons behind your loan decisions. ... Read full article
The more that compensation designs depart from well-grounded pay-for-performance principles, including appropriate metrics and actual financial results, the less effective they are as an incentive ... Read full article
The most effective housing reform would let the GSEs do what they do best: act as a conduit for private capital to enter the residential lending market. ... Read full article
Until a mechanism to shut the biggest and baddest is well in place, the prospect of taxpayer bailout will distort financial markets and handicap competitors. ... Read full article
The swap execution facility regime in Dodd-Frank, once championed as the magic pill to cure the problems in the derivatives market, is turning out to be less potent than hoped. ... Read full article
Know-your-customer, an essential precaution, must be coupled with know-your-employees. A host of instances highlight the involvement of employees in fraudulent transactions in most cases in league with customers. ... Read full article
A recap of the informed opinions (and the discussions they generated) on BankThink this week. ... Read full article
The return to profitability of Fannie Mae and Freddie Mac is not a reason to preserve them as part of a future housing finance system. ... Read full article
Loan performance data show the entire case against GSE underwriting standards, and their role in the financial crisis, is based on social stereotyping, smoke and mirrors, and little else. ... Read full article