Agencies need to make sure that the regulations being implemented are necessary to address the problems the Dodd-Frank Act intended to address. Analyzing the rules' potential economic impact is critical.
Basel III is nearly incomprehensible to most readers, including bank directors, managers, and analysts. Of what use is a measure no one can understand? Tangible equity capital is understood by all.
An alternative capital requirement that allowed Lehman and Bear Stearns to build up huge subprime portfolios and incur excessive leverage remains in effect for six large broker-dealers and investment banks.
Intended to bring together the entire universe of U.S. financial regulators in the hope that doing so would identify and forestall new risks to the financial system, the FSOC, two years in, has not identified much and can therefore be credited with little forestalling.
The notion of decreasing the degree to which a banker can use his or her judgment to add to the ALLL not only throws the baby out with the bathwater, but it also fails to protect the investor, the very person that the accounting rules claim to be protecting.
A practical, well-executed plan, even one with disappointingly modest goals, will deliver more than an overly ambitious plan, easily subverted, that in hindsight probably had no hope of ever succeeding.
It is neither the intent nor the practice of NCUA to influence a vote on a credit union conversion. Our rules protect members' rights to make well informed decisions.
There will be some complex decisions for those involved in Tarp situations, particularly with regard to banks that are likely to fail if they are not acquired or recapitalized. Here's what to consider before you make them.
The market for discount notes of the Federal Home Loan Banks represents an adequate Libor replacement since, in addition to meeting other criteria, yields on its securities are the result of actual arm's length transactions with some 80 approved debt underwriters worldwide.
By proposing to design regulations intended to shape state laws and practices, the FHFA is picking a fight with the states that will overshadow any economic benefit from risk-based pricing.
