regulation-reform

Breaking Up (Big Banks) is Hard to Do

07/31/12

This is no time to start unwinding the largest banks. There's enough uncertainty in this fragile economy. But starting a conversation now about the costs and benefits will lay the groundwork for sound action when conditions improve.

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Stop Romanticizing Glass-Steagall

07/31/12

The modern, neo-Glass-Steagall advocacy has a mystical quality about it, an appeal that proposes to rise above the tough debate over the thorny details and reach back to a mythical time when bank regulation worked so very well.

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'Disparate Impact' Doctrine Is Vital for Fair-Lending Exams

07/30/12

In a society where blatant expressions of discrimination are largely considered to be unacceptable, discrimination often takes on subtler and more insidious forms.

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Say Good Riddance to HSBC

07/30/12

A Congressional investigation found HSBC engaged in money laundering and sanctions busting for ten years, in multibillion-dollar amounts. Perhaps not coincidentally, the bank has been disinvesting from the U.S. Let's invite them to complete their departure-fast.

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Anti-Money-Laundering Enforcement Gets Tougher and Smarter

07/26/12

As the HSBC hearings demonstrate, there's a growing expectation that individuals, not just institutions, will be held accountable. Recent enforcement actions also show a more risk-based, rather than rules-based, approach.

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Why Reinvent the Wheel to Comply with New Derivative Rules?

07/26/12

For many, it is more beneficial to take advantage of mechanisms that are integral to the fabric of the company and of the financial ecosystem, as a way to achieve compliance and maximize investments in current foundations.

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We Need an Interim Systemic Watchdog While OFR Sets Up Shop

07/25/12

Financial markets remain highly complex webs subject to major systemic shocks we are ill-equipped to identify before our financial system melts down.

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Reputational Risk Goes Well Beyond Bad Press

07/25/12

A regulatory settlement or a Senate hearing can remove a particular cloud enveloping an institution, but create deeper doubts than the ones it removes.

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Eminent Domain: Eminently Suitable for Defaulted Loans

07/24/12

Use eminent domain to refinance unaffordable mortgages, cut through the mire of servicers, home equity investors and trustees. Protect homeownership and communities while respecting everyone's property rights.

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Would the Stress Tests Have Caught WaMu?

07/23/12

Recessions do not cause bank failures. It is banks causing booms that cause recessions that cause banks to fail.

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