Too Big to Fail (TBTF)

Translating the Warren-Yellen Exchange

02/25/15

Senator Elizabeth Warren surprised a lot of people by laying into Federal Reserve Board Chair Janet Yellen as hard as she ever laid into Timothy Geithner. I think this was a really important exchange. But its easy to miss exactly what's being communicated in it. Senator Warren's comments can basically be translated as follows:  

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TBTF and The Single Point of Entry (SPOE): Part Two

02/25/15

In an earlier post I described the FDIC’s proposed SPOE approach to resolution of SIFI banks and other financial institutions under Title II of Dodd-Frank. That post discussed two of the three components of SPOE: control of the process by the regulator and no bailout for management or owners. This post lays out the role of the third component, the “forlorn hope” debt.

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A 21st Century Trust Indenture Act?

02/17/15

MBS investors suffered a serious legal blow a couple of months back when the Second Circuit held that the Trust Indenture Act of 1939 doesn't apply to MBS

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Hacking and Systemic Financial Risk (Encore)

02/14/15

The data breach stories just don't seem to stop. (And why would they?). The latest (I think) is about a massive and sophisticated multi-million dollar hacking of several banks.  If you read down through the story, one of the things the hackers did was manipulate the balances of real accounts.  They'd change a real $1,000 balance to $10,000 and then have $9,000 wired to an account at another institution.  

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Size Matters: Community Banks' Real Problem

02/10/15

Community banks are ailing.  Over the past decade many of them have failed or been gobbled up by larger banks. What's going on? 

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Corporate Recidivism? Ocwen's Charter Problems

01/13/15

Last month mortgage servicer Ocwen (that's NewCo backwards) was mauled by the NY State Department of Financial Services. Now the California Department of Corporations is seeking to revoke Ocwen's license to do business in that state. 

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Safe Banking

12/31/14

Just in time for the new year, I've got a new article called Safe Banking up on SSRN. The article is a first principles reexamination of the industrial organization of financial services. It identifies the institutional combination of deposits and lending as the key problem in our financial system.

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For the Soul of the Party: the Budget Showdown and Financial Reform

12/10/14

Will we have an appropriations bill before a government shutdown? The fight over the 2015 Appropriations Bill is now focused on one of the non-appropriations measures stuck onto the bill by the House GOP. That provision would repeal section 716 of the Dodd-Frank Act, which prohibits bailouts of swap entities and pushes certain types of particularly risky swaps out of insured depositories. Section 716 might be thought of as the "Banks Aren't Casinos" provision of Dodd-Frank.

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MetLife as a SIFI

11/06/14

Along with some thoughts about FSOC's designation of SIFIs in general, over at Dealb%k.

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