2) A proper program would have taken the underwater long dated HTM at a MTM. Then @federalreserve should have required banks to cut dividends & buybacks & raise capital within that year. The @USTreasury should have taken Sr. Pref retire-able upon full capitalization of the… twitter.com/i/web/status/1…
3) Taking HTM bonds from banks at par, for a year, without taking Sr. Pref & explicitly requiring banks to raise capital within 12 months exacerbates moral hazard, transfers future risk to the DIF & taxpayers & ties the hands of the Central Bank vis a vis monetary policy.
4) Without the “stick” of warrants or Sr. pref there is no way to “force” banks to raise capital. Remember, Sec. Paulson - through Bob Steel - told Freddie to raise capital in 2005. The company refused to take dilution citing ‘market conditions’. We know how that ended (it… twitter.com/i/web/status/1…
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1) The fact is that @FDICgov#deposit#insurance is outdated. Don’t consider only the $250k or amount but underlying activities when assessing deposit insurance. It was designed for a Glass-Steagall world. Today, the #DIF should be priced relative to underlying business risk.
2) An old fashioned community bank that merely takes deposits and makes loans within its customer geography should be assessed at a different level than a bank that is also an asset manager, insurer, and investment bank.
3) #FDIC insurance should be priced based upon underlying activity AND business line risks. The DIF assessments for plain vanilla, old fashioned banks, should be essentially free up to a dollar amount that captures the deposit needs of their local customers.