1) Attempts by the Fed to argue it was a roll-back of the Dodd Frank that caused, or led to, the failure of #SiliconValleyBank are 100% untrue…
2) the bill didn’t prohibit or in any way prevent the Fed from applying enhanced prudential supervision standards. It permitted the Fed to do such enhanced prudential supervision on any BHC, or category of BHCs, if it was concerned that such BHC(s) could pose a risk to financial… twitter.com/i/web/status/1…
3) Second, and more important, the root of the failure to supervise interest rate risk at the banks was 100% tied to the Fed’s 2013 final rule that allowed non-GSIBs to elect to exclude most items from regulatory capital…
4) This can clearly be seen in “
THE FEDERAL RESERVE SYSTEM BOARD OF GOVERNORS HOLDS A MEETING ON A REGULATORY CAPITAL FRAMEWORK FOR BANKING ORGANIZATIONS FINAL RULE”
5) the precise statement in the rule is: “ the final rule would allow non-advanced approaches banking organizations to make a onetime election to opt out of the requirement to include most elements of a AOCI in regulatory capital. While these banks would not be required to… twitter.com/i/web/status/1…
6) Those are the facts. I am not partisan in calling BS in the financial sector. I believe good public policy, and it’s necessary adjustment, require truth and facts at their core not politics. It is thus I am writing.
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1) When the Gov't expanded the Fed’s balance sheet from $4t to $9T banks were forced to invest that newly printed money. The banking problems are tied to the fragilities of a fractional reserve system, in which deposits are leveraged by lending long... @SquawkCNBC@JoeSquawk
2) Taking long dated securities at par - rather than at current values - without requiring banks to raise new equity, increase deposits, shrink their portfolios or suspend dividends or buybacks only pushes the problem into the future...
3) The Fed liquidity program is not the answer. The lagged effects of Federal Reserve interest rate increases on credit performance haven't begin to hit loan portfolios. Guaranteeing deposits won’t solve it...
1) The fact is that @FDICgov#deposit#insurance is outdated.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.
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.