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Jeremy Kress Profile picture
Jeremy Kress
@Jeremy_Kress
Assistant Professor of Business Law @MichiganRoss. Co-Faculty Director @MichiganCFLP. Former Federal Reserve attorney.
Mar 15, 2023 • 10 tweets • 3 min read
There is a developing narrative that SVB would have met all regulatory requirements, even if Congress and Fed had not substantially deregulated.

I think this narrative is likely wrong. 🧵 The analysis linked above purports to show that SVB would have satisfied the modified LCR that originally applied to banks with $50B-$250B in assets, based on December '22 data.

(The modified LCR was essentially 70% of the full LCR that applied to even bigger banks).
Mar 14, 2023 • 10 tweets • 4 min read
A few thoughts, speaking only for myself:

Debating whether stress tests, the LCR, NSFR, living wills, or any of the other enhanced prudential standards would have saved SVB/Signature misses the forest for the trees. S.2155 and "tailoring" sent the clear message that $50B-$250B banks are not systemically important, and should not be treated as such. Policymakers took their eye off the ball.
Sep 9, 2021 • 8 tweets • 4 min read
A quick thread on Jay Powell and bank consolidation.

Tl;dr: By waving through bank mergers, Powell has undermined the Biden Administration's professed commitment to enhancing competition. The President should replace him as Fed Chair. Under Powell's leadership, the Fed has been a rubber stamp for bank mergers.

The Powell Fed approved 95% of merger applications in 2018 (up from ~80% under Obama Admin). The Powell Fed also approved contested mergers at record speed: four months, on average (down from ~1 year).
Dec 19, 2019 • 9 tweets • 4 min read
Unsurprisingly, big-bank lawyer Thomas Vartanian opposes @SenWarren and @RepChuyGarcia's Bank Merger Review Modernization Act, based on my research.

I want to explain why Vartanian's critiques are misleading, disingenuous, and flat-out wrong. /1

americanbanker.com/opinion/fix-cr… I've already rebutted the argument that @CFPB doesn't need a separate say on bank mergers b/c it has a seat on the FDIC board.

The FDIC doesn't oversee the biggest mergers. And even if it did, its focus is safety-and-soundness, not consumer protection.

Dec 6, 2019 • 4 tweets • 2 min read
I've seen arguments (in @morningmoneyben and elsewhere) that the Warren/Garcia proposal to give the @CFPB a say in bank mergers is unnecessary because the CFPB Director already sits on the FDIC Board.

I want to explain why these arguments are wrong. 1/ First, the largest banks and bank holding companies are within the OCC's and Fed's jurisdiction - not the FDIC's.

So the CFPB is currently excluded from reviewing mergers involving the banks it supervises (those with >$10B in assets). 2/