Viewpoints: Washington/Regulatory
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2011
Relationships Are Hard, Especially with Regulators
American Banker | Jun 15 There are no divorces in banking. Despite the many temptations, and even the occasional justifications, bankers cannot indulge their passions and treat examiners harshly.
Approving Loans Is a Risky Role for Bank Directors
American Banker | Jun 15 The dilemma for community bank directors is to choose between minimizing their personal liability and the useful function that board reviews of individual loans can serve.
Raise Interest Rates, Boost the Economy
American Banker | Jun 14 The Fed policy of keeping short-term interest rates near zero is deterring lending, hindering job-producing investment and undermining confidence.
Stress Tests for Community Banks Would Be Mission Creep
American Banker | Jun 14 Internal stress-testing is a good practice, but regulatory use of hypothetical results to determine supervisory ratings or required capital levels would be destructive.
Two Sets of Standards, One Big Muddle for SIFIs
American Banker | Jun 6 Firms designated as systemically important financial institutions are damned twice: first with the Dodd-Frank resolution regime, and then by the global SIFI regulatory requirements.
The OCC Clears Things Up on Dodd-Frank Preemption Measures
American Banker | May 27 The preemption provisions in the Dodd-Frank Act have been a source of confusion. Acting Comptroller of the Currency John Walsh eliminated the uncertainty.
Stop Shrieking about Durbin and CFPB, Start Planning Instead
American Banker | May 27 The more we hear about how banks will be killed by Durbin or some other monster, the more we can expect investors to shun bank stocks. They wont buy into Crybaby Banking.
Michaels Breach is Warning on the Durbin Amendment
American Banker | May 26 If the Fed rule goes into effect, fraud costs will be funded not by interchange revenue or by retailers, but by consumers and the community banks.
Bad Mix: Politics and Crisis Prevention
American Banker | May 26 The banking and S&L crises in the 1980s were driven by seriously flawed fiscal, monetary and regulatory policies. The same is true of the latest crisis.
A Funding Cut that Mortgage Scam Artists Would Love
American Banker | May 25 Depriving distressed homeowners of easy access to trained counselors would hurt everyone except for the fraudsters who are offering bogus mortgage help.
Expanded Remittance Information is Coming, So Get Ready
American Banker | May 24 The banks that are willing to offer expanded remittance information to their business customers will have an immediate competitive advantage over those that do not.
OCC's Walsh Gets It Wrong on Preemption
American Banker | May 18 The acting comptroller of the currency's claim that the "prevent or significantly interfere" standard is only "the starting point" for analyzing preemption issues is troubling.
Fixation on the Next Quarter Has Bad Results
American Banker | May 18 Moving away from an excessive focus on quarterly earnings can produce real safety and soundness gains for financial institutions and strengthen the regulatory mechanism.
The Systemic Risks of a Reg Q Repeal
American Banker | May 16 The Regulation Q repeal will significantly exacerbate interest rate risk and present even greater challenges in maintaining banking stability.
Fincen Partnership with Financial Institutions Working as Planned
American Banker | May 3 Banks have told us that their understanding about how they contribute to deterring and helping law enforcement bodies detect crime has grown.
FDIC's Covered Bond Concerns Misplaced
American Banker | May 2 Bottom line, neither Congress nor the FDIC should limit covered bond issuance by a bank. In fact, covered bond issuance by banks of all sizes should be encouraged.
Home Loan Bank Proposal Off the Mark
American Banker | Apr 20 This proposal could remove a critical source of liquidity throughout the country — member institutions could be required to hold at least 10% of their assets in mortgages.
Illiteracy and Complexity Don't Mix Well
American Banker | Apr 20 A working knowledge and understanding of financial concepts is critical given the prospects of traditional government-sponsored safety nets, which are becoming less secure.
What Well-Governed Banks Have in Common
American Banker | Apr 19 Banks that get governance right will have better odds of success in any economic climate. Conversely, if a bank is experiencing serious problems the governance process needs attention.
When Bad Things Happen to Good Banks
American Banker | Apr 14 Ending TBTF expectations that promote moral hazard is a worthy goal. But, as noted, systemic risk strikes not just evildoers and slackers, but also innocent bankers and counterparties.
What Exactly is Durbin Fixing?
American Banker | Apr 14 Re: "Durbin to Dimon: Debit Reform 'Overdue,' Not 'Idiotic'" Mr. Durbin and politicians like him must live under the absurd notion that the citizens of the U.S. no longer have freedom of choice.
Ron Paul's Tilting at Gold Windmills
American Banker | Apr 13 There are few topics where more intellectual capital has been spent on an issue of lesser practical value as the prospects for either a partial or total return to the gold standard.
To Avoid Foreclosures, Try Forbearance
American Banker | Apr 12 A well-structured forbearance program would likely save many homeowners from defaulting on their mortgages, and it would do so at a very modest cost.
Coping with New Consumer Credit Risk Realities
American Banker | Apr 12 Rational judgment must complement the efficiencies of the laws of large numbers. Bankers must avoid the lure of financing consumers that believe in spending beyond their means.
A Covered Bond Solution for Housing
American Banker | Apr 11 Covered bonds will be very high-quality assets in any case, but such a rule would suggest that unlike FHLB advances they would not be able to pass all their risk to the FDIC.
The Many Benefits of Brokered Deposits
American Banker | Apr 8 Recent bank failures have given brokered deposits a bad rap. When used properly, they carry benefits that vastly outweigh the isolated instances where they are misused.
Seize the Moment: Use Settlement Talks to Halt Abuse of Homeowners
American Banker | Apr 5 Some in Congress don't want banks held to account for their actions. But banks should be held accountable, and if anything the proposed terms should be strengthened.
Avoid Bloated, Bogged-Down Governance
American Banker | Apr 4 During times of transformational change the governance structure and process tends to get complicated. These programs require full dedication and adoption of four features.
Regulations Are Burying Small Banks Alive
American Banker | Mar 31 The 2,300-page bill will heap at least 10,000 pages of new regs on community banks while doing almost nothing to solve the problems that brought us to financial panic in 2008.
Dodd-Frank's Bizarre Notion of 'Ability to Pay'
American Banker | Mar 29 Maybe the idea was that banks were too stupid to see that they needed to "consider" ability to pay, but once compelled to consider it, they would make better lending decisions.
Short of Dumping, at Least Delay Durbin
American Banker | Mar 24 I urge financial institutions to make the impact of this legislation tangible and meaningful to Congress. Illustrate the cost of this regulation in real terms.
Brokered Deposits' Broken Reg Structure
American Banker | Mar 24 There is growing consensus that the focus should be moved from a rigid definition of the means of gathering deposits to the characteristics of the deposits themselves.
Banks Are Not Like Utility Companies
American Banker | Mar 22 The utility model is best suited for economic activities in which the consumer, by virtue of the service has little choice. That is not true in today's banking environment.
Community Banks Can't Let Dodd-Frank's Repeal of Reg Q Stand
American Banker | Mar 16 An eleventh-hour amendment to Dodd-Frank that repealed Regulation Q could punish community banks that serve as the lifeblood for small businesses across the country.
To Fix the GSEs, Copy Ginnie Mae's Model
American Banker | Mar 9 We cannot afford to tie government backing to specially chartered financial companies. The question then becomes how to involve private capital in the process.
Banks Still Need a Robust Secondary Mortgage Market
American Banker | Mar 9 While the GSEs have become struggling entities in conservatorship with a doubtful future, the structure of the secondary mortgage market remains significant, especially for community banks.
How Do You Rate Your Fairness Awareness?
American Banker | Mar 8 Bank boards of directors and senior management should move promptly to establish a fairness-awareness culture to assure that every interaction the bank has with the consumer is fair.
Dodd-Frank Capital Rule a Weight on U.S. Banks
American Banker | Mar 8 We ask that the agencies reconsider the NPR in order to minimize the unintended consequences. Agencies should require U.S. banks with advanced approaches to use Basel I calculations.
Regulatory Balancing Act
American Banker | Mar 1 We must tilt toward regulation that promotes a safe and sound financial system but lean away from regulation that hinders growth and competition.
A 120% Solution for Our Homeownership Problem
American Banker | Feb 18 What we need is just the type of tax incentive that has routinely been given, generally at far higher amounts annually to the affluent who purchase McMansions.
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