The FDIC's single point of entry approach survived its first test Tuesday the five-member board voted unanimously to flesh out how the policy will work when a systemically important company fails.
But this show of unity may be misleading and fleeting.
The proposal was only put on the agency's open meeting agenda on Monday, which suggests Chairman Marty Gruenberg wasn't entirely sure he had the necessary votes.
And it's now obvious that Vice Chairman Tom Hoenig and Director Jeremiah Norton still have some fundamental concerns. As you read their statements, you can almost see them scratching their heads, wondering if SPOE has any chance of working in the real world.
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For instance, on how much equity and debt a holding company should be required to hold, the FDIC proposal asks if the amount should be calculated against total assets, versus risk-based. That's vintage Hoenig, and such a shift would make the requirement akin to Brown-Vitter levels something the industry's been trying to avoid.
"The FDIC is interested in commenters' views whether the leverage ratio would provide a more meaningful measure of capital during a financial crisis where historical models have proven to be less accurate," the proposed statement reads.
Finally, I can't resist sharing Karen Shaw Petrou of Federal Financial Analytic's take: "The FDIC's release today outlines how its single-point-of-entry approach to systemic resolution could work, but it provides scant comfort yet that it can or will."
The policy statement is open for comment for two months. The industry wants and needs this resolution process to work if it has any hope of convincing critics that policymakers have found a way to end too big to fail.