Upon Further Analysis — Archives
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The Case for Bright(er) Lines
As noted in an earlier post, efforts to reduce the role of supervisory guidance included limiting the use of numerical bright lines. While regulators need to develop and apply these bright lines with some care, their absence can undermine effective supervision. The “guidance on guidance” specifically cautions against the use of quantitative thresholds or bright…
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Supervisory Guidance & Selective Amnesia
Most attribute recent bank failures, at least in part, to a lack of quick and effective actions by bank supervisors. How much of the blame lies with Congress, senior regulators, or the banking industry lobby is more open to dispute. Attempts to absolve the latter groups rely on some selective amnesia. Actions that bank regulators…
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The Fed’s IG – Theory vs. Reality
A fundamental problem with the bill is that it tends to assume away political dysfunction and labor market realities. Our hyper-partisan political environment isn’t very good at filling independent, non-partisan positions.
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The Sad State of Interest Rate Risk Disclosures
Bloomberg Tax reports that Silicon Valley Bank omitted economic value of equity (EVE) metrics from its December 2022 10-K after including EVE for the previous ten years. Perhaps more notable, however, is that few large banks report EVE externally. Even fewer provide sufficient detail on key assumptions to allow for a meaningful assessment of interest…