Upon Further Analysis — Archives

  • Decoding Basel Endgame Changes

    Federal Reserve Vice-Chairman Michael Barr recently previewed “broad and material changes” to the Basel Endgame capital proposal. Summarizing changes to a 1,000-page proposal in a 24-minute speech will leave out a lot of details. However, we can get a good sense of the proposed changes based on what we already know about the old proposal…

  • Six Key Points on Bank Capital

    Policy debates about banking regulation often revolve around an understanding (and occasionally misunderstanding) of bank capital. While capital can be the most important indicator of a bank’s financial strength, the concept is not always well understood. Some assumptions about capital adequacy rely more on folk wisdom than evidence. Here are six observations about bank capital.…

  • Regulating Brokered Deposits

    The FDIC stirred up a hornet’s nest with proposed changes to its brokered deposits regulation. The proposal would reverse some changes made back in 2021 that narrowed the scope of deposits subject to brokered deposit restrictions. Some have criticized the proposed changes as lacking a strong empirical basis. However, the same can be said of…

  • Civility and Bank Supervision

    McGill University scholar John A. Hall describes civility as the “glue that holds society together.” Civility, or the lack thereof, comes up in politics, the workplace, and our personal lives. The role of civility in bank supervision presents an interesting case in point. The relationship between banks and their supervisors is inherently adversarial, but also…

  • Regulatory Limbo

    July 27, 2024 will mark the one-year anniversary of the Basel Endgame proposal. The negative response to the proposal means that a revised version isn’t likely until sometime next year. Meanwhile the Basel Endgame will remain in regulatory limbo. Finalizing regulations can take time, but some get enacted more quickly than others. The speed of…

  • Are Regulators Cracking Down on Interest Rate Risk?

    The Federal Reserve’s post-mortem following the Silicon Valley Bank failure stressed the “need to evaluate how we supervise and regulate a bank’s management of interest rate risk.” Other bank regulators have noted similar concerns. It’s now 16 months since SVB’s failure. What actions have regulators taken (or not taken) to address interest rate risk? SVB…

  • How a Bank Examiner Might Analyze a Baseball Statistic

    Baseball enthusiasts may be the nerdiest of sports fans. From the development of the box score in 1858, there has long been an obsession with statistics. These statistics have grown increasingly complex with the advent of sabermetrics, aka Moneyball. OPS, WHIP, and FIP have replaced old school stats like batting average, RBIs, and won-loss records.…

  • Banks, Regulation, and Reputation Risk

    Attempts to limit reputation risk considerations…make for a sort of enforced shortsightedness. Reputational risk can cause real, monetary damage, but that damage is hard to quantify before the fact. You should weigh not just benefits and risks that are easily quantifiable but to also consider those that aren’t.

  • Secrecy and Supervision

    New banking regulations go through an extensive notice and comment period. Regulators provide sometimes excruciating detail on the proposed regulation’s rationale, benefits, and costs. On the other hand, supervision of individual banks operates largely outside of the public view. Is this level of secrecy warranted?  What’s the proper balance between the need to maintain confidentiality…

  • Rethinking Core Deposits

    Core deposits are an important but often elusive concept with implications for both interest rate risk and liquidity. A strong core deposit base can help insulate a bank from interest rate swings and market turmoil. Accurately defining and measuring core deposits remain significant challenges for regulators, bank managers, and analysts. How can recent experience help…