Upon Further Analysis — Archives
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Are We Ready for Robo-Examiner?
Some observers have touted the promise of artificial intelligence (AI) in improving the quality of bank supervision. Recent staffing cutbacks at bank regulatory agencies have given this issue more immediacy. Can robo-examiners come to the rescue? More generally, what are some of the more promising applications of AI in bank supervision? And what are the…
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AI-Generated Supervisory Letter
As a test, I used ChatGPT to generate a supervisory letter given a set of facts. I didn’t use the bank’s name, but the findings corresponded to those of an August 21, 2021, examination of Silicon Valley Bank. The query also used Uniform Bank Performance Report (UBPR) data as of June 2021. Here is the…
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Was Bob Welch’s 1990 Cy Young Award a Travesty?
Baseball fans love to engage in retrospective arguments. Who really deserved the MVP or Cy Young Award (CYA) twenty, thirty, or fifty years ago? These arguments often pit old school statistics against sabermetrics. One especially controversial choice was Bob Welch winning the 1990 AL Cy Young Award over Roger Clemens. But was Welch’s selection really…
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Lessons Learned? A Report Card
We all make mistakes. But it’s also important to learn from those mistakes. Banking regulators frequently go thought a lessons learned exercise following bank failures and other events that expose weaknesses in the bank supervision system. We’ll look at some of the lessons learned from the 2023 bank failures and give out a report card…
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Reputation Risk – See No Evil?
Federal banking regulators recently announced that they will no longer examine banks for reputation risk. But they also went a step further by removing any references in examiner guidance to reputation risk or even the word “reputation.” These efforts come across as ham-handed, Orwellian, and more than a little silly. What is Reputation Risk? Reputation…
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How Leveraged are Big Banks?
U.S. banking regulators have proposed changes to the Enhanced Supplementary Leverage Ratio (eSLR), which is applied to the nation’s largest financial institutions. Supporters of the proposal argue that the eSLR should act as a backstop rather than a binding constraint. But a backstop that never acts as a binding constraint doesn’t make for much of…
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Understanding MRAs
Matters requiring attention (MRAs) play a critical, if little understood role in bank supervision. While cease and desists, consent orders, and civil money penalties are public documents, MRAs are kept confidential. This confidentiality means that even those who follow the banking industry closely may have only a limited understanding of how MRAs work in practice.…
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Speedbumps and Bank Supervision
U.S. rules for banks adjust requirements depending on the bank’s size and exempt smaller community banks from some long-standing regulations. Congressman Andy Barr has proposed legislation to make a larger group of banks eligible for these relaxed requirements. Other legislators and regulators have made similar proposals and have also suggested adjusting thresholds for regional banks…
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Supervisory Appeals and Unreliable Narrators
Much of bank supervision operates outside the public eye. Recent critiques of supposed regulatory overreach note the secretive nature of bank supervision but then make claims of their own that are hard to either verify or falsify. This can lead to an “unreliable narrator” problem. One area where this is readily apparent is in the…
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What are Unsafe and Unsound Practices Anyway?
The assessment of safety and soundness is among the most fundamental elements of bank supervision. But what does safety and soundness mean in practice? And what makes certain aspects of a bank’s condition or management unsafe or unsound? Some have suggested revisions to current safety and soundness regulations to base them more on objective risk…