On September 28, BPI submitted a comment letter to the FDIC concerning the proposal to renew the Insured Depository Institution (“IDI”) Rule’s information collection requirement. The letter, which was submitted… Continue Reading
September 28, 2018
Archives for September 2018
September 26, 2018
BPI Submits Proposal to SEC on “Nexus” Presumption for Collateral Consequences of Criminal/Enforcement Matters
On September 26, BPI submitted a proposal to the SEC concerning a nexus presumption for Rule 506(d) of Regulation D and Section 9(a) of the 1940 Act. Specifically, BPI recommended… Continue Reading
September 21, 2018
BPI Responds to Washington Post’s Unsubstantiated “Too Big to Fail” Claim
In a September 10 news article “A guide to the financial crisis – 10 years later”, Renae Merle reports as fact that large banks remain “too big to fail.” Ms…. Continue Reading
September 21, 2018
Six questions about the Net Stable Funding Ratio (NSFR) requirement
Six questions about the Net Stable Funding Ratio (NSFR) requirement Yesterday, the Basel Committee on Banking Supervision (BCBS) “reiterated their expectation of full, timely and consistent” implementation of the Basel… Continue Reading
September 21, 2018
Joint Trades File Amici Brief In Support of Petition for U.S. Supreme Court Review of National Bank Act Preemption to a California State Law
On Monday, September 17th, BPI, along with the ABA, CBA, Chamber of Commerce and MBA, submitted an amici brief in support of Bank of America’s petition for U.S. Supreme Court… Continue Reading
September 20, 2018
What a Recent Fed Paper Gets Wrong on European Stress Tests
A recent paper by Niepmann and Stebunovs (2018) (henceforth N&S) presents data suggesting that some European banks may have “gamed” the European Banking Authority’s (EBA) stress tests by adjusting their… Continue Reading
September 14, 2018
Banks are a Bulwark Against, Not a Source of, Financial Crisis Risk
The financial crisis that consumed our nation a decade ago caused a great recession that led to unemployment for millions and lost savings in the trillions. Between 2007 and 2010,… Continue Reading
September 13, 2018
Banks’ Resiliency Rose in the Second Quarter Supported by Higher Capital Levels
The Bank Conditions Index (BCI), which provides a summary measure of the condition of the U.S. banking system, rose in the second quarter of 2018 as shown in the chart… Continue Reading
September 13, 2018
Bank Policy Institute Sends Letter to the House Financial Services Committee in support of the Brokered Deposit Affiliate-Subsidiary Modernization Act
On September 13, the Bank Policy Institute sent a letter to the House Financial Services Committee in support of H.R. 6158, the Brokered Deposit Affiliate-Subsidiary Modernization Act. The bill would… Continue Reading
September 13, 2018
BPI Sends Letter in Support of the Consumer Information Notification Requirement Act
On September 13, the Bank Policy Institute sent a letter to leadership of the House Financial Services Committee in support of the H.R. 6743, the Consumer Information Notification Requirement Act. … Continue Reading