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Archives for September 2018

September 28, 2018

BPI Comments on FDIC IDI Plan Requirement

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

Uncategorized

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

Letters

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

Advocacy, Systemic Risk and TBTF

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

Bank Liquidity (Research), Research

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

Advocacy, Amicus Briefs

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

Bank Capital and Stress Testing (Research), Research

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

Advocacy, Bank Capital and Stress Testing (Policy), Bank Liquidity (Policy), Systemic Risk and TBTF

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

Bank Capital and Stress Testing (Research), Bank Conditions and Credit Availability, Bank Liquidity (Research), Research, Systemic Risk and TBTF

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

Bank Activities and Structure

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

Cybersecurity (BITS)

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