BPI has filed a comment letter with the federal regulators in response to their request for comments on a notice of proposed rulemaking to simplify and tailor the compliance requirements… Continue Reading
October 7
October 5
BPI Files Comment Letter on SCCL Rule
BPI recently filed a comment letter with the Federal Reserve in response to its request for comment on a proposed reporting template designed to provide the Fed with information to… Continue Reading
October 4
How Would Banks that Concentrate in Main Street Lending Fare in the Fed’s CCAR Stress Test?
We have frequently demonstrated that the focus of the Fed’s stress tests on bank performance under a single apocalyptic recession scenario overstates the risk of assets that perform particularly poorly… Continue Reading
October 1
Five Questions for the Federal Reserve on the GSIB Surcharge
Each bank in the United States designated by the Financial Stability Board and Basel Committee on Banking Supervision as a global systemically important bank (GSIB) is held to a capital… Continue Reading
September 21
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
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
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
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
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
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