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Профиль

Jeremy Kress

Профиль Vively

Associate Professor of Business Law, University of Michigan Ross School of Business. Views my own.

Dodd-Frank was signed into law 16 years ago today. That means regulators are now ~15 years late issuing incentive compensation, source of strength & early remediation rules. These rules could've helped prevent SVB. Instead of another report, regulators should just do the work Congress assigned.

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This, from Barrett's dissent in Cook, is among the many critical questions unanswered by Roberts' majority opinion. What happens when a Dem president in 2029 orders Warsh to increase bank capital requirements? Deny a bank merger? Break up JPMorgan? Roberts doesn't say.

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We’re going to need to get comfortable referring to today’s decision as Cook I because you can bet your ass there’s going to be a Cook II.

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When your defense of speaking at a regulated bank’s private dinner during a blackout period is “we only talked about regulatory policy,” I think you’ve lost the plot.

The Wall Street Journal

Exclusive: The Fed’s vice chair of supervision spoke at a private dinner Bank of America hosted for clients hours after the central bank announced its latest policy decision. on.wsj.com/4gqqVTu

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.@grahamsteele.bsky.social and I filed a comment letter today contending that the latest Basel capital proposals are unlawful. The Collins Amendment requires big-bank capital rules to be at least as strong as small banks'. These proposals illegally flout that congressional mandate.

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Sequels are always worse than the original, and Trump's FSOC guidance is no exception. Today I submitted a comment letter on behalf of a group of legal scholars opposing the new guidance, which is somehow even more ass-backward than the original version FSOC adopted in 2019.

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So, I wrote about bank mergers (again). My new book chapter looks back on my time overhauling bank merger oversight in the Biden administration, examines the Trump admin's partial dismantling of our changes, and charts a path forward for future reforms. papers.ssrn.com/sol3/papers....

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“enhance”

Federal Reserve

@federalreserve.gov, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency finalize changes to enhance community bank leverage ratio: www.federalreserve.gov/newsevents/p...

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It remains a mystery how the Fed is supposed to be independent for one purpose, but not for others. If independence over bank regulation/supervision is undesirable or unconstitutional, the Fed should be stripped of its authority.

Colby Smith

Warsh is set to tell lawmakers on Tuesday that the Fed's independence in setting rates is "essential" but that policy decisions related to bank regulation and "public monies" should not be given the same deference

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Regulators could keep capital in the banking system, ensuring that it supports lending and strengthens the economy. Instead, they're letting banks go on a stock buyback spending spree, diverting capital from where it's actually needed. www.ft.com/content/67d4...

US banks make record buybacks on Trump’s looser rules and choppy marketsSix largest lenders spend $33bn on shares, smashing market forecastswww.ft.com
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Instead of “quietly asking,” Treasury could demand standardized, usable and comparable financial data from private credit firms. But that would require a functional Office of Financial Research, which Bessent has gutted.

Punchbowl News

First in the VAULT: The Treasury Department has begun quietly asking private credit firms to submit information detailing their business models and ties to the regulated financial system. @brendanpedersen.bsky.social has the scoop: punchbowl.news/article/vaul...

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Dude, just take the L

Aaron Rupar

Jeanine Pirro: "The judge has neutered the grand jury's ability to investigate crime. As a result, Jerome Powell today is now bathed in immunity preventing my office from investigating the Federal Reserve. This is wrong and it is without legal authority."

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I read Bowman's speech to mean that the biggest winners will be the "DSIBs" - super-regionals with $250B+ assets. She suggests they will see more than a "modest" decrease in capital requirements. That's an odd policy to roll out on the 3rd anniversary of SVB's failure...

Federal Reserve

Speech by Vice Chair for Supervision Bowman on Basel III and bank capital rules @cato.org: www.federalreserve.gov/newsevents/s... Watch live: www.cato.org/events/basel... Learn more about Vice Chair for Supervision Bowman: www.federalreserve.gov/aboutthefed/...

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New paper alert! My latest, "Enforcing the Community Reinvestment Act," with Jeff Zhang, is forthcoming in @washulawreview.bsky.social. TL;DR: Using 20 years of data, we find that CRA enforcement does not incentivize banks to invest in low-income communities. papers.ssrn.com/sol3/papers....

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In Senate testimony last week, Comptroller Jonathan Gould defended his handling of the Trump family's bank charter application by praising his agency's "superb professional" staff. This week, he busted their union.

Bloomberg Law

The Office of the Comptroller of the Currency told employees that it is canceling the agency’s collective bargaining agreement, according to an internal email obtained by Bloomberg Law.

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Jonathan Gould, getting politics out of bank regulation.

Elizabeth Warren

Trump Grifting 101 Step 1: Silicon Valley Billionaire donates to the Trump campaign Step 2: Raises funds for a new bank promising his "political network" will get it done Step 3: Submits bank charter Step 4: Gets it approved rapidly + celebrates with Trump's bank regulator:

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Jay Powell’s legacy on bank regulation: letting the fox guard the henhouse. subscriber.politicopro.com/article/2026...

POLITICO Pro: Wall Street lawyer to head Federal Reserve department of supervisionRandall Guynn will be the first head of supervision to have spent most of their career outside the central bank in decades.subscriber.politicopro.com
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The "stop politicizing banks" administration wants banks to be immigration agents. 🫠 h/t @grahamsteele.bsky.social www.wsj.com/politics/pol...

Exclusive | Trump Administration Considers Requiring Banks to Collect Citizenship InformationA potential executive order would enlist banks in the Trump administration’s illegal-immigration crackdown.www.wsj.com
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The top 0.09% of banks accounted for 40% of banking system profits last year. This is not what a healthy financial system looks like. www.ft.com/content/8fc1...

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