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Bloomberg View says it is important for the living wills for U.S. banks that are "too big to fail" to be ready by the end of August 2011. This is required under the Dodd-Frank legislation. The living wills are designed to provide the government and the FDIC with an orderly pathway for winding down the business of a bank. On August 8, 2011, when the Dow Jones Averages dropped by 634 points, shares of Bank of America and Citigroup led the decline. Bloomberg points out that investors think Bank of America's net worth is only one third of what the bank claims, and for Citigroup this is less than half. Investors view the stocks of these banks as risky because they are likely to need to raise fresh capital and this would dilute the value of existing shares.

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Linda Thomsen is out as Director of the SEC's enforcement division since 2005, as she resigns. Robert Khuzami, a lawyer for a bank dealing in securities, Deutsche Bank, is her replacement. In the current environment with serious concerns about the independence of regulatory agencies and the different mindset needed for regulators, the new SEC enforcement chief will still have the mindset of someone working in a bank which was involved in the same risk taking practices that got the banks into trouble.

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Collapse of the easten european economies says the Economist would raise questions about the idea of a united Europe, the idea of the EU itself, and destabilize the euro - as countries in the EU like Ireland and Greece are in just as bad a shape. And in talk of enlargement of the EU will be doomed, and this is true of the western Balkans, TUrkey, and some countries int he former Soviet Union. Politically letting these countries derift could mean they fall for populists and nationalists of the bad type. And there is the serious economic consideration for banks in Austria, Italy and Sweden, which are heavily involved in lending to Eastern Europe. They could see catastrophic losses and put the banking systems of these countries at risk. Sweden has already chosen to help the Baltic Countries, and sees it has its political responsibility, and the whole Baltic region as its home, see link. The Economist suggests a differentiated approach depending on which group of countries in Eastern and Central Europe something that Angela Merkel of Germany also supports. For Ukraine the Economist says its best to let the IMF provide assistance. For the Baltic countries, plus Bulgaria, the Economist advocates an accelerated path to the euro, on the grounds that they are tiny and shouln't affect confidence in the euro. The Baltic countries have a population of 7 million. This approach is not supported by the European Commission or the European Central Bank. For the 4 larger countries, Poland, Czech Republic, Hungary, and Romania, the Economist says the priority should be to prevent further currency collapse, and to rescue the banks responsible for the foreign currency loans that are going bad, with the pain being shared between debtors and the banks, governments of lending and borrowing countries. Financial institutions like the ECB, the IMF, and the European Bank for Reconstruction and Developemnt, and the European Investment Bank should help support the rescue effort. ...

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The high cost of fines is likely to affect recapitalization of UK banks. Fines for Libor-rigging and compensations for customers on Payment Protection Insurance may cost the UK banking industry about 20 billion pounds, says Nixon. Other fines such as the $1.9 billion fine for money laundering activities of HSBC have to be added to this. This means less money for meeting stronger capital requirements and for lending to business and households. Higher compliance costs will mean higher costs in future years. HSBC estimates of the anti money laundering systems are about $990 million a year. The Bank of England has raised concerns about the need for additional capital to safeguard British banks.

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The Volcker Rule goes into effect in July 2012. Under the rule proprietary trading operations of banks must be divested by 2012, with banks getting an additional three years to comply for specific situations. The financial industry is pushing back against the rule with comment letters from industry firms. Mr. Volcker outlined his response in his letter of comments to the objections raised by financial firms. To the objection that this would reduce liquidity in the market and raise corporate borrowing rates, Vocker says that too much liquidity is a problem because firms tend to bid up asset prices in the hope that they can always find buyers.

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This WSJ article provides a detailed account of the positions of Clinton and Trump on Wall Street, the financial industry, banks, Dodd-Frank, regulatory reform, 6 weeks before the U.S. presidential election.

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Abut 3 million homeowners are expected to default on their mortgages in the 30 months ending in mid 2009, and two thirds of this or 2 million will go into foreclosure, according to Moody's Economy.com. So what led to all this which eventually hit the financial markets in the U.S., and also to a lesser degree in Europe, through the opacity of the mortgage securities created from bad mortgages with falsely tagged triple AAA ratings that ended up in the assets of banks and investment firms? The motivations of each group were perverted as things unfolded. When the packagers of securties were not responsible for what they were doing they pursued profit before ethical behaviour and all sorts of securities were created. As these packagers were allowed to shop for ratings the ratings companies gradually lowered their standards to attract business. Politicians failed in the free market atmosphere of the Republican Bush administration and Republican led Congress. Senator Bachus and Congressman Frank introduced legislation during the later period of the bubble but failed to draw support to curb the bad lending. Republicans blocked a new antipredatory lending law in North Carolina from being enacted for the country from 1999 onwards. And Bush without realizing the ramifications prodded HUD to push Fannie Mae and Freddie Mac to require higher percentage of loans to go to low income borrowers. Fannie and Freddie in turn met this requirement by increasing the demand for these subprime loans by buying the mortgage securities, which the packagers of these securities backed by subprime mortgage loans and incorrectly rated AAA by conniving ratings agencies were happy to supply. It was a sad situation with a happy -everyone could say the were bringing home ownership and the American dream to low income people, and business was signing up for this ride with short term gain in mind. And in all this financial innovation lost its legs as packaging these securities and constructing new investment vehicles like the conduits were being used in perverse ways. The basics of labeling something correctly was torn apart. You could not turn a subprime loan to low income borrowers or a loan without documentation to flippers and speculators into something different by simply labeling it as AAA. What the confidence in financial innovation in the American system did was help spread these securities all over the globe, where they were held with confidence by towns in remote parts of the Scandinavian north country as well as financial centres in Europe and Asia. At the state level politicians in California saw this as one of the state's star industries and protected it from legislation to curb bad lending, as most of the big lenders were based in California. Due to a strange set of affairs the Department of Corporations was left with the tasks of oversight of mortgage lenders in the state. It was concerned more with issues like protecting senior citizens from financial scams and was not staffed to meet the supervisory role of a huge mortgage lending business. When it comes to the Fed's role Greenspan also took the laissez fairre stand of not interfering with free markets, even when a lot of the bad lending was obvious and one Fed Governor Gramlich was pushing for better lending standards. The Fed supervisory role was over banks and banks were required to follow lending standards, but most of this lending had shifted to mortgage brokers and financial companies which were beyond the supervision of the Fed. Had the Fed extended its supervision to mortgage affiliates of the banks this could have increased the level of supervision and made a difference. But state regulation mechanisms in California by Department of Corporations show that the regulatory mechanism did not take into account the realities of mortgage lending and how it had changed. ...

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Too big to run is where the banks are today. Excellence in management would help, but banks have just grown too big, bigger than even before the crisis. Bank of America's 2.3 trillion dollars in assets is 10 times the size of Exxon says the Econmist, and they need to shrink and simplify things. And even with the deities at Goldman Sachs the bank remains a black box.

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Prof. Cochrane of the University of Chicago goes over the Federal Reserve's new "Enhanced Prudential Standards and Early Remediation Requirements" for big banks. He finds serious shortcomings in the Fed's proposals to regulate the largest banks. He points to the proposal that puts less than one dollar at risk for every 10 borrowed dollars as ridiculously low, and says the Fed is admitting it really does not know how to correctly measure and regulate credit exposure in today's banking system. The Fed's remediation requirements are basically ways to get regulators to take action early with "triggers," because regulators were slow to act in the last crisis. This is down to regulating the Fed, not the banks. As stated in recent editorials in the Journal, and supported by Daniel Tarullo at the Fed, the best way to protect the financial system is in having capital reserve requirements that are high enough and reliable enough for a crisis.

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Mervyn King, the governor of the Bank of England, is coming under increasing criticism for supporting the Conservative-Liberal coalition government's austerity plan, and for lack of efforts to fight inflationary pressures. On a major issue on which King has taken a clear stand- that the largest British banks should increase capital levels exceeding the international standards- not much has happened. Consumer prices in Britain were up at a 3.7% annual rate in December, and the government's austerity policies will also cause pain. In a recent speech King said that the Bank of England had limited ability to fight the higher unemployment and increased inflation. It was an admission of the limits of central bankers in the current situation. King said "a squeeze in living standards is the inevitable price to pay for the financial crisis and the subsequent rebalancing of the UK and world economies.

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This Wall Street Journal editorial comes out in favor of higher capital reserve requirements similiar to that suggested by Federal Reserve Board governor Daniel Tarullo. The Journal says that if regulators are serious in the U.S. about controlling systemic risk, then the 14% rule or a 15% rule for assets held in reserve by banks should be adopted. Daniel Tarullo had suggested a 14% capital reserve requirement. These requirements would be phased in gradually over several years. Basel III requirements require only a 7% requirement and is phased in over many years. Capital standards are likely to be gamed. For this reason the requirement for only Tier 1 capital to be eligible is essential. What about the Basel III standards and the European banks? Would this put them in a better position to earn higher returns. This should be a problem left for European taxpayers to tackle says the Journal. As long as U.S. taxpayers are supporting U.S. banks with an implicit subsidy to take on larger amounts of risk -because they will be saved in a crisis with taxpayer dollars- the Journal says it makes sense to require 10-14% in capital reserves. It cites the Japanese banks which were highly overleveraged with lower capital reserves compared to American banks, and fared poorly. The Dodd-Frank bill imposes a complicated set of regulatory requirements with regulators required to write new sets of rules. The editorial concludes that it is far better to tackle the problems in the banking system with a sufficiently high requirement for capital reserves to manage risks than to have the detailed rule making on every subject that Dodd-Frank suggests....

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One sees the "quintessential IBM-er", close confidant of Sam Palmisano, and the involvement with Ms Chiesi, where insider information is excahnged over dinners. Questions arise about the ethics prevailing at the country's supposedly high standard maintaining firms such as IBM and McKinsey where another high ranking executive Anil Kumar faces similiar charges. Did these senior managers not ask themselves what was the right thing to do or was the dividing line between ethical and unethical simply blurred. Top ranking executives at Siemens were also found making decisions where they could not see the difference.

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Timothy Egan vists the west coast of Ireland, near Dingle, where David Lean filmed "Ryan's Daughter," and sees abandoned half-finished houses. One in eight houses in Ireland sits empty he says, as the excesses of the boom years now are there for all to see.

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The Vickers commission, has been appointed by the Cameron government to look into the British banking system and the largest banks. Ringfencing to protect retail deposits from the bank's other investment activities has been suggested. The focus is on increasing capital requirements as critical to protecting British taxpayers and the banking system. This means going beyond the Basel 3 requirements to build an extra safety buffer for the types of situations the British government was faced with in HBOS, where losses were even greater than average. Determining this should be coordinated with EU and Basel regulators.

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U.S. Federal Reserve governor Daniel Tarullo tells the Council on Foreign Relations that so much remains to be done four years after the financial crisis. The law firm of Davis Polk says 67 percent of deadlines were missed for new rules required to be set in place by the Dodd-Frank legislation, including the Volcker Rule. Tarullo said: "It is sobering to recognize that more than four years after the failure of Bear Stearns began the acute phase of the financial crisis, so much remains to be done." Tarullo fears that crucial momentum may be lost because of the long delays stemming from resistance by the banks. Tarullo met with bank CEO's in April 2012. Banks have protested that Fed stress tests have not revealed the parameters for the testing. Tarullo's response given at a recent Fed conference in Chicago were that this would let banks game the exercize by running the Federal Reserve model and not improving risk management and capital planning, making this a mechanical compliance exercize. Banks have particularly opposed a requirement that limits the risk in business between two banks to 10% of their credit risk....

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Before taking up the job of enforcement chief at the SEC, Robert Khuzami spent five years running the U.S. legal division of Deutsche Bank. In that job he worked with lawyers who advised on the collaterized debt obligations issued by the bank, and the details to be disclosed to investors. Like Goldman, Deutsche Bank has faced alllegations of not disclosing the proper information for its CDO's. Before joining Deutsche Bank, Khuzami was a prosecutor in the U.S. attorney's office in Manhattan for 11 years.