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The U.S. Federal Reserve's actions in 2013 to counter the growing size and complexity of large banks. JP Morgan Chase and Wells Fargo assets have grown by 75% and 275% betwen 4th quarter of 2006 and 4th quarter 2012.

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Richard Fisher, president of the Dallas Federal Reserve Bank, has a three part proposal for tackling the "too big to fail" problem and concentration of 70% of the U.S. banking assets in a few banks. It calls for Market Discipline to be exercized in a way that the Dodd-Frank legislation fails to do. This is to be accomplished by having deposit insurance and the Fed's discount window apply only to traditional commercial banks, not the nonbank affiliates and parent holding companies. Customers, creditors and counterparties of all nonbank affiliates and the parent holding companies would be asked to sign a disclosure accepting that there is no government guarantee. In addition the largest financial holding companies would be restructured so that all their corporate entities would fall under a speedy bankruptcy process. Fisher does not clarify how he would do this restructuring. The Fisher idea come after changes in the banking industry through internal management restructuring following trading losses, legal settlements and the passage of a Swiss referendum called the Minder Initiative on compensation. Fisher suggests the U.S. Fed and regulatory authorites in other countries should push for further restructuring and calls for action beyond the limited results from 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. He is critical of Dodd-Frank's often ambiguous and lengthy worded legislation- 849 pages for the law and 9000 pages for the regulations written to implement the law. Fisher emphasizes the point that its hard to implement a law and enforce rules when its not clear and is difficult to understand....

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Thomas Hoenig, chairman of the Kansas City Federal Reserve Bank, says the five largest financial institutions in the US are 20% larger today than they were before the 2008 crisis. These five institutions control $8.6 trillion in financial assets or the equivalent of 60% of gross domestic product in the USA. He points out that whether we like it or not, these firms are too big to fail. Though these institutions survived the 2008 crisis with a bailout from the Fed as shown in the Fed's recent revealed documents, Hoenig says, little has changed on Wall Street. Two years after the crisis of 2008, these firms again operate with bonus and compensation schemes that reflect not the recent failures but a sense of success. Hoenig says this is why the American people are angry. An absence of accountability and blatant inequities with which smaller businesses and institutions were treated compared to the large ones, is why they will remain angry. Without this accountability he feels Americans cannot build a national consensus for the sacrifices needed to rebuild the American economy....

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Mitch McConnell, Republican U.S. Senate minority leader from Kentucky, recommends the nomination of Thomas Hoenig, as vice chairman of the FDIC. Hoenig, the former head of the Kansas City Federal Reserve Bank, has consistently pointed out the danger of financial firms that are "too big to fail."

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THe Economist says that the efforts of banks like Chase JP Morgan, Goldman Sachs and Wells Fargo to rewrite history are wrong and dangerous. They are wrong because there was acomplete collapse of confidence by December 2009 and these banks benfitted from state guarantees and government efforts to help the banks without which Goldman, and Morgan Stanley and other banks would be in serious difficulty or in danger of collapsing. It is dangerous because it is being used to distort the process of putting in place the right compensation incentives to avoid overleveraging and risk taking, putting in place prudent regulation, and taking all the right steps to prevent a future banking crisis, with the argument that this should apply only to the weaker banks. It is dangerous on two other points. The banking regulations should apply to the entire banking industry, and especially on banks that are too big to fail. These banks now are content to leave the toxic assets on their books where they are and consider government efforts to purchase these toxic loans and securoities or otherwise resolve these assets in some kind of good bank-bad bank scheme, as unnecessary. All this is happening even as the banks themselves remain poorly capitalized, even after raising funds in the capital markets recently, and remain very dependent on the government. The danger is that this may make everyone complacent in the event of a developing new storm....

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The Fed's own files, data from 21,000 Fed transactions over 2007-2010, are revealed in a kind of Wikileaks release. The data is available because of a transparency provision in the Dodd-Frank bill introduced by Vermont Senator Bernie Sanders. This editorial in the Wall Street Journal shows that banks on Wall Street received much more help than advertised. Goldman Sachs is shown to have used the Primary Dealer Credit Facility 212 times for an amount of nearly $600 billion. Morgan Stanley is shown to have used the overnight Fed lending program 212 times from March 2008 to March 2009. The Wall Street Journal editorial concludes that this makes it impossible for someone to argue that either bank would have survived the financial storm without the Fed's help. The same is true for General Electric. GE tapped the Fed's Commercial Paper Funding Facility 12 times for more than $15 billion And with the help of the FDIC's debt guarantee program GE sold $60 billion of government guaranteed debt. GE and Citicorp are shown to be the heaviest users of that program from November 2008 to Juy 2009. The overwhelming lesson, says this editorial, is to ensure that there is no repeat of this kind of situation. And the new Congress needs to tighten the too-big-to-fail criteria....

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Create small, more transparent financial institutions out of the big banks by breaking these big banks up and selling them to private equity. These big banks are too big to save, too big to manage, andprone to taking excessive risk, thus damaging the economy. Craft policy and antitrust laws so that no financial firms become too large, as this has been proven to create risks for the whole economy. Do this by dividing banks up regionally or by type of business. TARP simply contimues the old game of big banks and financial institutions. These are the views of Paul Krugman and Simon Johnson presented to the Joint Economic Committee of Congress on April 21, 2009. Also on the panel Kansas City Fed President Thomas Hoenig who said policy measures have focussed too heavily on propping up big institutions like AIG.

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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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Anat Admati, is a professor of finance and economics at Stanford University School of Business. He says banks should depend on generating 30% of their assets from equity, something the banking industry of today in the U.S. and Europe considers heretical. More of the bank's assets should come from equity and much less from borrowed funds. Outside of banking healthy corporations in the U.S. carry debt at about 70% of assets and there is no reason banks should not do the same. In 2013 says Admati, the situation is not much different from that after the 2008 global financial crisis- large banks carry liabilities and debt at over 90% of their assets. The $2.2 trillion in debt at JP Morgan Chase bank is about 91% of assets of $2.4 trillion. Basel III regulations allow banks to borrow upto 95% of assets, and proposed banking regulations in the U.S. put this at 95%, with the way this is measured still being debated. At such high levels of debt the margin of error is small, and systemic risk which is high in a globally interconnected banking system means the whole banking system can freeze from one large bank going into failure such as Lehman Brothers. This happened in 2008 and the margin of error is still small, which is why global banking is such a high wire act with the U.S. Federal Reserve, the ECB and other central banks issuing regular warnings and regulators faced with the task of keeping the banking system in check through vigilance and investigations of banks violating laws. How much difference has Dodd-Frank legislation in the U.S. made after 2008? Jason from Atlanta says in response to Admati's article, that the Glass-Steagall Act of 1933 was 37 pages and the banking system did not freeze up in the way it did in 2008 for the rest of the twentieth century until its repeal. The 879 page Dodd-Frank legislation of 2011 is overly voluminous and still leaves 243 rules to be written by regulators in consultation with the financial industry. Banks are larger now than they were in 2008 and have an outsized influence in shaping the rules, leaving the U.S. Federal Reserve's supervisory committee and Fed Governor Daniel Tarullo with the job of somehow keeping banks out of trouble. JP Morgan Chase, Admati reminds readers, has $2.4 trillion in assets as of June 30, 2013, and debts of $2.2 trillion, with $1.2 trillon in deposits and $ 1 trillion in other debt owed to money market funds, other banks, bondholders and the like. ...

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Simon Johnson, is Professor at MIT's Sloan School, senior fellow at the Peterson Institute of International Economics, co-founder of BaselineScenario.com a widely cited site on the global economy, and is a member of the Congressional Budget Office's Panel of Economic Advisors. Here he talks to the WSJ's Deal Journal reporters. He says the stress test don't mean much because the government using a milder scenario, made the banks look better than they really are. He suggests a wait-and-see strategy, as banks have 1 month to file plans on how they will raise needed capital and 6 months to do it. He sees a steeper yield curve on Treasury debt as a result, with long term Treasury securities like 20 year Treasury notes yielding higher than short duration securities, which should stimulate long term lending. Expect banks to issue more bonds than stocks which dilute shareholders value, and as bond prices are low. Johnson sees real risks of inflation in 1-2 years, becaue of the way the government has inflated the economy, in a manner he says like the private sector bubble. Expect the government to cut back to prevent this from happening. He also sees pretty good earnings in the financial sector in the second quarter which should help stocks. The question remains about how sustainable all this will be, because he says " the government by oversubsidizing the financial sector will get us stuck in the same kind of financial bubble that got us into the mess in the first place." ...

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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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Serious doubts remain about the effectiveness of value at risk or VAR quant models used by JP Morgan Chase to measure potential losses on a trade on a bad day. A newer model used by Chase in the first quarter showed smaller losses. When the old model was run this trade showed double the losses according to Chase managers. Greenberger, a former CFTC official and a professor at the University of Maryland School of Law, says if the trade become hard to unwind it shows poor risk management. And experts say it is not much of a hedge if it is done in an obscure part of credit markets and hard to unwind without serious losses. Peter Tchir, a former head of index trading at RBS bank, says CEO Dimon must have seen these kinds of hedges as part of his overall strategy, which is why he supported them in April 2012. The problem lies in that the bank size has grown to such proportions that its simply too big to manage, with trades it has to make becoming massive as a consequence.

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Sanford Weill built Citigroup into a mega bank through repeated acquisitions. He was the strongest voice for the repeal of the Depression era Glass Steagall Act banning banks from risk taking activities in investment banking. The Glass Steagall Act was repealed in 1999, and repeal legislation was given the name of "Citigroup Authorization Act." On July 23, 2012, Weill told CNBC: "I am suggesting that they (the big banks) be broken up so that the taxpayer will never be at risk, the depositors won't be at risk... Mistakes were made." Weill said that the housing bubble and the financial crisis has proved that the repeal was a mistake.

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Francesco Guerrera of the WSJ interviews Sergio Ermotti, CEO of Swiss bank UBS, and Andrea Orcel, the head of UBS investment bank. He asks Ermotti why the drastic restructuring at UBS, especially the downscaling of its investment banking operation. Ermotti says its because it was time to stop throwing money away on activity that did not cover the bank's cost of capital and the unhappiness of shareholders with the way UBS was operating. The string of bad news from UBS with legal settlements, trading scandals and huge losses have created a special situation at UBS which required drastic action. UBS was able to take the action also because of its successful wealth management business, which will become the core of its future business. Other banks such as Goldman Sachs and Morgan Stanley with large fixed income, currency and commodity (FICC) businesses, get more of their earnings from this unit and are less likely to follow UBS.

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Estimates of new rule making as a result of the Financial Reform Bill of 2010, range from 243 new federal rule-makings required based on an analysis made by law firm Davis Polk & Wardwell, to higher numbers made by other experts. The Journal reported in a separate piece on the analysis made by Davis Polk and Wardwell. That estimate includes 67 one time studies and 22 new periodic reports, as being a estimate on the low side. The Journal says the larger banks would benefit by being better able to handle the extra regulatory costs.