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The Fed gets tougher on "too big to fail" but how tough? Does it have the guts to go after this problem asks Peter Eavis. If he does Bernake would go down in history as a hero says Eavis. Meanwhile Fed Governor Tarullo clearly point to the utterly inconceivable fact that after a crisis of these proportions with large banks being bailed out, the remaining banks and financial institutions are larger than before the crisis. And the banking lobby has stalled regulation to control the problems in derivatives trading and other areas. Splitting up or downsizing the banks and separating their social function as deposit takers in the economy from their trading desks and investment activity, is being advocated by central bankers from Volcker to Mervyn King. See links.

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The FDIC with help from the Treasury would bail out the creditors and the counter parties in the event a large financial institution fails. And then the FDIC would collect the money from some 120 banks. This is the idea behind a Geithner- Rep. Frank proposal. But critics point are skeptical whether the FDIC can collect the money from banks, which would be too weak themselves in a financial crisis. One critic said it allows the government to spend another $1 trillion to bailout banks, and then perhaps in one year or a hundred years collect that money back.

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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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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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Former Fed chairman sees the "resolution agency" as a key feature of new financial reform legislation in Congress. This agency would have the power to takeover a large troubled financial institution. It would have the authority to quickly shut it down and this would make it less likely for large financial institutions to take risks knowing the federal government would rescue them.

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Jon Huntsman, Republican candidate for President in 2012, calls for a fee on banks with a size that is above a certain percentage of the GDP. This would cover the cost banks impose on taxpayers when they are bailed out. It would eliminate the advantage banks gain from "too-big-to-fail," a subsidy Huntsman estimates to be one half percentage point in today's market. He points to efforts by the UK and Switzerland for more stringent financial standards than the U.S.

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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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Of 21 reader comments to this piece on banker pay, all except for 4-5, were very critical of the bankers behaviour, including many of their colleagues in the financial industry who commented. The lack of any response from the FSA on the grounds that its not the FSA's job, or from the Treasury, is disconcerting. Treasury is said to have not said a word, when RBS hired a head trader for a rumored 7 million pounds. All this coming on the heels of the RBS and Lloyds debacle, makes the Labor government open to attack from the Conservatives under Osborne and Cameron. and from Mervyn King of the Bank of England. They have expressed strong disapproval of the busines as usual attitude of bankers.

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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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Volcker says that even with all the fuss about the length of the Volcker Rule, its important to remember that the regulation itself is only 35 pages. And he says that lawyers for the banks are not honest when it comes to this, because they spent a lot of time finding holes in the rule and were working to add complications to it, and now they are turning around and saying that the Volcker Rule is too complicated. Asked about Dodd-Frank, Volcker says that it does make the U.S safer in a financial crisis because of the crisis resolution process set up under Dodd-Frank legislation. A bank fails and the resolution is clearly laid out- the government takes over and liquidates it, or merges it or sells it. Stockholders don't get a bail out, management is fired, and creditors have to take losses. A lot still depends on having vigorous and alert regulators. He sees two large problems, the Euro crisis and the U.S. deficit, which need strong action. Volcker remains perplexed by why the situation of huge disparities in income growth has not been expressed to a greater extent- on one side the lack of growth in income for the average family in 10-15 years and the other side having the huge increase in incomes at the top end. He does not know of any years when this was as big as it is now- except 1928, 1929....

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Jon Hilsenrath of WSJ provides an illuminating account of how Daniel Tarullo as head of the Large Institution Supervision Coordination Committee has changed the way bank supervision and rules are set for U.S. banks since the days of the 2008 financial crisis. Tarullo started the effort under Ben Bernanke and continues this in 2014-2015 under Fed chairwoman Janet Yellen. The New York Fed is seen as ineffective in bank supervision and the supervisory role is now entirely performed under the leadership of Tarullo, assisted by Kenneth Gibson and Timothy Clark. The trio are some of the great unsung heroes of the effort to put the U.S. financial system and the economy on a safer footing.

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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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How Obama's new selection for Fed governor, Daniel Tarullo- who taught banking law at Georgetown University- is shaking things up at the Fed. He is in charge of regulation of the banking system at the Fed. He has instituted a review of bank review practices and supervision at all of the regional Federal Reserve banks. With many banks failures in the south, the Atlanta Fed came in for serious review, and regulators from outside the area were sent to the Atlanta Fed. Tarullo did not hesitate to make new appointments for serious oversight, as regulators had simply become lax. Tarullo has brough in economists to take a fresh look at how the banking system would perform in the event of another crisis, and what action needs to be taken. This compares to individual bank examiners having alimited perspective what damage the overall banking system could do with lax regulation. He has also asked the Fed regulatory staff to look closely and hard at the troubled commercial real estate loans and toughen regulatory measures. Welcome and overdue as this is, in another banking crisis this could be too little too late. Congress has weakened regulatory reforms proposed by the Obama administration, and the Obama administration itself has not the will to address the tough issues raised by the banking crisis. Both have buckled under pressure from the lobbying of the banking industry, and the close connections between some banking executives and the administration. This has raised the level of urgency felt by Tarullo, Volcker, Mervyn King and some in the financial industry itself, with the issue of "too big to fail" and breaking up the larger banks into smaller ones, moving to the top of everyone's agenda. With the simple fact that if banks were "too big to fail" before the crisis, then they are much bigger now, and the question of what action must be taken shoved aside as too big to tackle....

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Areas in the "too big to fail" part of Dodd-Frank U.S. financial reform legislation where work remains to be done to prevent a future crisis include: the creation of living wills by the largest banks so that they can be dismantled in an orderly fashion, and the designation of which banks are systemic risks by the Financial Oversight Stability Council. The FDIC and the Federal Reserve have yet to finalize the rules for creating "living wills" for large banks. The rules are expected to be finalized by fall 2011. The FOSC is working on the designations and what criteria to use for selecting the non-bank firms that pose systemic risks. Progress has been made at the FDIC by finishing several rules for implementing a new system to wind down a large failing bank. The FDIC is hiring staff for a new office that focusses specifically on large complex financial firms. Fed Governor Daniel Tarullo has led the effort for higher capital reserve requirements for U.S. banks, requirements that would be closer to 14% for capital reserves. In an editorial on June 16, 2011, the Wall Street Journal said that if the Federal Reserve is serious about controlling systemic risk then it should support capital reserve requirements of 14%....

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J.P. Morgan Chase announces $2 billion in trading losses in May 2012. The Chief Investment Office unit made a bet with a trading strategy that CEO Jamie Dimon said had grown very complex. These losses could grow or shrink during the rest of the year.

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Systemic risks from "too big to fail" and the pushback on capital reserve requirements that leave banks with lower reserves. Ewing describes the role of the president of the Swiss Central Bank, Mr Hildebrand, in setting rules for higher capital reserves for Swiss banks than that of other countries and the pushback from the banks resisting the new regulations. "He will never find another job in Switzerland," a Swiss newspaper Der Sonntag quoted one banker saying this about Mr. Hildebrand. Losses at Swiss bank UBS during the financial crisis and the $2 billion loss at a UBS trading desk in 2011 have created a new awareness of systemic risk at banks. During the financial crisis banks used an optimistic estimate of "risk weighted assets" which led to insufficient capital reserves in a crisis even as the banks were shown to be well capitalized. A sense that banks in Europe and the U.S. will continue to have insufficient capital reserves at 3-4% of assets under new rules and with the longer phase in times for the new Basel III regulations of reserves at 7% of assets to after 2016....

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Former Fed Governor Kevin Warsh's views on the need for greater transparency and disclosure from the large U.S. banks and the risks to the financial system from "too-big-to-fail" banks in 2012-2013. He says the U.S. should not be dependent on the Basel standards for capital requirements and use its own system of stricter requirements similiar to the UK and Switzerland. His views are that the Dodd-Frank law puts too much dependence on regulators doing the right thing, information transparency is lacking for markets to impose discipline, and delegates too much to Basel standards which are not rigorous enough for protecting the U.S. economy.