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George Will describes the views of Richard Fisher, president of the Federal Reserve Bank of Dallas on "too-big-to-fail" risks in the U.S. banking system.

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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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The Wall Street Journal's reporting in Sept, 2011, on France's bank BNP Paribas. Contributor Nicolas Lecaussin quoted a BNP Paribas executive saying the bank no longer had access to dollar funding. There is a loss of dollar funding to French banks from U.S. money market funds as the funds reduce exposure and shorten maturities. Analysts point to the French banks having one of the lowest ratios of liquid assets to short term funding needs in Europe. This reporting was questioned by BNP Paribas and French government officials. This happened as central banks including the U.S. Fed intervened in markets in September 2011, to ensure full availability of dollar funding to French banks.

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U.S. Federal Reserve chairman Yellen launches a sweeping review of practices for supervision of large banks in Nov. 2014. The review is designed to check "whether there are adequate methods for decisionmakers to obtain all necessary information to make supervisory assessments and determinations," and whether channels exist for decision makers to take into account divergent views when important issues arise. This is in response to questions about how the culture at the New York Federal Reserve may have stifled differing opinions on how banks should be supervised and what is proper information sharing between regulators and banks.

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An internal IMF document that estimates Europe's banks are short of capital by $273 billion. IMF managing director, Christine Lagarde, tries to downplay the report by saying this is not from a stress test that the IMF conducts. In August, Lagarde, called for an "urgent recapitalization" of European banks. As France's finance minister, Lagarde, steadfastly insisted French banks were well capitalized. France worked hard to prevent requirements for significant capital reserves under the Basel III rules. The higher capital requirements were supported by the U.S.. Simon Johnson said in his blog, that as long as European banks had inadequate capital to act as a buffer against losses, European countries had no safe route for restructuring their debts.

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AIG and GE Capital are designated "systemically important" financial institutions by the U.S. Treasury in 2013.

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Renewed calls for higher capital reserves by banking regulators and Britain's Independent Banking Commission after $2 billion in losses at UBS. The losses were a result of derivatives trades made at UBS's London trading desk.

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This WSJ editorial says GE's decision to exit the banking business follows the U.S. Federal Reserve's move to designate GE Capital a "systemically important financial institution," subject to extra scrutiny by the Fed and stricter regulation. This reduces the potential for higher returns that existed in the earlier environment of limited regulation. It points out that GE was so keen on escaping the "too big to fail" label and stricter regulatory oversight that it was willing to pay $6 billion in taxes to repatriate cash from overseas as part of shrinking GE Capital. In an earlier editorial in 2011 WSJ pointed to the role of GE Capital in the financial crisis of 2008, when GE shares dropped to $6 and GE needed government rescue funds.

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Abrantes-Metz, a professor at the Stern School of Business, New York University, looks at the problems of stress tests of banks 2010-2014.

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Paul Volcker before the U.S. Senate Banking Committee on May 9, 2012, before the announcement of the $2 billion trading losses by J.P. Morgan Chase. The following day Chase announced the losses from trades made by JP Morgan trader Bruno Iksil- nicknamed the "London Whale"- who made a complex hedge on a group of corporate bonds, betting $100 billion that the bonds would not default. The Volcker rule as it is currently written would not prevent such a transaction. The problem as Volcker pointed out before the Banking Committee is that under "too big to fail," "the losses would be socialized with the potential gains all private."

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Moody's Ratings company downgraded banks in the U.S. and Europe on June 21, 2012. Morgan Stanley, J.P. Morgan Chase, Goldman Sachs, Citigroup were downgraded two notches. Morgan Stanley managed to stave off a three notch downgrade. Credit Suisse was downgraded three notches. Bank of America was down one notch, and Wells Fargo which has only a small trading operation was not reviewed. This is the first time since 2007 that Moody's has conducted a sweeping downgrade of banks. About 100 banks were reviewed by Moody's. Banks being downgraded have large trading operations or investment banking business that is subject to higher risks. Greg Bauer, a managing director of global banking at Moody's said in his statement: All of the banks affected by today's actions have significant exposure to the volatility and risk of outsized losses inherent to capital-markets activities." For Moody's the main issue was that the capital bases of banks are maintained, considering that government support is less likely than before, according to Mr. Wassenberg, Moody's managing director for European banks. The impact on banks will be fewer opportunities for trading revenues for some banks, and will raise borrowing costs for banks. Moody's also cut the ratings of large European banks with significant trading operations. This includes Deutsche Bank, Barclays, HSBC, RBS, BNP Paribas, Credit Agricole, Societe Generale, UBS, and Royal Bank of Canada....

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Macroprudential policies of central banks in S. Korea, Indonesia, China, Canada, and other countries, as concerns grow about a housing and credit bubble.

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Transcripts of Federal Open Market Committee meetings of the Federal Reserve in 2006, show new chairman Bernanke, and New York Fed president Geithner's failure to see the housing slump. Fed Governor Susan Bies raised the housing issue at meetings of the Fed, and is ignored by Bernanke, who sees a soft landing for the housing market.

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The Bernanke Fed's decision on Sept. 16, 2013 to continue the pace of bond purchases is seen with relief in emerging markets and taken positively by equity markets worldwide. The Fed's decision is based on evidence of sluggishness in the economy and in the pace of job growth, as well as the likelihood of more political uncertainty about the budget because of sharp differences between Democrats and Republicans.

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Frank Rich on the ticking bomb in the banking system and the bank lobbying that has kept reform from happening. Phil Angelides leads the Financial Crisis Inquiry Commission which is due to begin hearings soon. But says Rich, Angelides who is following in the footsteps of Ferdinand Pecora who investigated the 1929 crash as chief counsel of the Senate committee that did the investigating, will have to deal with a lot of resistance as he tries to alert the public to the need for action before a new crisis develops. For this to happen there will be aneed for more awareness of what happened, and a serious investigation, and prosecutions where necessary. Interestingly National City Bank was investigated then by Pecora. It is the predecessor of today's Citibank. At the time National City repackaged bad Latin American debt as new securities which it sold eaily to investors who later lost badly. Weill and Rubin at Citigroup made a series of bad decisions at Citigroup leading to huge losses at the bank, for which they have not accepted responsibility....

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In its May 2011 special report on international banking the Economist points out the need for banking regulators to take stronger action than they have so far. What it calls "pre-emptive insurance" it says is needed - stronger regulation, larger capital cushions, and some form of separation of different kinds of banking. Without this the dangers of excessive risk taking and banks that are "too big to fail" will continue to threaten the world's economy. Banks that are smaller and better capitalized says the Economist can fail more gracefully than the large mega banks that exist at this time. In fact the banks today in the U.S. are larger than at the time of the 2008 crisis. Other analysts also point to the lack of major changes in banking and financial structures today compared to the situation before the 2008 crisis, both in Europe and the U.S.

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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....