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Simon Johnson reminds readers that in October 2008, Johnson, Peter Boone, and James Kwak, suggested that some European countries had given taxpayer-backed pledges to banks that had liabilities larger than their own gross domestic products. Their proposal included creation of a European Stability Fund with at least 2 trillion euros of credit lines guaranteed by all member nations, as well as Switzerland, Sweden, and the U.K., to buy time dealing with underlying insolvency in Ireland and other countries. Simon Johnson, is former chief economist of the IMF. He says the euro-zone only belatedly acted on this advice and the politicians never took responsibility for what they allowed to happen. The runaway financial globalization he says, was allowed to happen by US Treasury officials, but European banks were seriously involved in similar behaviour. These banks became too large relative to their economies, captured their regulators and acted recklessly. Europe's leaders haven't fully faced up to this and keep telling their voters that the problem is entirely because of US banks irresponsible behaviour. Ireland was the extreme example of this. And Johnson provides readers with the names of two books on the subject. David Lynch has "When the Luck of the Irish Ran Out," Fintan O'Toole has "Ship of Fools: How Stupidity and Corruption Killed the Celtic Tiger." Both laying out the intermingling of politicians, bankers and real-estate developers that resulted in the reckless growth and collapse of Ireland. In his own account in Atlantic magazine, May 2009, Johnson compared the US economc boom-bust-bailout cycle to what happened to Argentina, Russia and Indonesia. These were emerging middle class countries with crony capitalism, unsustainable debt and other problems. Johnson says, don't think these problems are limited to emerging markets. Its a global or general occurrence in which powerful people get together to build an economic model that brings growth based on debt. Under public pressure the German government keeps saying there must be burden sharing, that creditors must take losses also. Johnson says Angela Merkel and her colleagues have not thought through what signal this sends to the markets- which is to tell people to get out of Irish banks now. And the big German banks are telling the government they face big losses if Ireland or other European countries default. If the ECB can't pay, and the German taxpayer won't pay, Johnson asks, does the IMF have the resources to tackle Spain? If China offers to recapitalize the IMF with some of its $2.6 trillon in reserves, and becomes the largest shareholder, would the IMF headquarters be moved to Beijing as the Articles of Agreement require for the largest shareholder. ...

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The New York Times reports from the comments of current and former members of the Chase Chief Investment Office (CIO), that risk officers at Chase were ignored when they raised issues about the complex trades made by trader Iksil. Iksil's trades had the support of his manager Mr. Macris, and Ms. Drew who was in charge of CIO. The comments also indicate that at one point Mr. Macris brought in a Risk Officer with whom he had worked closely for many years. Risk Officers are supposed to be independent and their concerns seriously heard, with the authority to halt trades that pose excessive risks. Which made this kind of cozy behaviour in the CIO trading offices in London cause for alarm. These reports also say Mr. Braunstein, the new CFO at JP Morgan Chase, did not strengthen controls after he assumed office in 2010. Bank officials disputed this. The New York offices did not fully grasp the complex trades being made in the CIO London offices, and upper management let the CIO operate pretty much on its own, especially with CEO Jamie Dimon's confidence in Ms. Drew's management of the CIO. This led to another gap in the process of risk management. Dimon had other priorities and distractions, from problem mortgages coming with the acquisition of Washington Mutual, pushing back aginst financial regulation after the 2008 crisis, stress tests and others. At the same time the U.S. Federal Reserve, regulators, and Treasury's coordinated effort to merge failing banks with other larger banks- because of the lack of the process of unwinding failed banks provided later under Dodd-Frank legislation- created mega financial banks. Unlike what the U.S. under Treasury Secretary Rubin pushed for in the case of S. Korea during a banking crisis in 1997, Treasury under Geithner and Fed officials did not push for unwinding of failed financial institutions such as Countrywide and Washington Mutual in 2008-2009 Chase's own portfolio of assets under the CIO, increased by an astounding amount from $76 billion in 2007 to $356 billion in 2011. Even if Ms Drew had managed CIO well before, managing a portfolio of this size is most likely to have presented a whole set of new challenges and problems for which the CIO office was not prepared. Similiar concerns were raised by other Fed officials such as Fed governors, Hoenig and Fisher, who raised the issue that such mega-banks posed unacceptable risks and were too big to manage. Pressures to increase investing profits, growing complacency, relaxing risk management controls, led to the situation where a single trader Mr. Iksil, who had only joined the bank in 2007 according to other reports, could create large losses. This follows a situation at UBSin 2011, where a novice trader made bets that resulted in large losses....

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Federal Reserve proposals in Dec 2011 for large U.S. banks leave capital cushions at 5% of assets. This phases in the higher 7% of assets rule for capital reserves and a surcharge of upto 2.5% based on bank risk levels under new Basel III regulations for implementation in 2016.

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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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Eisinger says the Federal Reserve's staff plays an important role in regulatory reform. He quotes Cornell law professor, Robert Hockett, who says the general counsels tend to become more conservative over time and inclined to support the status quo. This makes required regulatory changes such as increasing the capital reserves at banks and reducing leverage more difficult. Eisinger describes the position of the U.S. Federal Reserve's general counsel, Scott Alvarez, on disclosure of lending by the Fed during the banking crisis, and on capital reserves, which veered more to the position of the banks which preferred less information be released and capital reserves be left at the 5% level than the 6% proposed by the FDIC and the Office of the Comptroller of the Currency. Comments by Alvarez in nonpublic hearings to Congressional staff members on May 18, 2012, about the JP Morgan London Whale trading losses, according to Eisinger, shows lack of awareness of the overall implications of the breakdown in financial controls and supervision inside the bank....

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Guerrera describes the vital role that FDIC chairman Gruenberg's plan for unwinding failing financial institutions will play in tackling the "too-big-to-fail" problem facing the U.S. He points to the increasing importance of this after the failure of risk management systems at JP Morgan Chase bank.

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George Osborne, Britain's Chancellor of the Exchequer, says he supports giving regulators powers to take action to split banks that do not ring fence their risky operations and separate deposit taking from risk taking activities. He says this as parliament considers legislation on banking regulation after the LIBOR investigations and problems in British banking following the 2008 financial crisis. Osborne said: "Irresponsible behavior was rewarded, failure was bailed out, and the innocent- people who have nothing to do whatsoever with the banks- suffered." Referring to the larger role of the financial industry in the British economy, Osborne stated: "Our country has paid a higher price than any other major economy for what went so badly wrong in our banking system." This comes as Britain feels the impact of a decline in growth in 2013.

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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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Banking regulation in the U.S. after the Dodd-Frank legislation differs from banking regulation rules proposed by the Independent Commission on Banking in Britain. Britain has a much bigger financial sector relative to the size of its economy than the U.S., posing larger systemic risks. The commission in Britain is proposing structural changes that would separate investment banking from deposit taking at banks. Banks would have separate balance sheets for these two activities- and operate them as separate subsidiaries- even though they are part of one holding company. This means it would be harder to raise money cheaply for risktaking in investment banking. Under the Volcker Rule in the U.S., banks investment banking and deposit taking would not be separated in a structural separation- there would still be one balance sheet- only banks ability to trade with their own capital and run hedge funds would be constrained. Some banks have spun off trading operations in the U.S. and the the rules banks have to follow have not been clearly defined. Too big to fail is still a problem under current American regulation, though its effects are mitigated to some extent. As one expert puts it, its hard to regulate the banks because too much money is involved and the banks have the money and the lawyers to prevent or dilute new rules. The argument made by the banks in Britain is that universal international banking provides a public benefit and efficiencies. But John Vickers, the former chief economist of the Bank of England, and chairman of the Independent Commission on Banking, has a different view. He said recently, "it seems quite hard to identify and quantify real efficiencies as distinct from purely private gains."...

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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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Bank of England's governor Mervyn King disgrees with the Gordon Brown government on the issues of financial regulatory reforms.

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The largest U.S. bank holding companies, including Bank of America, J.P. Morgan Chase and Citigroup, and two foreign banks Deutsche Bank and Barclays PLC must submit initial plans for "living wills" by July 1, 2012. The Dodd-Frank legislation requires financial firms to develop plans that lay out how they could be liquidated if they went under in a crisis. This legislation gives the FDIC and other regulators the power to seize and dismantle a failing financial firm, to help mitigate the problems of "too-big-to-fail" firms. The FDIC and U.S. regulators lacked such powers at the time of the collapse of Lehman Brothers in 2008. The FDIC and the U.S. Fed co-wrote the living will rule for "comprehensive and coordinated resolution planning." In all, 124 banks, including 100 foreign banks with U.S. affiliates, which have over $50 billion in assets worldwide, must submit plans and update on a regular basis. Smaller banks will have the deadline extended to December 2013.

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Bank of England's governor Mervyn King says that there "has been very little reform" in the FSA and the Gordon Brown government's bank overhauls. He said in a speech to Scottish businessmen that "the belief that appropriate regulation can ensure that speculative activities do not result in failures is a delusion." Paul Volcker, former Fed chairman, is of the same view that regulation will not do what is necessary to avert another crisis, that separating speculative activities from normal deposit taking and banking activities is an essential part of reform. According to King, the capital requirements that regulators impose will not be enough as they are arbitrary, and its hard to know how much capital will be needed for an unpredictable crisis. And having "too-important-to fail" banking firms to continue existing, would require a resolution regime. The better option he believes is to draw a line between utility banking with government guaranteeing these bank's socially necessary functions, from the speculative activities that can be left to market discipline. This means breaking up "too big to fail" firms. Conservative party's Osborne, as shadow Chancellor of the Exchequer, sees the need for this separation of banking activities....

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Ring-fencing the retail operations of UK banks from possible losses in the investment banking activities was part of proposals by the Independent Commission on Banking in the UK. Now a parliamentary commission calls for periodic reviews of such ring-fences to ensure this separation is actually still in place, and not been diluted or otherwise removed by bending the rules to favor banks because of lobbying by the banks. It says "over time the ring-fence will be tested and challenged by the banks. Politicians too could succumb to lobbying from banks and others, adding to pressures to put holes in the ring-fence." The report emphasized that a lot more needs to be done to restore standards in banking, especially after recent reports of LIBOR and other revelations of market rigging and corruption. The emphasis in the report is for banks "to be discouraged from gaming the rules."

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JP Morgan Chase CEO Jamie Dimon's confidence in Ina Drew was based on her hands on abilities, especially demonstrated during the 2008 financial crisis. Current and former bankers in this account by the Times Silver-Greenberg and Schwartz, say things changed in the years that followed. In 2010 Ina Drew was ill with Lyme's disease. The conflicts between the risk taking propensities of traders at the London trading desk under Mr. Macris, and the more risk conscious New York trading desk under Ms. Duersten, had already led to shouting matches under Ina Drew. After her illness and her absence from the office for long periods this spilled out into the open. In early 2011 Ms. Duersten left Chase after 16 years. Her replacement who would be new to Chase could not restrain the risk taking propensities of Mr. Macris and the London trading desk, the way Duersten and Ina Drew had done earlier. Macris and a trader reporting to him, Mr Iksil (referred to as the "London Whale" for his massive trading positions and bets), were free to operate without any restraint in this environment. Ina Drew returned in 2011, but she was not the same hands on person after the illness. She moved to the corporate offices on the 48th floor, instead of being on the floor above the New York trading desk. In 2008 she had held daily meetings with traders required to defend their trading positions. This did not happen in 2011. Jamie Dimon learned about the London Whale in the Wall Street Journal, April 6, 2012. Dimon's efforts in pushing back against stricter regulation, stress tests, and other issues were to lead to the CEO of the 2008 crisis becoming a much more distracted person in 2011. He was taken unawares by the breakdown in the relationship between the London and New York offices of the Chief Investment Office, the changed situation of Ms. Drew, and that risk management controls at the bank were not in place. Risk management overly depended on one person and the trust of the CEO in that person, and was not institutionalized. At the same time it should be noted that Jamie Dimon became CEO of Chase after the acquisition of Bank One in 2005, and Ina Drew was hired in that year, only three years before the crisis of 2008. The merger of other banks into JP Morgan Chase created a bank with $360 billion investment portfolio- even Ina Drew had never previously handled a portfolio of this size and the complex risks brought in with the Washington Mutual portfolio....

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Did U.S. Treaury Secretary, Timothy Geithner, ignore a key request by President Obama to present plans for the restructuring of Citigroup after the government bailout of Citigroup? Ron Suskind says this is what happened in his book on the Obama administration and how the White House operated to make key decisions. Ron Suskind, intervewed key members of the Obama White House economic policy team, Lawrence Summers, Christina Romer, Peter Orszag. In all Suskind conducted 700 hours of interviews for his new book in Sept 2011: "Confidence Men: Wall Street, Washington and the Education of a President." According to the book, in early 2009 after Obama authorized a series of stress tests for banks he told Geithner to develop a plan for restructuring Citigroup. A month later at a meeting not attended by Geithner Obama raised a question about the status of the plan. He was told by Romer that no restructuring plan had been developed for Citi. Suskind says Geithner disagreed about a plan to restructure Citi and decided to ignore the request. Geithner and the Treasury Department say Obama asked Geithner to develop a backup plan to overhaul banks if the government was forced to keep a big ownership stake in the companies, and "there was fortunately never a need to put them in place." Geithner told Suskind that he doesn't slow-walk the President on any matter. Other aspects of the operation of the economic policy team that Suskind covers are a series of memos from top aide Pete Rouse raising questions that ongoing communication between some members of the economic team and Summers was giving Summers power to shape policy. Summers, Director of the National Economic Council, is shown as trying to keep out the views of Romer and budget director Orszag from reaching the President without going through him. When Orszag gives a private report to the president on the deficit, Summers objects saying that this was immoral. Obama lacked the fresh ideas needed to tackle the problems created by the mortgage and banking crisis of 2008, when he used the Clinton administration economic policy team of the 1990's- Rubin, Bernanke, Summers and Geithner. Fresh approaches were needed two decades after Clinton's election in 1992, and the Bush administration that followed, as many of the problems developed during this period. The similiar embedded thinking was shared during the Clinton and Bush administrations and the economic advisors about dealings with the banking sector, but the situation for deficits, unemployment, housing, and the economy had completely changed requiring fresh approaches. ...

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The FDIC chairman, Mr. Gruenberg has defined the agency's strategy under the "orderly liquidation authority" given by the Dodd-Frank legislation to deal with financial firm failures. The Lehman Brothers collapse ruffled fianncial markets worldwide because of the lack of such authority and a organzed well defined plan to deal with bank failures. Gruenberg described the plans to the WSJ. Once the Treasury Department and federal agencies agree that a financial institution has to be taken over, the FDIC would first unwind the parent holding compay of the firm by putting it in receivership and revoking its charter. Unlike the situation for Lehman, the firm's subsidiaries can continue to operate, with financial support from the FDIC held parent company provided by the U.S. government under Dodd-Frank legislation. The next step would be for FDIC to create a "bridge company," with most of the firm's assets going into it. At that point equity holders would be wiped out and a debt for equity swap would be made with creditors. The firm would come out of this process as with a Chapter 11 bankrupcy, as a new recapitalized private firm. The FDIC is trying to build credibility in the markets that it has the ability to do this smoothly, and Gruenberg admits that till it happens its hard to convince markets in a decisive way. Another problem is that 85% of the international assets and derivatives of top U.S. banks are in the UK. Former Fed chairman Volcker is guiding the FDIC, and he sees the FDIC's efforts to work closely with the UK very favorably. These efforts are significant and vital to avoid the worldwide disruption in financial markets that ocurred after the Lehman collapse, and provide a well planned action plan in place of an ad hoc day by day response....

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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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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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The Basel 3 Rules and the extra capital cushions required by 2019, will double the amount of core equity a big bank holds as a proportion of assets. This is happening earlier because markets are making banks increase their capital cushions. But more needs to be done to make "too big to fail" banks in the U.S. and Europe safer, says the Economist in a May 2011 special report on international banking. An independent commission in Britain has suggested an additional equity buffer of 3%. The Economist says the Basel committee should consider similiar rules for the largest banks. Another proposal is being considered by Swiss regulators who want to see their banks holding the equivalent of 9% of their risk weighted assets in convertible capital. This kind of buffer is considered essential to prevent the kind of sudden collapse of the global financial system that was seen in late 2008.