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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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A review of the Volcker Rule for bank regulation in its final form by the WSJ in Dec. 2013 shows it leaves out language permitting portfolio hedging. Banks will not be allowed to use portfolio hedging creating new risks. Regulators wrote in the rule that hedges are not to "give rise .. to any significant new or additional risk that is not itself hedged contemporaneously." The Volcker Rule in its final form was influenced by regulators awareness of the J.P. Morgan Chase bank's huge losses from portfolio hedging in the Whale case. Senators Merkley and Levin in the U.S. Congress wrote to regulators saying a loophole in the Volcker Rule allowing portfolio hedging would lead to a repeat of the "London Whale."

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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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Moody's downgrades the credit ratings of 26 Italian banks in May 2012. Italy's largest retail bank Intesa Sanpaolo SpA, showed net profit of 804 million euros, up 22% from the prior year. Of this 183 million euros was from capital gains made using the ECB low cost loans under special ECB financing to buy government debt. The ECB financing was through the Long Term Refinancing Operation launched by the ECB in December 2011, which benefitted Italian and Spanish banks.

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Russia's Sberbank is expanding in Eastern Europe by making acquisitions from Western banks withdrawing from Eastern Europe. Sberbank sees the withdrawal of banks from Austria, Portugal and other countries as an opportunity to establish a major presence in Eastern Europe. With the $800 millon deal made in 2011 acquiring Volksbank of Austria's operations in Slovakia, the Czech Republic, Hungary, Slovenia, Croatia, Ukraine, Serbia and Bosnia and Herzegovina, Sberbank is now the largest bank in Eastern Europe with $386 billion in assets. Western European banks are faced with a pullback as they work to meet higher capital reserve requirements and respond to the effects of the eurozone debt crisis. Sberbank now manages $6.9 billion in corporate and individual loans in Eastern Europe.

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During 2022 the San Francisco Federal Reserve Bank issued 6 warning citations to Silicon Valley Bank, saying that its bank practices did not allow for enough cash in the event of crisis. By July 2022 in a full supervisory review it was rated deficient for governance and controls. At a meeting with senior leaders of the bank the possible exposure to interest rate losses related to Fed increasing rates was also discussed says this report in NYT. The Fed regulators stated that the bank was using wrong models showing that SVB bank would do better as interest rates increased. Questions are being asked about why things that were in plain sight were overlooked by the regulators- 97% of deposits were uninsured by the federal government. In the event of a crisis depositors might try to get their deposits out causing a run on the bank which is what actually happened with $42 billion attempted withdrawals in one day. Michael Barr is the vice chair for Fed supervision. A investigation report is expected by May 1. March 29 the House Financial Services Committee will hold ahearing in Congress. Peter Conti-Brown, an expert on financial regulation at the University of Pennsylvania calls it failure of banking supervision, and says it will become clear from the investigation whether the supervisors failed in their work. One of the problems is that the CEO of SVB bank, Gregory Becker, was on the Board of the San Francisco Fed. NYT says the optics of this is bad. Bernie Sanders, Senator from Vermont, calls it absurd that he was appointed to the Fed board of the institution that was regulating SVB bank. Another problem is that Randall Quarles, vice chair of Fed supervision 2017-2021 carried out a 2018 regulatory roll back law of president Trump in an expansive way says NYT. This law exempted banks with less than $250 billion in assets from strict banking supervision that larger banks were expected to go through. Fed chairman Powell is criticized for not  flagging these steps as potentially dangerous for the banking system in the way this was done by vice chair Lael Brainard. Brainard is now head of Biden's National Economic Council. She never favored the Trump law and had grasped early the risks of such deregulation. Sanders will bring a new law to prevent bank CEO's from sitting on Fed boards, and Senator Elizabeth Warren has called for an independent review that does not include Powell.     ...

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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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Estimates of the exposure of European banks to Greece's sovereign debt shows BNP Paribas has 5.01 billion euros in exposure to Greek debt, Societe Generale 4.23 billion euros, Deutsche Bank 3.02 billion euros, and HSBC 1.94 billion euros, Credit Agricole 0.85 billion euros, Unicredit 0.80 billion euros, Santander 0.51 billion euros. The exposure of French, German, Italian and Spanish banks in Greece is a critical difficulty in resolving the crisis, as the banks are still in a fragile condition after the global financial crisis of 2008. With the debate on resolution of the crisis focusing on how a three way distribution of the burden should take place between austerity cuts, bondholder and creditors, and taxpayers in Germany and other EU countries, negotiations are finally taking place between each European government and the banks of that country. Three countries where such talks are taking place are Germany, France and the Netherlands. Finance ministry officials in Germany and France met with representatives of the banks and insurers in their country to arrange for the banks to voluntarily take losses on their holdings. The respective holdings of Greece's government debt according to the Bank for International Settlements are: French banks $14 billion, German banks $22.65 billion. Overall exposure to Greece is higher for French banks- at $56.7 billion for French banks and $33.97 billion for German banks. This opens the door to a Brady Plan type solution for the financial crisis in EU countries Greece, Ireland, Portugal and Spain....

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Moody's says Spanish banks have not set aside reserves for $160 billion in potential losses.

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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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WSJ looks at dangerous work loads and overwork, 100-125 hour work weeks with little or no chance for rest for younger workers in investment banking. Most of them sign up for the opportunity unaware of the toll it will take and bosses routinely expect such dangerous workloads ignoring bank policies that are not enforced by the banks management. 

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The collapse of Silicon Valley Bank and its causes shown in graphs in the WSJ.

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523 European banks borrowed 489 billion euros from the European Central Bank on Dec. 21, 2011, under the newly created Long Term Financing Operation of the ECB. This is designed to meet the financing needs of European banks which are shutoff from normal financing of selling unsecured bonds to private investors because of market anxiety. Much of this is for replacing other outstanding ECB loans, with analysts estimating about 190 billion euros of new liquidity being injected into the banking system. This also has the effect of reducing the borrowing rates for government bonds. In Spain the government sold 5.6 billion euros of government bonds at an auction on Dec. 20, 2011, with the interest rates dropping from 5.7% a month earlier to 1.7%. Small and midsize banks in Spain helped surging demand by buying the bonds to use as collateral for three year loans from the ECB at 1%.

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Independent audit by the consulting firm Oliver Wyman of 14 Spanish banks.

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Marek Belk, head of Poland's central bank, says Poland should prepare for impact of a general slowdown in the eurozone. Poland's economy is expected to grow at 4% for 2011, but experience a slower rate of growth in 2012. Poland's public debt is at 55% of GDP compared to 120% for Italy. Belka said the mistakes in Italy show it is important to stay ahead of the markets. The action taken in Italy on November 14, 2011, if taken 2 months earlier would have prevented the jump in Italy's borrowing costs. Risks facing Poland come from the fact that a large proportion of the nation's banking assets are owned by banks of other European countries- as much as 70% of Poland's banking assets. As a result if these banks experience difficulties the local branches could become orphans. Belka would like to see private capital in Poland be used to bring a larger share of the banking sector back in Polish hands. Belgian and Portuguese banks are considering selling their banking operations to Polish banks, and PKO Bank Polski SA, PZU SA are possible buyers. Poland's central bank has kept interest rates steady at 4.5%....

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Central banks for the European Union, US and Britain show slight divergence in their approach to inflation. The Bank of England's Bailey increases interest rates in UK to 0.25% from 0.1% a slight increase to signal its direction more than a serious interest rate increase. In the US Fed chairman Powell indicates an intention to make 2-3 rate increases  in 2022 if the conditions require action. In the European Union Ms. Lagarde of the ECB will taper purchases to 20 billion euros a month later in 2022, and keep interest rates at minus -0.5%. The British pound and the euro gained slightly as a result. 

Supply chain issues and energy prices are a big part of the current inflation increases which were described as transitory by Mr. Powell. The persistence of this inflation led to recent moves by the central bank. At some point these pressures would ease leading to a long term policy approach that pushes for a robust economic recovery.

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Land prices went up by 500% during the last decade and developers went on a building spree in Spain. 800,000 units were built in 2007 alone. Many of these developed areas are now ghost towns. Coastal villages were turned into residential areas for vacationing Spaniards and for retired people from other parts of Europe. At the peak of the boom in real estate the construction sector accounted for 12% of GDP, double the level in Britain and France. Spain's deputy finance minister, Jose Campa,says that the adjustment in housing prices has already taken place. Yet housing prices are down a modest 12.8% from the peak according to the Bank of Spain. And that leaves plenty of skeptics. The estimates of the central bank, the Bank of Spain, are that banks in Spain have $280 billion in "problematic exposure," on their books, out of $580 billion invested in real estate and construction. With the lack of adequate disclosure it is hard to estimate the real exposure of Spanish banks. To improve investor confidence, the Bank of Spain is forcing banks to make more disclosures and to acknowledge bad assets faster....

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Sheila Bair, former head of the U.S. FDIC, points out flaws in the rules for capital adequacy ratios and risk weighted assets which allow banks to increase their capital adequacy ratios. The ratios show the financial strength of the banks and their ability to absorb losses, which makes their accurate calculation very important for the safety of the U.S. banking system, especially with large "too big to fail" banks. Bair says the 2013 U.S. Fed stress tests showed Bank of America as having a capital adequacy ratio of 11.4%, when it should actually be 7.8% without the risk weighted adjustment. The mortgage banking crisis showed how the risk wieighting can be flawed and give a distorted representation of the acutal risks facing the banks in its assets. For Morgan Stanley the 2013 stress tess by the U.S. Fed showed the capital adequacy ratio at 14%, taking out the risk weighting adjustment this drops to 7%. Bair says its not the idea of risk weighting that is the problem, but the way it is applied- for example considering sovereign government bonds in the eurozone as zero risk, or that only 20% of the accounting value of debt one banks buys from another bank is to be taken into account in setting the ratio. Go back to the drawing board she says, it makes no sense that Citibank debt be shown as having one fifth risk of IBM's. ...

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About 30% of German bank debt will mature in less than a year, according to the German central bank, well above the long term average of 22%. In its annual financial stability report, the Bundesbank provided a warning that German banks have increased their dependence on short term financing. This is a risky practice if a bank is caught short when interest rates rise. Hypo Real estate, a German property lender had to be taken over by the German government, because it could no longer borrow at short term rates below what it was receiving in interest for its long term loans. Andreas Dombret, a member of the central bank executive board, said that new bubbles could form in certain securities markets as banks make "a renewed increase in the search for yield."

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JP Morgan and Citicorp announced profits of $5.4 billion and $3.3 billion respectively in the second quarter of 2011. Christopher Whalen points to one area of serious risk on bank balance sheets, which is second liens or home equity lines of credit. FDIC data show U.S. banks holding $624 billion in second lien loans in the 1st quarter 2011. Core Logic data shows 11 million of the U.S. mortgaged properties - or 23% of all properties- being underwater in March 2011. Of this 4.5 million properties carry home equity loans. The average amount of negative equity for borrowers was $65,000. Whalen says the largest banks are pretending that the second liens are good because interest payments are being made. Borrowers pay only the interest for ten years on many of these home equity lines of credit. He says banks have written off $500 billion so far in assets related to housing, but this has not included much in the way of writing down second liens. If housing prices do not stabilize banks will need to make writedowns of first and second liens. Whalen says this loss is probably as large as the $500 billion already charged off by the banks. For the 1st quarter of 2011, the second liens were $136 billion for Bank of America, and it has written down $6.8 billion in 2010, Wells Fargo had $108 billion, and it had written down $4.7 billion in 2010. J.P. Morgan had $60 billion aso of the 2nd quarter of 2011. JP Morgan spokesman said the bank charged off $3.44 billion in 2010, and $1.3 billion in the first half 2011. Citibank had $46 billon in March 2010....

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Ireland owes $139 billion to German banks and $132 billion to British banks according to the Bank for International Settlements in Basel, Switzerland. German officials said in Berlin that Deutsche Bank was especially exposed to Ireland. But Deutsche Bank does not say that, it insists the money at risk is $400 million euros, calculated after the use of derivatives to hedge risk. Total gross exposure is not revealed by Deutsche Bank. This makes investors more nervous and promotes the spread of contagion to Greece and Portugal.

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Fears that the European banking sector is very weak and not enough has been done to fix the problems. KBC bank of Belgium has receivbed $41.5 billion in 3 separate rounds of government help. For abank with total assets of $425 billion this exceeds the bailout of the Royal Bank of Scotland. Moody's has issued awarning about credit risks at 30 Spanish banks and lowered its ratings of the Greek banking sector. Nonperforming loans at Russian banks compose 10% of the average bank's books and could rise to 25% by endo of 2009. Sweden has big problems for banks that laoned to the Baltic countries. A European bank analyst at Standard and Poors estimates a doubling in writeoffs for European banks in 2010.