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Eisinger says ten years from now people will look back and say Dodd-Frank has made our financial system safer. It has received the kind of criticism leveled at Sarbanes-Oxley which was a response to another period of bad practices in accounting and finance.

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At the height of the market a year ago Citigroup acquired Nikko Cordial for 1.6 trillion yen ($17.7 billion). Now in a reversal of an earlier decision, after announcing a loss of $8.3 billion on Jan 16, 2009 for 4th quarter 2008, Citigroup will consider Nikko Cordial a non-core asset, meaning that it would be sold if a buyer can be found in Japan. Japanese banks are relatively healthy and there are propects for finding a buyer there.

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Greek tax evasion is estimated by three economists who studied data from Greek banks at about $11 billion based on a 40% tax rate, a third of the country's annual deficit for 2009. Unreported income is estimated at $28 billion. Doctors, dentists, lawyers, architects, engineers are the biggest groups underreporting income. Greece's parliament took up a bill in 2010 but the bill failed because of oposition from these groups. It remains to be seen if the Samaras government with support of the IMF-EC can take action similiar to that taken by the Monti government in Italy to go after tax evaders. By cutting the minimum wage and incomes of lower income groups disproportionately compared to cracking down on tax evasion and protecting incomes of higher income groups the economic plan for Greece proposed by the IMF-EC and the Greek government becomes unworkable and threatens the social fabric. By not raising this issue Germany's media and government have appeared callous in their pursuit of austerity measures as working class Greeks protested in Athens in 2011-2012, even though some of the issues raised by the Germans are legitimate. France and Italy are imposing a wealth tax to cut the deficit but this is not taking place in Greece. Global financial media has also not reported adequately on these aspects of the problem in Greece and Italy....

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Dilution of the Volcker Rule by defining "hedging" as covering bank risk on a "portfolio basis," "including aggregate risk of one or more trading desks." The new wording is in a 174 page draft proposal for the rule released by regulatory agencies. The Federal Reserve, the FDIC, the CFTC, the SEC, and the Treasury Department are putting together the final wording. This opens the door for banks to engage in proprietary trading on their own account. Experts say this makes it possible for financial firms to make all kinds of bets on the market, by defining the risk of its portfolio broadly, such as a U.S. recession. Additional changes are the deleting of the requirement that chief executives pledge their firms are not engaging in proprietary trading. Another change that is being debated is whether to require banks to report all trading to a single repository so that regulators can see if there is systemic risk. The result of this would be a watering down of the original Volcker Rule provision in the Dodd-Frank legislation, that banned proprietary trading after the 2008 financial collapse on Wall Street....

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Peter Eavis discusses ways in which regulators are conducting ongoing supervision of large banks under the Dodd-Frank legislation- with stress tests, and the review of living wills of banks in 2016

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Nancy Koehn calls this a brave and insightful book, with relevance for readers watching the debt ceiling negotiations unfold in the U.S. in July 2011. The question he asks about how the elites could have got so many things wrong relate to Greece as well as the bubbles and ensuing crises in the U.S. in the last decade. Manolopoulos points to the problems of using GDP indicators if the economic activity it measures is not reflecting an increase in the productive capabilities and competitiveness of the country. He also cautions about the negative impact of liberalization of capital flows if this results in a large pool of global credit that short termist governments can access without regard to the longer term consequences of repayment. The creation of bubbles is one danger of access to large pools of capital. another danger is that this capital leads to governments relaxing all conservative practices of budgeting in managing a nation's finances.

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The House of Representatives just passed a bill to stem foreclosures and stabilize house prices by having the government through the Federal Housing Administration reinsure upto $300 billion of problem loans. The bills backers estimate 1.5 million foreclosures could be prevented by this bill but the Congressional Budget Office estimates only about 500,000 foreclosures can be averted this way. Under this bill lenders would have to writedown their loans to 85% of current value of the house. Borrowers pay a fee for the insurance and give up any share in future price appreciation to the government. According to the Congressional Budget Office the cost to the government is modest about $1.7 billion over years. The reason for the limited effectiveness of this bill is that it is voluntary, not much government money is extended. Many of the comments in the blog on this article as is the case with other articles on help to homeowners facing foreclosure show the widespread idea that its a bailout of irresponsible decisions by homeowners and mortgage companies who made the loans. This may be the reason why so little has been done in this regard and the limited government money extended even in plans put forth by Congressional Democrats like Barney Frank. Feldstein who is a former Chairman of the Council of Economic Advisors under Reagan has taken a different approach focussing on homeowners who may see the rational decision is to walk away from homes where they have no equity in their homes as prices drop by 20% and for government to prevent a wave of foreclosures in this manner. The danger is if not much is done there could be a downward spiral in home prices as foreclosure reach a new high in 2009. Last year according to Economist's charts foreclosures were averaging more than 100,000 a month now they are averaging more than 200,000 a month, this would take it from 1.5 million foreclosures in 2007 to 2.5 million in 2008. According to the Economist 9 million people owe more than their house is worth, the homeowners who have negative equity, and if they were to foreclose at the rate of 2-3 million a year and accelerating as the economy deteriorates, this could be enough to start a downward spiral. At that point a new President and Congress would have to take drastic action with a substantial amount of the government's money. In that kind of crisis not much thought would be given to the cost because like the financial meltdown that was feared during the Bear Stearns crisis the fears of a global severe economic crisis would make action necessary on many fronts of which housing would be one....

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The artificial nature of the target of debt to GDP of 120% for Greece in 2020. This is the target being followed in negotiations by the troika of the ECB, IMF and the EU. Experts say the sustainable level would be much lower for Greece -this would be much lower because of the aging population in Greece and lower level of workers to support retirees in future years, the inefficient tax collection system and poor prospects for changing it, the degree of control over monetary policy and the rate of change of debt. A recent study by the Bank for International Settlements shows debt sustainability at 85% after studying 18 countries from 1980 to 2010. No precise source has been found for the 120% target. An IMF Report in 2011 said the 120% was the "maximum level considered sustainable." Alan Auerbach at UC Berkeley and Michael Woodford at Columbia University, say the additional factors are relevant to Greece. The many unpredictables over the course of ten years is another serious difficulty.

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Of the 27 nations represented at the EU summit meeting on January 30, 2012, all except Britain and the Czech Republic agreed to the new measures for budgetary discipline. The new fiscal compact will come into effect after 12 eurozone countries have ratified the compact. This prevents one or two countries holding up the agreement. This provides the Merkel government in Germany an agreement on concrete measures for budgetary discipline- evidence of specific action to dissenters inside the Christian Democratic party and in German public opinion- which would enable it to support efforts by the ECB, the IMF and the EU to address the crisis, including the funding of the European Financial Stability Fund. The text of the fiscal compact makes it harder to block sanctions against countries that fail to impose budgetary discipline, while at the same time making allowance for countries with excessive debt such as Italy.

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Under the rules for the European currency and the European Union there is no mechanism or process of fines or other sanctions to promote compliance to debt and deficit rules. In the case of Greece, an examination of budget reports shows that Greece never met the deficit rule of 3% for any year except 2006 and it has never been within 30 percentage points of the debt ceiling. Greece's statistics are faulty and deficit figures are continually being revised upwards. Several times the figures were quadruple what was initially reported in late 2009, for instance the deficit figure was 3.7% of GDP, then revised to 13% of GDP, setting off the current crisis for the Euro and the European Union. In 2001 Greece failed to reflect $2.2 billon in military expenses. According to Eurostat, the EU statistics authority this was 10 times what was saved from the derivatives swap arranged by Goldman Sachs to trim Greece's deficit. That transaction trimmed the deficit by one tenth of a percentage point.

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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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Neal Wolin, Michael Barr and Diana Farrell who had roles in the Clinton administration are now key figures in the effort to get financial reform legislation through Congress against resistance from well funded lobbying groups. Farrell is one of two deputies to Lawrence Summers, Obama's senior economic advisor. Michael Barr is Assistant Treasury Secretary for financial institutions. Both Wolin and Barr worked at Treasury during the Clinton administration. After Clinton left office Wolin went to work for Hartford Financial Group and Barr went to teach at the University of Michigan. Barr has helped formulate much of the policy-making.

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This Journal editorial says Germany and France will have to pay for preserving the Eurozone one way or another. It suggests a direct approach of the German and French governments injecting capital for recapitalizing German and French banks that would take losses on bad loans to Greece, Ireland, Portugal, and Spain; combining this with bondholder haircuts for creditors, and reforms that include spreading the burden for Irish bank debt and cleaning up the cajas savings banks mess in Spain. This would mean exactly the opposite of what is taking place now, including the abandoning of individual country rescues and bailouts; which the Journal calls extending loans and pretending the problem is not with German and French banks that would have losses on the bad loans. The problem is that this places the entire burden on austerity measures in each bailout country which reduces growth and raises unemployment to levels that make the problem much worse than before. This is not happening because of a serious failure to reach agreement on the shared sacrifice and cooperation between the governments, creditor banks, the ECB and other parties in the eurozone, on a serious debt restructuring across the eurozone that would put the euro back to stability with some mechanism for serious financial discipline in eurozone states....

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Bank of England Governor warns that British banks are undercapitalized in Nov. 2012 and need to add to reserves for additional losses.

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Martin Feldstein points out why the recent agreement for a "fiscal compact" is no more than an empty statement about fixing the eurozone's finances. In this respect it is no different than the Stability and Growth Pact it replaces, with serious weaknesses. Feldstein cites the weaknesses in the language of the agreement. Each eurozone country is required to limit its"cyclically adjusted" budget deficit to 0.5% of GDP and bring its debt down to 60% of GDP. Compliance will be performed by the European Court of Justice and fines imposed. In practice the questions loom large- for a country like Spain with a 23% unemployment rate, isn't all of the 6% budget deficit cyclical? Again the agreement says deficits are calculated "net of one-off and temporary measures." Under this provision a lot of the stimulus programs would be considered in the category of "one-off." Other language lets eurozone countries frame budgets based on "exceptional circumstances" and "periods of severe economic downturn." Italy has declining economic growth, does it make sense to have a large budget surplus in that situation to lower debt to GDP, and how does that goal relate to "exceptional circumstances."...

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New rules for euro currency nations in Sept. 2011. The rules provide for sanctions against countries with budget deficits exceeding 3% of GDP, and national debt exceeding 60% of GDP. Countries that break the rules will be required to make a cash deposit in a non-interest bearing account for an amount that is 0.2% of GDP. If the situation continues the deposit becomes a fine. The European Commission will still require finance ministers permission to impose sanctions, but the voting system makes this harder to block. The European Parliament will consider 6 pieces of legislation to make these changes.

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Mario Draghi faces his first test as head of the European Central Bank as Italian bond yields approach 8%. Draghi has limited purchases of bonds of troubled EU countries to 5-10 billion euros each week. This has been sufficient to keep Italian bond yields from going out of control, but high enough to keep pressure on governments in Italy, Spain, Portugal and Greece to make necessary changes. France, Germany and other countries in the EU are working on new rules for making strict budget discipline legally binding, with enforcement sanctions by a EU budgetary authority. Germany is pushing for the new rules. France's Sarkozy with a legacy of Gaullist reluctance to surrender sovereignty in such matters had resisted such calls in the past, but is moving in the direction of convergence of fiscal policies as the only way to preserve the euro currency and the EU idea alive. Draghi is taking a flexible stance on inflation and lowering rates compared to his predecessor, Trichet. He sees signs of slowing manufacturing activity and credit tightening in Europe as signs that inflation will come down from above 3% to something closer to the 3% target set by the ECB. Economists expect him to lower interest rates for the eurozone to 1% from 1.25%, when the ECB meets in a week. The manufacturing purchasing manager's index went down to 46.4 in November, below the breakeven point of 50, which signals a contraction. Output and orders were down across all of Europe, including Germany. Economists say Draghi has left open the possibility of larger bond purchases if the new rules are made legally binding on eurozone members....

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The Journal editorial title suggests that Greece chose economic decline. It puts the responsibility for this choice on one political party that lied about its fiscal position, and another party that failed to take strong action. The government unions were uncooperative and resisted making changes. Making matters worse was policy from the EU that misread the Greece situation as a liquidity problem, and not as a solvency problem considering the huge debt Greece has piled up. And austerity measures pushed by the EU are doing little for growth- leading to an acceleration in the economic decline in recent months.

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Germany's calls for closer political and fiscal union for the eurozone countries to complement and support the euro currency arrangement. German chancellor Merkel calls it "more Europe," "step by step." It all hinges on French president Hollande and how well the Socialist party does in the elections to the National Assembly on June 10 and June 17, 2012. If he does well and gets a working majority with other like minded parties he will not need the support of parties that are opposed to giving up sovereignty. Hollande's mentor is Jacques Delors, a former president of the European Commission and a strong supporter of the idea of European Union. England under the Conservatives remains Euro-skeptic. France and Germany were driven closer by the idea of European Union by necessity, because of history and three wars. The European Union had strong support after 1945 from French and German leaders, Monnet and Adenauer, who struggled with political opposition but won over skeptics, with the process continued by German chancellor Kohl, a mentor of Angela Merkel....

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Failure of U.S. regulatory agencies to implement an important provision of the Dodd-Frank legislation- instructing regulators to find all references to ratings agencies in their rules, and then replace them with better standards for judging credit risk. Treasury's Office of the Comptroller of the Currency, is one of the agencies trying to gut this reform, says this Wall Steet Journal editorial. The S.E.C. voted unanimously in March and April to propose rules eliminating credit agencies in their regulations on money funds and stock brokerages. As the comment periods have ended, the Journal calls for the rules to be immediately made final. Officials from FDIC and OCC are dragging their feet on this. One problem they face is their assumption that the Dodd-Frank law requires them to come up with the perfect rule for measuring credit risk. This is not what the change is intended to do. It is enough says the Journal to return the responsibility for the right metrics and the hard work of analyzing a security back to where it belongs- to people who manage these assets and institutional managers. Even if they made some mistakes it would be far less than the systemic risk posed by having all major institutions making the same mistake at the same time and the entire system following flawed ratings by the big three credit ratings agencies. This happened in the 2008 mortgage securities financial crisis. S&P has stated that it does not support the old system. And new alternatives are appearing for ratings- CreditSights, Rapid Ratings, Kroll Bond Ratings which got S.E.C.' support, and other alternatives still to come....

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The facts that guide one's understanding of what is happening in Greece relate to the size of the public sector for a small country like Greece, and the failure of people from all classes of society from cab drivers and civil servants to small business and the shipping industry, to pay taxes. These two twin facts and a splurge of spending during and after the 2004 Olympics without proper and correct account keeping, has brought Greece to its present situation. One estimate is that every Greek person would owe 27,000 dollars, that is how much the national debt has swollen to- a massive 300 billion euros debt for a small country. This is 115% of its GDP. And the public sector spending simply went unchecked by different governments trying to win votes. Estimates are that the public sector makes up 40% of Greece's GDP, and government workers are 15% of the active workforce. Not paying taxes has become a societal trait in Greece, as a result the government does not collect an estimated 25 billion euros a year in taxes each year. And this does not include the taxes that would be paid if owners in the Greek shipping industry were to not take advantage of an exemption from paying taxes granted by the government. The result- Greece's socialist government of Prime Minister Papandreou has accepted a $110 billion euro bailout from the European Union and the IMF which comes with cuts in public spending and austerity measures designed to reduce the deficit form 13.6% of GDP to 3% in 3 years. Its important to understand what is happening in Greece, because from Prime Minister Cameron in Britain (with his cuts in government department spending of 25% over 5 years), to Prime Minister Naoto Kan of Japan (with a planned doubling of the sales tax), the mood in Europe and Japan is shifting to austerity measures that would correct excessive government spending. In Greece Papandreou and his ministers are making serious efforts to change a culture of not paying taxes. See the groups and links for Papandreou and Greece....