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White House visitors database shows lobbyists have frequent access to the White House. On one January day, Jan. 17, 2012, lobbyists came with the CEO's of their companies to 1600 Pennsylvania Avenue at 9 am for roundtable with President Obama. The CEO's are on the president's Jobs Concil. At 1 pm representatives from the meat industry arrive. And at 4 pm a lobbyist from Goldman Sachs comes for a meeting with Alan Krueger, chairman of the Council of Economic Advisors. Its a fairly routine day.

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Regulators from the S.E.C., the FDIC, the Federal Reserve and the CFTC, defend the plan to implement the Volcker Rule in Jan 2012 hearings before the House Committee on Financial Services of the U.S. Congress.

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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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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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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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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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Tim Pawlenty, former Republican governor of Minnesota, and co-chair of the Romney campaign, becomes the head of the lobbying organization for U.S. banks, Financial Services Roundtable. He succeeds Steve Bartlett. During his brief presidential run in 2012, Pawlenty raised $5 million in donations from banks. Sorkin talks to Bartlett about the appointment and Pawlenty's criticism of banks during the bailout. Bartlett says that in Washington what you say and think depends on the position you are in.

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The Large Institution Supervision Coordination Committee (LISCC) was setup by Fed chairman Bernanke and Fed governor Tarullo, in 2010. The Fed's 200 PhD's, bank examiners and other experts at headquarters are now tapped for the the task of looking at adverse scenarios, checking on assumptions made by the banks in their analysis, requesting data from large banks on their loan and securities portfolios, and asking banks to consider adverse scenarios. Such adverse scenarios include a decline in the U.S. economic growth of 1.5% in 2011, and decline in housing. The Fed checks the banks estimate of its financial position aginst the Fed's own standard and prods the banks to consider new risks. Before the 2008 crisis the Fed's 12 Reserve Banks did the day to day supervision and reported back to Board of Governors, a system that led to a diffusion of responsibility and did not work. Former Fed vice chairman, Alan Blinder, says the bank boards did not exercize responsibility, and "blew it, big time," during the financial crisis. This approach has the effect of acting as a early warning for the banks for things that could go wrong. J.P. Morgan Chase CFO Braunstein made a Feb 15 presentation to show that Chase's stress scenario was more stringent than the Fed's. The current review says Tarullo includes asking banks to do a check before issuing dividends to shareholders, and consider what would happen if the economy is in trouble in the next 9 quarters. According to Fed guidelines issued in November if the bank's plan does not show enough capital to handle economic, regulatory and lending risks, the Fed can challenge the bank's decision....

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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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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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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.

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Raghuram Rajan, Professor of Finance at the Graduate School of Business, University of Chicago, was appointed chief economist at the IMF in 2003. He presented a paper, titled "Has Financial Development Made the World Riskier," at the annual Jackson Hole meeting of economists and central bankers for 2005. Rajan says he had planned to write about how financial developments during Greenspan's 18 year old tenure had made things safer, but the more he looked the more evidence came up that the risk reward relationships in a normal functioning financial market had been terribly distorted. Market participants were being rewarded for wins but were not being asked to take on commensurate risks and impacts on their bonuses and rewards. He also cautioned about the use of credit default swaps which acted as insurance against bond defaults, and said insurers were generating big returns on this but with the appearance of little risk- even though the pain could be immense in a default. Banks were carrying credit securties on their books that posed risks to the whole financial system if things went wrong with the credit securities. Reaction from the gathering was unfavorable. Lawrence Summers, a former Treasury Secretary said, "the basic, slightly lead eyed premise of the paper was misguided."...

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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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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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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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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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IMF research by Ocampo and Erten shows that when adjusted for inflation since the 1970's, the prices of metals have remained about the same, food prices down 58%, and energy prices up 163%.

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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.