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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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Regulators at the U.S. Federal Reserve and the FDIC are planning to reject the "living wills" plans of 4 of the 8 systemically important banks, including JP Morgan Chase bank, in April 2016. The banks will have to come up with revised plans and strategies to address bankruptcy and issues raised by regulators, or face sanctions including higher levels of capital required.

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The Journal points to the lack of changes to "too-big-to-fail" financial institutions after the global financial crisis of 2008, as the same large banks are likely to be put on the Federal Reserve's list of banks that are considered to be "systemically important" four years later in 2012.

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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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Michael Barr was appointed in July 2022 to the Federal Reserve Board of Governors by president Biden, and made the vice chair of financial supervision. As a legal scholar at the University of Michigan with a number of books published on the plight of black Americans after the financial crisis of 2008, he is familiar with the problems created by banks from a laissez fairre approach to regulation.  Barr helped write the rules for the legislation on supervision of banks after the financial crisis of 2008 that hurt worker and families, and minorities particularly in places like Detroit. He is now responsible for correcting the problems created by the Trump legislation that exempted banks under $250 billion from this regulation. Barr will bring this down to $100 billion, the original 2008 legislation has a threshold of $50 billion for banks to be subject to oversight by the central bank and stress testing. In 2018 Barr said about Trump's legislation to limit regulatory oversight in an op-ed in American Banker- "The rules (after 2008) were not meant to apply only to the largest handful of systemically important firms. It is the very antithesis of macro-prudential supervision to focus only on the largest handful of financial firms and to ignore risks elsewhere in the system." ...

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Lower reserve capital ratios of China's mid-size banks, Citic, Mingsheng, China Merchants bank falling below the Basel III requirements of Tier 1 capital ratios- mostly common equity- of at least 8.5% of assets by 2018, 9.5% for systemically important banks. In comparison the higher capital ratios exceeding Basel III requirements of Industrial and Commercial Bank of China, Bank of China and Construction Bank of China, the large state owned banks. The situation is worse when one considers that these midsized banks have tried to grow aggressively taking on credit risks beyond their capacity. China Merchants Bank has off-balance sheet wealth management products, high interest deposits invested in riskier assets of $83.7 billion at the end of Sept 2013, equivalent to 200% of shareholders equity.

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U.S. Fed governor, Daniel Tarullo, said in a recent speech that U.S. financial institutions could be required to meet stronger capital requirements than the Basel international standards. The Fed is considering requiring the riskiest financial institutions to put aside 8.4% to 14% of capital. The Basel standards require institutions to gradually increase the capital cushions to 7% by 2019 from about 2% at this time. Less risky institutions would would have a smaller increase over the Basel standards- about 20% compared to the 100% increase over Basel for the riskiest institutions. Speaking at the Peterson Institute for International Economics, Tarullo said- "The regulatory structure ...should discourage systemically consequential growth or mergers unless the benefits to society are clearly significant." Tarullo said no one wants to see another TARP. Banks would have to build up their capital reserves using common equity and not other forms of less reliable capital such as contingent capital, where banks convert debt instruments into equity in an emergency. Tarullo emphasized the need for the U.S. to move beyond the Basel requirements, known as Basel III, because they are narrowly designed for individual institutions and do not adequately address the systemic risk. When there is a high degree of risk correlation among many actors in fast moving markets additional risks are created which require stronger capital standards. Tarullo said systemically important institutions have "no incentive to carry enough capital to reduce the chances of such systemic losses."...

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UniCredit announced plans to reorganize its Central European and Eastern European banking operations and increase its capital by 7.5 billion euros. Unicredit showed a third quarter 2011 loss of 10.64 billion euros after losses on Greek bonds and goodwill writedowns. The Italian bank said the capital increase will bring its Tier 1 ratio to above 9% as required by Basel III rules. UniCredit is listed as one of the globally systemically important financial institutions or G-SIFI's. Unicredit plans to make the placement of the rights issue to raise capital in 1st quarter 2012. Pricing remains a difficult matter considering that Unicredit shares have dropped precipitiously since 2007 when it had a market capitalization of 100 billion euros. Its market capitalization is now about 15.3 billion euros. Just in the last year the shares have dropped 50% to 0.68 euros a share in Sept. 2011.

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To get the agreement of the 27 countries engaged in the talks to set new banking rules, the new Basel III banking rules are being phased in over a protracted period. Some changes go into effect in 2013, but others will be put into effect by 2019. The focus on the new rules is how much capital, or "common equity" banks will be required to hold as a cushion to absorb losses in a crisis like that of 2008. Large banks will be required to hold 7% of their assets in common equity. By 2015, banks will have to begin building a 2.5% buffer of capital, which must be in place fully by 2019. No action was taken on issues such as requirements for banks to have access to ample liquidity, what systemically important banks should hold in capital, and establishing a counter cyclical capital buffer.

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Carney breaks down Fannie Mae's 2013 earnings figures of $84 billion to show that this is due to unusual factors- such as low interest rates that it gets to access capital from the government, and the reversal of a write-down of deferred-tax assets. $45.4 billon is from the reversal of a writedown of deferred tax assets, $14.6 billion to gains not easily repeated, and about $12 billion because Fannie was able to borrow at 2.06%. (Mortgage securities generated interest income of $22.12 billion. The mortgage guarantee business generated about $12.3 billion which is a result of the 2012 change to the bailout agreement terms) He sees Fannie's core earnings that it could keep generating at about $12 billion. The additional reserve capital requirement that it would face as a systemically important or "too big to fail" financial institution at about $100 billion, making it about 8 years for it reach the reserve capital requirement. The situation at Fannie Mae is not as rosy as the 2013 earnings figures suggest. ...

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Henrik Bohme says in DW.com that the German government may have to step in to rescue Deutsche Bank after the $14 billion legal settlement with the U.S. Justice Department for the bank's practices before the financial crisis of 2008. He points out that there are other legal settlements that are expected, including one for money laundering charges. In all he says there are 7,800 legal challenges the bank faces. The share price has dropped by 90% to 10 euros by September 2016. The market capitalization is low at 14 billion euros, and it was dropped from the Eurostoxx 50 index because of this. It has 1.7 trillion in assets under management, is a systemically important bank, which means the German government has no alternative but to step in and rescue the bank. Issuing new shares with so many legal challenges is not an option as there would be few buyers.

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The governments stress tests most adverse scenario shows that the 19 largest banks could suffer losses of upto $599 billion through the end of 2010 if the economy does wose than expected. It asked these banks to raise a total of $74.6 billion in capital in the financial markets to provide abetter cushion against these losses if they occurred. The tests measured potential losses on mortgages, commerical loans, securities and other assets. This adverse scenario covers 2 year cumulative losses of 9.1% on total loans.

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Peter Eavis says the too big to fail problem remains unsolved, and with the recent consolidation the "big four" accounting for 70% of all assets held by domestically cahrtered banks. There is no effort by the Obama administration to prevent banks from getting too big. And the Fed has accumulated greater powers as a regulator. It is still the same Fed, Eavis reminds one that failed as abank regulator by letting Citigroup's common equity ratios drop to perilous lows. And its overstimulative monetary policies having built up more risk than the system could handle. There will be more regulatory capital at these big banks as a result of actions by Treasury, but risk remains.

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By a vote of 223 to 202 largely along party lines the House passed a bill that brings sweeping changes to the American financial regulatory system. The 1279 page bill creates anew federal agency for consumer protection, establishes a council of regulators to police the financial system for systemic risks, initiates oversight of the derivatives market, and gives the government power to wind down large firms that are in danger of collapse and pose systemic risk. The bill also gives sharehlders advisory say on executive compensation, increases transparency of credit rating agencies, and sets aside billions in governmet money to help unemployed homeowners.

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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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It is not clear whether Citigroup is off the problem list of banks, banks which rate a 4 or a 5 on the scale of 1 to 5. This could change even now after the stress tests. Here's why. Since late 2007, Citigroup has more than $50 billion in write-downs and loan defaults. The recent stress test of the 19 largest banks produced results that showed additional large losses looming over Citigroup, and questions are raised how Citigroup passed. The test found that estimated losses could reach $104.7 billion in loan losses through 2010 under the government's worst case scenario, and face nearly $20 billion in losses on its credit card portfolio. Yet the Fed's conclusion that Citigroup needed to bolster its capital by only $5.5 billion to withstand another economic shock did not reflect these facts. Investors and analysts also saw Citigroup as being in much worse shape than the other banks. THe FDIC did not agree with the Fed's conclusion. Only the Comptroller of the Currency agrees with Citigroup CEO Pandit, that the Citi model is not broken and just needs more time. THe FDIC wanted the rating lowered for the Citibank unit, and sparred with the Comptroller of the Currency over this. The FDIC has 305 banks on the "problem" list, and would like to add Citigroup to this list, so that it could keep a tighter review of what is going on at Citigroup. FDIC is helping finance a $300 billion loss sharing agreement with Citigroup, and has large exposure to Citigroup. FDIC's Bair thinks Citigroup has not moved fast enough to get rid of unwanted assets which might cause problems if the economy deteriorates, and would like to see a change in management. FDIC officials have approached former US Bancorp CEO, Mr Grundhofer, who is highly regarded in the industry, as a possible replacement. One reason being that while most of the problems of Citi stem from consumer loans, Pandit's experience is in investment banking, and he has not moved fast enough to get rid of risky and unwanted assets. He has failed to bring in managers with experience in handling the kinds of problems Citigroup faces in this crisis. With the FDIC's Bair having anticipated the crisis earlier than other regulators, the FDIC is expected to get additional powers in the new regulatory structure. This may result in tighter supervision of Citigroup. It also shows gaps and flaws in the stress tests that let some banks off too lightly, and make them vulnerable to the next episode in this crisis. ...