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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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The US Fed under Jerome Powell stress tests of 31 banks for 2024 shows the banks can withstand a rise in unemployment to 10% and 36% drop in house prices. This is relevant now that the new administration of DJT makes another effort to correct the huge trade imbalance with China, Mexico and Canada, which itself is destabilizing in the long run and needs to be addressed. The first term of DJT failed to correct the imbalance with new tariffs kept in place by the Biden administration. This is not just one's imagination, reports suggest China has poured $230 billion of subsidies into its EV industry since 2003 mandate given by premier Jen Biao to dominate that industry. And now has capacity of 20 million car production a year, twice the domestic demand in gasoline cars, wanting to send the surplus production to the US and Europe. This isn't the 1930's type of tariffs, it is simply to get a fair even playing field for trade, where no one side is massively subsidizing and dumping which is one of the principles of WTO free trade that is being broken by China and Mexico. Specifically the anti dumping clause in Article 6 of the 1994 GATT agreement on free world trading mechanism to ensure free and fair trade. ...

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Abrantes-Metz, a professor at the Stern School of Business, New York University, looks at the problems of stress tests of banks 2010-2014.

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The Public-Private Investment Program of the U.S. Treasury Department has not had a good start. With most banks passing the U.S.government's stress tests and raising $50 billion in the markets, PPIP which was intended to to help resolve the situation of all the toxic securites siting on the bank's books, has gone the way of all the prior efforts to solve this problem. Simply postponed this time hoping that the housing market recovers. With the Rogoff-Reinhardt study showing that it takes about 6 years or longer before housing recovers from such aserious crisis as this one, it would be 2012, before one sees an improvement. See the link to the Business Week analysis that shows housing markets in the USA having some aspect of normalcy in 2012. Yet even this analysis is using an optimistic scenario, because it assumes Moodys Economy.com estimates of economic growth for GDP of 4-5% in 2011- 2012. This assumes the consumer debt that has reached over 100% of GDP will be reversed quickly in 2010, and the the factory capacity utilization currently at 68% and expected to drop further in 2009- with more automobile manufacturing capacity remaining to be scrapped -will recover quickly in 2010-2011. This is unrealistic considering the combination of factors at work. Here Devin Leonard talks to PIMCO chief Bill Gross, who with Warren Buffett and PIMCO CEO Mohammed El-Erian, are key proponents of the PPIP program. Both El-Erian and Warren Buffett say they conceived independently of such a program, in which toxic securties are taken off bank's books with government help. As PIMCO is one of the largest traders of mortgage bonds in the country and has years of successful experience in dealing with mortgage bonds, the New York Fed under Geithner turned to PIMCO for advice in 2008. By this time PIMCO was under ownership of Allianz, a German insurer, which bought PIMCO for $3.3 billion in 2000, with $233 million and a $40 million retention bonus going to Bill Gross. Bill Gross describes how the program would function. PIMCO puts up $500 million, and Treasury matches this with $500 million. Analysts estimate that this partnership would be able to attract as much as $ 4 billion in low interest financing from Treasury and the Fed. Gross says that some of these securities pay as much as 14% interest, and even with a 70% default rate, this partnership could make $250 million a year on the $5 billion partnership, or a 5% return, with PIMCO making a 25% return on its original investment. This isn't exactly pro bono work as Buffett had originally suggested to Bill Gross in the midst of the crisis. But a more fundamental concern is that no one really knows exactly how much of toxic securties the banks have on their books, even though estimates have been made. If this is closer to $1 trillion, PIMCO's expertise and efforts will simply fall short of dealing with a problem of this size, and the window dressing of a problem of this magnitude could only hurt efforts for the eventual resolution of this problem. If housing does not recover as is expected till 2012 at the earliest, and the economy continues to deteriorate in unemployment and factory utilization, then the toxic securities on the bank's balance sheets may pose a bigger problem that will require serious action....

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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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Fed Governor Daniel Rarullo emphasizes the need for transparency and release to the public of stress test information. The goal he says is to release "this kind of standardized comparable information on a regular basis so that it's not a momentous event."

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The European Banking Authority has lost credibility after two rounds of stress tests by the EBA failed to turn up the problems at Spanish banks that required a $125 billion recapitalization by the EU rescue fund. Now EU officials are turning to the European Central Bank as the eurozone's main banking regulator. The U.S. Federal Reserve is performing this role after the 2008 financial crisis, with the FDIC in charge of bank closures and resolution. ECB president Mari Draghi says, letting the ECB perform supervisory tasks, a decision made at the June 28 EU summit talks, is fully in line with the bank's mandate. Separate decisions will be needed for a bank resolution authority like the FDIC. The ECB will then have to hire hundreds of banking experts to make on site visits to eurozone banks and check their loan books and make independent assessments of bad loans, bank risks, and capital requirements. The important thing is an agency which is free of local and political interference to make the correct evaluations....

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Over the weekend June 25-26, 2011, the Basel Committee made the decision to raise bank capital reserve requirements from 7% to 9.5%. Wall Street Journal and analyst estimates show that Bank of America, Citigroup, and J.P. Morgan Chase will have to together raise $150 billon in additional capital. The rule gives the banks time till 2019 to reach the new goal. Banks that get even bigger could face an additional one percentage point increase to 10.5%. As of the end of the 1st quarter of 2011, J.P. Morgan had an estimated 7.3% ratio and would need $35 billion to meet the 9.5% capital reserve requirement. Bank of America would need $68 billion and Citigroup $48 billion to reach the 9.5% target.

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This Wall Street Journal editorial comes out in favor of higher capital reserve requirements similiar to that suggested by Federal Reserve Board governor Daniel Tarullo. The Journal says that if regulators are serious in the U.S. about controlling systemic risk, then the 14% rule or a 15% rule for assets held in reserve by banks should be adopted. Daniel Tarullo had suggested a 14% capital reserve requirement. These requirements would be phased in gradually over several years. Basel III requirements require only a 7% requirement and is phased in over many years. Capital standards are likely to be gamed. For this reason the requirement for only Tier 1 capital to be eligible is essential. What about the Basel III standards and the European banks? Would this put them in a better position to earn higher returns. This should be a problem left for European taxpayers to tackle says the Journal. As long as U.S. taxpayers are supporting U.S. banks with an implicit subsidy to take on larger amounts of risk -because they will be saved in a crisis with taxpayer dollars- the Journal says it makes sense to require 10-14% in capital reserves. It cites the Japanese banks which were highly overleveraged with lower capital reserves compared to American banks, and fared poorly. The Dodd-Frank bill imposes a complicated set of regulatory requirements with regulators required to write new sets of rules. The editorial concludes that it is far better to tackle the problems in the banking system with a sufficiently high requirement for capital reserves to manage risks than to have the detailed rule making on every subject that Dodd-Frank suggests....

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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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Irwin says about the revised Basel III rules in Jan. 2013- one hopes that Mervyn King of the Bank of England and Basel regulators are doing the right thing, striking the right balance between pushing for higher capital requirements and adjusting this to take into account the stalling economies of Europe and the U.S. Banks were given till 2019 to meet capital requirements. More assets are now eligible to meet capital requirements (including lower rated corporate bonds) under revised Basel III rules. The large legal settlements and speculative losses of large banks in Europe and the U.S. in 2012 put more pressure on banks with the risk of reduced lending.

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An internal IMF document that estimates Europe's banks are short of capital by $273 billion. IMF managing director, Christine Lagarde, tries to downplay the report by saying this is not from a stress test that the IMF conducts. In August, Lagarde, called for an "urgent recapitalization" of European banks. As France's finance minister, Lagarde, steadfastly insisted French banks were well capitalized. France worked hard to prevent requirements for significant capital reserves under the Basel III rules. The higher capital requirements were supported by the U.S.. Simon Johnson said in his blog, that as long as European banks had inadequate capital to act as a buffer against losses, European countries had no safe route for restructuring their debts.

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Moody's Ratings company downgraded banks in the U.S. and Europe on June 21, 2012. Morgan Stanley, J.P. Morgan Chase, Goldman Sachs, Citigroup were downgraded two notches. Morgan Stanley managed to stave off a three notch downgrade. Credit Suisse was downgraded three notches. Bank of America was down one notch, and Wells Fargo which has only a small trading operation was not reviewed. This is the first time since 2007 that Moody's has conducted a sweeping downgrade of banks. About 100 banks were reviewed by Moody's. Banks being downgraded have large trading operations or investment banking business that is subject to higher risks. Greg Bauer, a managing director of global banking at Moody's said in his statement: All of the banks affected by today's actions have significant exposure to the volatility and risk of outsized losses inherent to capital-markets activities." For Moody's the main issue was that the capital bases of banks are maintained, considering that government support is less likely than before, according to Mr. Wassenberg, Moody's managing director for European banks. The impact on banks will be fewer opportunities for trading revenues for some banks, and will raise borrowing costs for banks. Moody's also cut the ratings of large European banks with significant trading operations. This includes Deutsche Bank, Barclays, HSBC, RBS, BNP Paribas, Credit Agricole, Societe Generale, UBS, and Royal Bank of Canada....

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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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Larsen says the EFSF should get the funding it needs to recapitalize troubled European banks, as the first step to solving the eurozone financial crisis. Banks in Spain and Italy that failed stress tests would get funds to build up their capital. Creditor haircuts should be part of the effort to reduce the debt burden of troubled eurozone countries.

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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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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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The Wall Street Journal's reporting in Sept, 2011, on France's bank BNP Paribas. Contributor Nicolas Lecaussin quoted a BNP Paribas executive saying the bank no longer had access to dollar funding. There is a loss of dollar funding to French banks from U.S. money market funds as the funds reduce exposure and shorten maturities. Analysts point to the French banks having one of the lowest ratios of liquid assets to short term funding needs in Europe. This reporting was questioned by BNP Paribas and French government officials. This happened as central banks including the U.S. Fed intervened in markets in September 2011, to ensure full availability of dollar funding to French banks.