Key Issues

Systemic Risk Council Letter to SEC About Money Market Fund Reform Proposal

Systemic Risk Council September 16, 2013 Dear Commission: The Systemic Risk Council is writing to recommend that the Commission strengthen its proposed money market fund reforms and put in place a final rule that will fully address the destabilizing risks created by the stable NAV accounting fiction and so-called “penny rounding”. As we have noted […]

Money Fund Lehman Moment Lurks as New Protections Stall

Publication: Bloomberg Author: Dave Michaels and Christopher Condon 9/05/2013 —A year ago, when opposition from the asset-management industry killed her plan to make money-market mutual funds safer, U.S. Securities and Exchange Commission Chairman Mary Schapiro looked to Timothy Geithner, then the Treasury Secretary, to tackle “one of the pieces of unfinished business from the financial crisis.” It […]

Systemic Risk Council Letter to Federal Reserve About Long-Term Debt

Systemic Risk Council June 7, 2013 Dear Chairman Bernanke: The Systemic Risk Council has consistently supported stronger and higher quality capital requirements for our largest banking organizations. We also support the implementation of Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that gives the Federal Deposit Insurance Corporation (FDIC) […]

Senators call for higher bank capital in letter to regulators

Publication: Reuters Author: Emily Stephenson 4/09/2013 —A bipartisan group of senators on Tuesday urged bank regulators to finish new capital rules, forcing banks to meet higher capital ratios and rely less on complicated calculations of the riskiness of their assets. Debate in Washington has heated up over whether the 2010 Dodd-Frank law and other measures did enough […]

Money Funds, Waiting for the Fog to Lift

Publication: New York Times Author: Diana Henriques 4/06/2013 —This is the kind of market that makes cautious investors long for the comfort of cash. Stocks? They seem a little frothy. Bonds? Ugh — low rates, inflation worries. Real estate? Still a hard sell. For decades, investors have waited out financial fogs like these in the haven of money […]

Systemic Risk Council Letter to Federal Reserve About Supervision of Foreign Banking

Systemic Risk Council April 5, 2013 Dear Chairman Bernanke: The Systemic Risk Council is writing in support of the Federal Reserve’s proposed rule regarding the supervision of foreign banking and nonbank financial operations (FBOs) in the United States.  This proposed rule would implement the enhanced prudential standards and early remediation requirements of the Dodd-Frank Wall […]

Regulators Let Big Banks Look Safer Than They Are

Publication: Wall Street Journal Author: Sheila Bair 4/01/2013 —The recent Senate report on the J.P. Morgan Chase “London Whale” trading debacle revealed emails, telephone conversations and other evidence of how Chase managers manipulated their internal risk models to boost the bank’s regulatory capital ratios. Risk models are common and certainly not illegal. Nevertheless, their use in bolstering […]

Self-funding of regulators would help fiscal mess

Publication: Politico Author: Brooksley Born and William Donaldson 3/10/2013 —Washington has been abuzz with the automatic, across-the-board spending cuts taking effect, known as the sequester. While many have been focused on the impact on education, law enforcement and transportation safety, another important area that deserves attention is the impact on our financial market regulators: the […]

Systemic Risk Council Letter to SEC About Internal Risk Models

Dear Commission: While we commend the Securities and Exchange Commission for raising the minimum capital required for the very largest broker-dealers that use the alternative net capital requirements, we remain concerned that the Commission (and other federal financial regulators) continues to allow large, complex financial institutions to use their own internal risk models to set […]

Systemic Risk Council Letter to Bank Regulators About Delayed and Weakened Global Capital and Liquidity Standards

Systemic Risk Council January 23, 2013 Dear Chairman Bernanke, Chairman Gruenberg and Comptroller Curry: The Systemic Risk Council (SRC) is concerned by the recent decisions to weaken and delay global capital and liquidity standards under the Basel III accords. As you know, risk-absorbing capital, particularly when combined with stable liquidity, plays an essential role in […]