Banking Brief: Ensuring Consistent Consumer Protection for Data Security: Banks vs. Alternative Payment Providers
Aug 31, 2015
Recently, The Clearing House released a White Paper that analyzes the alternative payment provider (APP) industry, identifies regulatory and enforcement gaps between banks’ payment operations and APPs, and makes recommendations on how to close those gaps in order to ensure that consumers receive a consistent level of protection.
Banking Brief: Overview of Total Loss Absorbing Capacity
Feb 20, 2015
In November 2014, the Financial Stability Board (“FSB”) proposed international standards for total loss absorbing capacity (“TLAC”) that a global systemically important bank (“G-SIB”) would be required to maintain to facilitate its orderly resolution should it fail.
Banking Brief: The Clearing House Working Paper Series on the Value of Large Banks Working Paper No. 4: Quantifying the Impact of Macroprudential Regulation on the Largest U.S. Banks
Nov 19, 2014
In the fourth paper in its Working Paper Series on the Value of Large Banks, The Clearing House builds on and provides evidence supporting the conclusion drawn in its Third Working Paper that the cost of compliance with regulations imposed on large banks must be factored into any assessment of whether large banks enjoy an unfair funding advantage.
Banking Brief: Living Will Requirements for Banking Organizations
Oct 9, 2014
The Dodd-Frank Act requires banking organizations with $50 billion or more of consolidated assets to file resolution plans annually with the Federal Reserve and FDIC. Each resolution plan, also known as a “living will,” must describe the organization’s strategy for rapid and orderly resolution under the U.S. Bankruptcy Code in the event of the organization’s material financial distress or failure.
Banking Brief: Resolution Strategies for Bankruptcy and Orderly Liquidation Authority
Oct 9, 2014
This Banking Brief will discuss different strategies, including single-point-of-entry (“SPOE”) and multiple-point-of-entry (“MPOE”), that can be used under both provisions of the law to facilitate the orderly resolution of financial institutions.
Banking Brief: The Clearing House Working Paper Series on the Value of Large Banks: Working Paper No. 3: Assessing Funding Costs and the Net Impact of Government Policy on Large Banks
Jul 29, 2014
In the third paper in its Working Paper Series on the Value of Large Banks, The Clearing House examines existing academic literature on bank funding costs, noting the significant decline in large bank funding advantages post implementation of Dodd-Frank reforms.
Banking Brief: Federal Reserve Proposed Rule to Implement the Dodd-Frank Act Section 622 Financial Sector Concentration Limits
Jul 18, 2014
The Clearing House Association believes that the Section 622 concentration limit should be implemented and applied in a manner that is transparent, predictable and, most importantly, avoids unnecessary and unintended restrictions on ordinary course business activity that clearly is outside of Section 622’s intended scope.
Banking Brief: OCC Proposed Guidelines Establishing Heightened Standards for Risk Governance
Apr 16, 2014
The Clearing House strongly supports the OCC’s overall Heightened Expectations program for large banks but is concerned that particular aspects of the Proposed Guidelines may require substantial changes to a bank’s risk management practices that would be unnecessary and potentially counterproductive to sound risk management practices.
Banking Brief: Bank Liquidity Regulation - The Proposed U.S. LCR
Feb 19, 2014
The U.S. LCR should deviate from the Basel LCR only when unique circumstances in the U.S. warrant such differences. A U.S. LCR that otherwise differs from international standards in material ways detracts from international goals of clarity and transparency across markets, competitive equality, and minimizing opportunities for regulatory arbitrage.
Banking Brief: Bank Liquidity Regulation - An Overview of the Proposed U.S. LCR
Feb 18, 2014
The LCR is a key component of the post-crisis U.S. liquidity framework and an important step in strengthening the resiliency of banks and the stability of the financial system. The U.S. banking agencies have proposed an LCR in the United States that is more stringent than the LCR agreed to internationally.
Banking Brief: The Clearing House Series on the Value of Large Banks: Working Paper No 2. - Access to Deposit Insurance and Lender-of-Last-Resort Liquidity
Jan 21, 2014
The second working paper examines whether large banks may experience any unfair advantage due to traditional or extraordinary government support to the banking system allowed under U.S. law.
Banking Brief: The Clearing House Series on the Value of Large Banks: Working Paper No. 1 - Identifying the Right Question
Nov 7, 2013
The first working paper in the series identifies the right questions for policymakers to be asking in the debate over whether large banks receive unfair economic benefits.
Banking Brief: Protecting Deposits, Depository Institutions, and the Deposit Insurance Fund - Sections 23A and 23B of the Federal Reserve Act
Mar 7, 2013
Sections 23A and 23B are specifically designed to restrict use of U.S. bank resources to fund affiliate activities that are disallowed inside the bank itself.
Banking Brief: U.S. Banking System - Scaled to Serve
Feb 7, 2013
Large banks are an important part of the U.S. bank ecosystem and generate unique benefits in certain products and markets that smaller banks are unable to create.
Banking Brief: Bank Capital - The Cost of Capital
Nov 2, 2012
Capital requirements should strike a balance between the mutually important goals of enhancing bank stability and fostering economic growth.
Banking Brief: Bank Capital - Insulating Against Losses
Oct 25, 2012
Regulatory capital serves as a buffer that allows banks to absorb losses without endangering depositors and other creditors as well as equity investors.
Banking Brief: Depositor Protections - The FDIC and the DIF
Jul 31, 2012
The deposit insurance framework provides federal insurance for bank customers’ bank deposits and protects taxpayers from liability for the deposits of others.
Banking Brief: The Future of Payments - Emerging Consumer Risks
Jun 13, 2012
The development of a shadow payment system that does not leverage the existing regulated banking infrastructure could pose risks consumers, merchants, and the payments system.
Banking Brief: The Future of Payments - Regulating Mobile Payments
Jun 5, 2012
The applicable regulatory framework and supervisory regime depends in large part on whether the mobile payment services are provided through traditional banking channels.
Banking Brief: The Future of Payments - Mobile Banking & Mobile Payments
May 22, 2012
Three basic operating models have emerged for U.S. mobile payments: a bank driven model, a mobile network operator driven model, and a mobile payment service provider model.