Blog: TCH Bank Conditions Index shows the degree of resiliency of the banking sector remained close to historically high levels
Sep 18, 2017
The Clearing House Bank Conditions Index (TCHBCI) decreased slightly in the second quarter of 2017 after having registered its highest level of resiliency in the first quarter of this year.
Blog: If a bank objects to its CAMELS ratings, can it seek judicial review?
Sep 13, 2017
According to the FDIC, the answer is no -- despite the fact that the unavailability of review would seem to be contrary to fundamental precepts of administrative law, as codified in the Administrative Procedure Act (APA) – not to mention notions of fairness and due process.
Blog: Worth Another Read: Goldman Sachs’ Steve Strongin Assesses Post Crisis Financial Reform
Sep 8, 2017
TCH Association President recalls Steve Strongin’s presentation at the 2016 TCH-SIFMA Prudential Regulation Conference.
Blog: Send the NSFR back to Basel
Aug 28, 2017
One of the recommendations in the report the Treasury Department released in June was for the U.S. banking agencies to delay implementation of the net stable funding ratio (NSFR) requirement until it could be reviewed and recalibrated, noting that it would introduce potentially unnecessary liquidity requirements and duplicate other requirements. For a whole host of reasons, we encourage the U.S. banking agencies to send the regulation back to Basel for a fundamental reconsideration.
Blog: The "Record Profit" Canard
Aug 23, 2017
Recently, one hears opponents of regulatory reform arguing that there is no need for regulatory reform because banks are making "record profits." The argument is quite puzzling, but we’ve heard it enough to think it deserved a quick response.