Tag: USA

The Impact of the Dodd-Frank Act

From The St.Louis Fed Blog.

One of the outcomes of the 2008 financial crisis was recognizing the cascading effects that the severe financial stress or failure of a large institution can have on financial markets and the economy at large. A primary goal, therefore, of post-crisis financial reform was heightened supervision and regulation of those institutions whose sheer size or risk-taking posed the greatest threat to financial stability.

These reforms were primarily codified in the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Under the Dodd-Frank Act, US financial institutions with $50 billion or more in assets are subject to enhanced prudential regulatory standards. These standards are designed to accomplish two primary objectives:

  • Improve an institution’s resiliency to both decrease its probability of failure and increase its ability to carry out the core functions of banking
  • Reduce the effects of a bank’s failure or material weakness on the financial system and the economy at large

To meet these objectives, the Federal Reserve employs a number of tools to monitor institutions and reduce the risks they pose to the U.S. financial system.

Capital Stress Testing

The Fed annually assesses all bank holding companies with more than $50 billion in assets to ensure they have sufficient capital to weather economic and financial stress. This exercise, called the Comprehensive Capital Analysis and Review (CCAR), also allows the Fed to look at the impact of various financial scenarios across firms.

If the Fed determines that an institution cannot maintain minimum regulatory capital ratios under two sets of adverse economic scenarios, the institution may not make any capital distributions such as dividend payments and stock repurchases without permission.

A complementary exercise to CCAR is Dodd-Frank Act stress testing (DFAST). The DFAST exercise is conducted by the financial firm and reviewed by the Fed. It aids the Fed in assessing whether institutions have sufficient capital to absorb losses and support operations during adverse economic scenarios. This forecasting exercise applies to banks and bank holding companies with more than $10 billion in consolidated assets.

Liquidity Stress Testing

The financial crisis made it clear that a firm’s liquidity, or ability to convert assets to cash, is important during periods of financial stress. In response, the Fed launched the Comprehensive Liquidity Assessment and Review (CLAR) in 2012 for the country’s largest financial firms.

CLAR allows the Fed to assess the adequacy of the liquidity positions of the firms relative to their unique risks and to test the reliability of these firms’ approaches to managing liquidity risk.

Resolution and Recovery Plans

Banking organizations with total consolidated assets of $50 billion or more are also required to submit resolution plans to the Fed and the Federal Deposit Insurance Corp. Each plan must describe the organization’s strategy for rapid and orderly resolution in the event of material financial distress or failure.

Have these tools made a difference? The answer is clearly “yes,” as shown in the figure below.

Capital Ratios

The capital ratios of the country’s largest firms (those with more than $250 billion in assets) have shown solid positive progress. In fact, one important measure of capital strength for this group of institutions, the average Tier 1 risk-based capital ratio, has increased 48.1 percent since 2007.

Some in the industry and in Washington, D.C., are calling for a re-evaluation of the Dodd-Frank Act provisions. While modifications for smaller, non-systemic firms would be welcomed by many, the damage from the financial crisis makes it sensible to continue strong expectations for the largest firms.

Repealing Dodd-Frank: What’s the Likely Fallout?

From Knoweldeg@Wharton.

In a move that generated widespread concern last week, President Donald Trump signed an executive order that aims to repeal the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act. Even Dodd-Frank’s strongest supporters acknowledge that parts of the law could be tweaked to remove excessive financial regulation and made simpler. But they worry that in the process of such reforms, much of what is good in Dodd-Frank will be undone.

The Trump administration’s vehicle to repeal Dodd-Frank is the Financial Choice Act, a failed 2016 bill being reintroduced by Republican Congressman Jeb Hensarling, who is chairman of the House Financial Services Committee. The bill gets its new traction from Trump’s presidential order, signed on February 3, which lists seven so-called “Core Principles” to regulate the U.S. financial system. The order directs the treasury secretary to consult with the heads of the member agencies of the Financial Stability Oversight Council and report within 120 days if existing laws and regulations support those principles.

According to Michael Barr, University of Michigan Law School professor and a key architect of the Dodd-Frank Act, the Choice Act would imperil the interests of the middle class, retirees and investors. “It just seems like a recipe for a huge disaster,” he said. “[Dodd-Frank] put in place real guardrails against re-creating the kind of financial crisis we saw in 2008. It is inexcusable that the administration has targeted the most vulnerable people in our society to be the ones that bear the brunt of their ideological push.”

Wharton professor of legal studies and business ethics Peter Conti-Brown does not expect an easy passage for the Choice Act. He said he is intrigued by the game plan of the administration in its pushback against Dodd-Frank. Describing the Republicans in Congress as “a coalition that includes rightwing Rust Belt populism that is hostile to international trade, for example,” he noted that they “should similarly be profoundly skeptical” of most provisions of the Choice Act. “It would be very hard to sell to those who voted for radical change … and call for an end to protections for average workers, consumers and investors.”

Barr and Conti-Brown discussed the likely legislative path and consequences of unwinding Dodd-Frank on the Knowledge@Wharton show on Wharton Business Radio on SiriusXM channel 111.

US Mortgage Rates On The Up Again

From Mortgage Daily News.

US Mortgage rates moved higher for the 4th straight day today, following Fed Chair Janet Yellen’s congressional testimony.  It wasn’t that Yellen’s speech or Q&A contained any major surprises.  Rather, bond markets (which dictate rates) were simply looking for some indication of “sooner vs later” with respect to the Fed’s next rate hike.  Her comments were generally more in line with “sooner.”  Bond markets responded by quickly trading rates to higher levels, resulting in multiple “negative reprices” for mortgage lenders this morning.

Bonds calmed down in the afternoon, and ended up clawing back roughly half of the morning’s losses by the end of the day.  Many lenders were consequently able to offer “positive reprices”–bringing rate sheets part of the way back to yesterday’s levels.

Despite the afternoon improvements, essentially every lender is in worse shape today vs yesterday.  The average top tier conventional 30yr fixed quote is back up to 4.25%–a move that was already in-progress yesterday.  Today’s rates are the highest since February 3rd.

Deregulation on Horizon for US Financial Institutions

Deregulation is likely to be a significant theme for US financial institutions (FIs), with the Trump administration and Republican leaders in Congress indicating broad support to limit and simplify the regulatory regime, says Fitch Ratings. Fitch does not believe that the Dodd-Frank Act will be repealed in full; however, select provisions are potentially subject to substantial revision.

Determining the aggregate ratings or credit impact of a major deregulation initiative without specific policy proposals would be premature. It remains unclear which, if any, deregulation policies will be the focus of the administration and ultimately be passed.

However, Fitch believes that the Financial Choice Act (FCA), proposed by House Financial Service Committee Chairman Representative Jeb Hensarling, R-TX, in 2016, may serve as a blueprint for some of the changes ahead. The FCA is broad in scope and includes proposals to change FI activities, modify and potentially reduce financial regulators’ authority, limit regulatory burdens for certain FIs, add greater congressional oversight of regulators and propose reform to market infrastructure.

In determining the potential impact of such regulatory changes, both the direct impact of the change and the responses from individual banks will be key in determining the ultimate issuer credit effect. The extent to which the reforms could lead to a reduction or changes to the quality of capital and/or liquidity, or weaken governance, will be particularly important for ratings over time.

Several parts of the FCA target regulatory relief for strongly capitalized and well-managed banks, such as a proposal to exempt banks from many regulations should they exceed a 10% or higher financial leverage ratio. Smaller banks meeting the requirements would most likely benefit. For large global systemically important banks, Fitch estimates that the $400 billion in incremental Tier I capital necessary to achieve the minimum leverage ratio – the calculation would likely be similar to the Basel III supplementary leverage ratio – would outweigh any potential cost benefits of regulatory relief.

Limiting regulatory authority is another key plank of the FCA. The most significant change for the markets would be the proposed restructuring of the Federal Reserve, including how it sets interest rates, as well as its authority as a central bank. The proposed rule also calls for restructuring the Consumer Financial Protection Bureau (CFPB), adding congressional review of financial agency rulemaking and subjecting agencies’ rulemaking to judicial review, among others.

Overall, Fitch believes that such reviews could hamper agencies’ effectiveness and significantly impede their ability to issue new rules, which could have an overall negative effect on the system. Fitch believes that restructuring the CFPB with a Consumer Financial Opportunity Commission, as stipulated in the FCA, would lower compliance costs and reduce potential fines for consumer finance, but lead to weakening control frameworks.

Why Does Economic Growth Keep Slowing Down?

From The St. Louis Fed Blog.

The U.S. economy expanded by 1.6 percent in 2016, as measured by real gross domestic product (GDP). Real GDP has averaged 2.1 percent growth per year since the end of the last recession, which is significantly smaller than the average over the postwar period (about 3 percent per year).

These lower growth rates could in part be explained by a slowdown in productivity growth and a decline in factor utilization.1 However, demographic factors and attitudes toward the labor market may also have played significant roles.

The figure below shows a measure of long-run trends in economic activity. It displays the average annual growth rate over the preceding 40 quarters (10 years) for the period 1955 through 2016. (Hence, the first observation in the graph is the first quarter of 1965, and the last is the fourth quarter of 2016.)

Real GDP

Long-run growth rates were high until the mid-1970s. Then, they quickly declined and leveled off at around 3 percent per year for the following three decades.

In the second half of the 2000s, around the last recession, growth contracted again sharply and has been declining ever since. The 10-year average growth rate as of the fourth quarter of 2016 was only 1.3 percent per year.

Total output grows because the economy is more productive and capital is accumulated, but also because the population increases over time. The next figure compares long-run growth rates of real GDP and real GDP per capita. Both series display similar behavior.

RealGDPperCapita

Although population growth has been slowing, the effect is not big enough to change the qualitative results described above.

The third figure adds long-run growth rates of real GDP divided by the labor force.2 Dividing by the labor force instead of the total population accounts for the effects of changing demographics and labor market attachment.

RealGDPLaborForce

From the 1970s until the 2000s, long-run growth rates of real GDP divided by the labor force remained well below those of real GDP per capita. There are two main factors that explain this:

  • Lower fertility and longer lifespans steadily increased the potential labor force relative to the total population.
  • Labor force participation increased significantly from the 1960s until 2000, largely driven by increased female labor force participation.

When accounting for both of these factors, economic activity from 1975 to 1985 looks more depressed than in the two decades that followed. This seems consistent with the negative effects that the 1970s oil shocks and efforts to reduce inflation in the early 1980s3 had on the economy.

The trend in labor force participation reversed in 2000, as participation rates have been steadily decreasing since then. This explains why real GDP divided by labor force growth rates are now higher than real GDP per capita growth rates.

Having accounted for the long-term effects of changes in demographics and labor market attitudes, we can now look at the effects of productivity growth and factor utilization. The final figure compares long-run growth rates in real GDP divided by the labor force with long-run growth rates in total factor productivity and long-run averages of capacity utilization (i.e., the actual use of installed capital relative to potential use).4 Note that data for capacity utilization are only available since 1967.

Capacity

The poor long-run performance of 1975-1985 can be attributed to low productivity growth and a decline in capacity utilization. Afterwards, long-run growth rates in output started to pick up, first associated with an increase in capacity utilization and then with increased productivity growth.

The current path of decline in output growth follows from both a slowdown in productivity growth and lower capacity utilization, though the latter factor started earlier and may have leveled off sooner.

Notes and References

1 As argued by St. Louis Fed President James Bullard, we seem to be currently in a low productivity-growth regime. See Bullard, James. “The St. Louis Fed’s New Characterization of the Outlook for the U.S. Economy,” announcement, June 17, 2016.

2 The labor force includes all persons classified as employed or unemployed in the Bureau of Labor Statistics’ Current Population Survey.

3 For more on the monetary policy actions of the early 1980s, see Medley, Bill. “Volcker’s Announcement of Anti-Inflation Measures,” Federal Reserve History, November 22nd, 2013.

4 The series for total factor productivity is taken from the Federal Reserve Bank of San Francisco. Capacity utilization is published by the Federal Reserve’s Board of Governors and covers only the industrial sector of the economy (manufacturing, mining, utilities and selected high-tech industries).

Why President Trump is not (yet) rolling back Dodd-Frank

From Vox.

The pen isn’t mightier than the independent regulatory commission.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (or, more simply, “Dodd-Frank”) was passed in 2010 in response to the 2007-2010 financial crisis. It centralized and strengthened federal regulatory control of financial services industries. It is one of the most controversial and important pieces of legislation in decades.

With Dodd-Frank firmly in his sights, President Trump signed Executive Order (EO) 13772 on February 3, 2017. EO 13772 calls upon the secretary of the Treasury to evaluate financial regulations and identify those that are too burdensome. This order has been described by Trump and many media outlets as “rolling back” Dodd-Frank.

This is too simplistic. While it seems clear that Trump would like to roll back the regulations stemming from Dodd-Frank, the reality is that he can’t do it alone. There are multiple reasons for this, but the most important is the nature of the agency most central to the writing of the Dodd-Frank regulations.

To be sure, Dodd-Frank is a complicated piece of legislation. For example, among many other things, it established the Consumer Financial Protection Bureau. The central player in the act, however, is the Securities and Exchange Commission (SEC), which regulates the securities industry in the United States.

 The SEC, which was established in 1934 in response to the stock market crash of 1929, has already adopted dozens of regulations mandated by Dodd-Frank and is finalizing a handful more.

On a day-to-day basis, the SEC’s regulations are largely beyond the reach of the president, because the SEC is an independent regulatory commission rather than an executive agency. The president nominates members of the five-person commission, subject to Senate confirmation, and former SEC Chair Mary Jo White has resigned, allowing Trump to nominate her successor. Obviously, enforcement and interpretation of the existing regulations are at stake under her successor. However, Trump cannot merely sign an order and cause these regulations to be rolled back. Once appointed, SEC commissioners cannot be removed by the president, and, at least in theory, the regulations required by Dodd-Frank cannot be entirely repealed by the SEC without new legislation (though they can be modified).

As with the Affordable Care Act, Trump cannot undo Dodd-Frank without support from (many) other people and institutions in Washington. Obtaining such support will require some compromise and, more importantly, time. The financial services industries and their various critics will not stand on the sidelines as this plays out over the next few months and years.

 To be sure, Trump and his advisers presumably know this. After all, Section 2 of EO 13772 says (emphasis mine): “The Secretary of the Treasury shall […] report to the President within 120 days of the date of this order (and periodically thereafter). …”

I think President Trump is going to get more than a few “reports” on this, and not just from the secretary of the Treasury.

Make ATMs Great Again

From Zero Hedge.

McDonalds replacing minimum-wage workers with “Big Mac ATMs“; Coffee stores replacing low-paid barristas with robots, and now Bank of America opening branches with no workers at all.

According to Reuters, the latest trend when it comes to retail banking is to do what every other industry is doing, and eliminate paid labor entirely. In that vein, Bank of America, has opened three completely automated branches over the past month, “where customers can use ATMs and have video conferences with employees at other branches.”

Like many U.S. banks in recent years, Bank of America has been reducing its overall branch count to cut costs even as it opens new branches in select markets. New branches are typically smaller, employ more technology, and are aimed at selling mortgages, credit cards and auto loans rather than simple transactions such as cashing checks. The move is similar to a parallel shift away from active, and highly paid, management, to robotic, algo, and other generally passive, and much cheaper, forms of asset management. Only here we are talking about near-minimum wage jobs quietly going extinct.

It was not immediately clear if the robots have learned the sneakier “cross-selling” techniques from Wells Fargo, or how to churn one’s account with excess fees as per JPMorgan.

Bank of America spokeswoman Anne Pace said there is one completely automated branch in Minneapolis and one in Denver, both of which are relatively new markets for the bank’s consumer business. They are about a quarter of the size of a typical branch. The new branches were mentioned briefly Tuesday by Dean Athanasia, co-head of Bank of America’s consumer banking unit, during a question and answer session at an investor conference, but he did not provide details.

In keeping with the unstated zero net new hires policy, Athanasia said Bank of America will open 50 to 60 new branches over the next year, though Pace said the bank will also be closing branches in certain markets, so the 50 to 60 branches do not represent a net increase. Assuming all of the new branches amount to zero new jobs, then they will also represent no increase in employment either.

Bank of America opened 31 new branches in 2016.

And since this trend of anti-retrofitting of existing branchs, those with workers, for new branches without, is just starting, Bank of America – which had 4,579 financial centers at the end of 2016, compared to 4,726 in 2015 and 5,900 at the end of 2010 – is about to make American robots and ATM machines great again. It is not clear just what angry Tweet trump can shoot out to make BofA changes its mind.

Is Local Unemployment Related to Local Housing Prices?

From The St. Louis FED.

The U.S. national labor market has recovered from the effects of the 2007-2009 recession; however despite the national labor market recovery, significant regional variation remains. Recent economic research highlights links between regional labor and housing markets. In their article, “ The Recent Evolution of Local U.S. Labor Markets, ” Authors Maximiliano Dvorkin and Hannah Shell examined the recession and recovery by reviewing the correlation between county-level unemployment rates and changes in housing prices.

National unemployment reached a pre-recession low in December 2007; by October 2009 the unemployment rate in most counties increased between 4 and 20 percentage points. The authors found that areas with higher unemployment rates before the recession experienced larger increases in unemployment during the recession, and those areas with lower unemployment rates before the recession experienced smaller upticks in unemployment during the recession.

The authors theorized that one reason for the disparity in unemployment rate increases could be related to the housing supply. Specifically, the unemployment rates in Arizona, New Mexico, Nevada and Utah remained above their pre-recession levels; these are also areas where housing prices dropped significantly.

When they examined the percent change in county house prices with the change in the county unemployment rate, the results showed a strong negative correlation, meaning that counties with larger decreases in housing prices experienced larger increases in the unemployment rate, perhaps because larger house price declines during downturns are leading to larger declines in local consumption spending that further depress the local economy.

FED Sets Up Parameters For 2017 Dodd-Frank Stress Tests

The Federal Reserve Board on Friday released the scenarios to be used by banks and supervisors for the 2017 Comprehensive Capital Analysis and Review (CCAR) and Dodd-Frank Act stress test exercises and also issued instructions to firms participating in CCAR.

CCAR evaluates the capital planning processes and capital adequacy of the largest U.S.-based bank holding companies, including the firms’ planned capital actions such as dividend payments and share buybacks and issuances. The Dodd-Frank Act stress tests are a forward-looking assessment to help assess whether firms have sufficient capital. Stress tests help make sure that banks will be able to lend to households and businesses even in a serious recession by ensuring that they have adequate capital to absorb losses they may sustain.

This year, 13 of the largest and most complex bank holding companies will be subject to both a quantitative evaluation of their capital adequacy and a qualitative evaluation of their capital planning capabilities. As announced earlier this week by the Board, 21 firms with less complex operations will no longer be subject to the qualitative portion of CCAR, relieving them of significant burden.

Financial institutions are required to use the scenarios in both the stress tests conducted as part of CCAR and those required by the Dodd-Frank Act. The outcomes are measured under three scenarios: severely adverse, adverse, and baseline.

For the 2017 cycle, the severely adverse scenario is characterized by a severe global recession in which the U.S. unemployment rate rises by about 5.25 percentage points to 10 percent, accompanied by a period of heightened stress in corporate loan markets and commercial real estate markets. The adverse scenario features a moderate recession in the United States, as well as weakening economic activity across all countries included in the scenario. The adverse and severely adverse scenarios describe hypothetical sets of events designed to assess the strength of banking organizations and their resilience. They are not forecasts. The baseline scenario is in line with average projections from surveys of economic forecasters. It does not represent the forecast of the Federal Reserve.

Each scenario includes 28 variables–such as gross domestic product, unemployment rate, stock market prices, and interest rates–encompassing domestic and international economic activity. Along with the variables, the Board is publishing a narrative that describes the general economic conditions in the scenarios and changes in the scenarios from the previous year.

As in prior years, six bank holding companies with large trading operations will be required to factor in a global market shock as part of their scenarios. Additionally, eight bank holding companies with substantial trading or processing operations will be required to incorporate a counterparty default scenario.

The Board is also releasing several letters with additional information on its stress testing program. One letter describes the reduced data required from the 21 firms that have been removed from the qualitative portion of CCAR; a second details enhancements and changes made to certain supervisory loss models; and a third provides an overview of the stress testing program and its expectations for foreign firms that are beginning the stress testing program this year, but are not yet required to publicly report their results under the Board’s rules.

Bank holding companies participating in CCAR are required to submit their capital plans and stress testing results to the Federal Reserve on or before April 5, 2017. The Federal Reserve will announce the results of its supervisory stress tests by June 30, 2017, with the exact date to be announced later.

Firm Removed from qualitative portion of CCAR New to CCAR 2017 Subject to global market shock Subject to counterparty default
Ally Financial Inc. X
American Express Company X
BancWest Corporation X
Bank of America Corporation X X
The Bank of New York Mellon Corporation X
BB Corporation X
BBVA Compass Bancshares, Inc. X
BMO Financial Corp. X
Capital One Financial Corporation
CIT Group Inc. X X
Citigroup Inc. X X
Citizens Financial Group, Inc. X
Comerica Incorporated X
Deutsche Bank Trust Corporation X
Discover Financial Services X
Fifth Third Bancorp X
The Goldman Sachs Group, Inc. X X
HSBC North America Holdings Inc.
Huntington Bancshares Incorporated X
JPMorgan Chase & Co. X X
KeyCorp X
M Bank Corporation X
Morgan Stanley X X
MUFG Americas Holdings Corporation X
Northern Trust Corporation X
The PNC Financial Services Group, Inc.
Regions Financial Corporation X
Santander Holdings USA, Inc. X
State Street Corporation X
SunTrust Banks, Inc. X
TD Group US Holdings LLC
U.S. Bancorp
Wells Fargo & Company X X
Zions Bancorporation X

Leveraging Will Survive Corporate Tax Reform – Moody’s

Moody’s says analysts from a major bank believe that reducing the top corporate income tax rate from 35% to 20% will slow the average annual increase of US industrial company debt over the next 10 years from nearly 5% without a tax cut to roughly 2% with the tax cut.

However, what happened after the slashing of the top corporate income tax rate from 1986’s 46% to 1987’s 40% and, then, to 1988’s 34% questions whether prospective tax cuts will more than halve the growth of corporate debt over the next 10 years.

Nevertheless, business borrowing is likely to be noticeably lower if business interest expense is no longer tax deductible. Such tax-reform induced reductions in business borrowing will be most prominent among very low grade credits and during episodes of diminished liquidity, extraordinarily wide yield spreads for medium- and low-grade corporates, and exceptionally high benchmark borrowing costs.

The top corporate income tax rate probably will be cut from i 35% to either the 20% proposed by House Republicans or to the 15% offered by Trump’s team. Assuming, for now, the continued tax deductibility of corporate interest expense, a lower corporate income tax rate increases the after-tax cost of corporate debt. However, a reduction by the corporate income tax rate may add enough to after-tax income to more than offset the burden of a higher after-tax cost of debt. In addition, today’s relatively low corporate borrowing costs will mitigate the increase in the after-tax cost of debt stemming from a lowering of the corporate income tax rate.

Corporate debt sped past GDP and revenues despite tax cuts of 1987-1988
Thus, a lowering of the top corporate income tax rate probably will not have much of a discernible effect on corporate borrowing. Despite the lowering of the corporate income tax rate from 1986’s 46% to 34% by 1988, the ratio of debt to the market value of net worth for US non-financial corporations rose from 1986’s 38.6% to a mid-1994 high of 51.1%. Moreover, from year-end 1986 through year-end 1989, non-financial corporate debt advanced by 9.6% annually, on average, which was much faster than the accompanying average annual growth rates of 7.2% for nominal GDP and 7.0% for the gross value added of non-financial corporations.

The supposed de-leveraging effect of corporate income tax cuts was further challenged by how debt outran both the economy and business sales despite still elevated corporate borrowing costs. For example, Moody’s long-term Baa industrial company bond yield barely fell from 1986’s 10.73% average to the still costly 10.55% of 1987-1989, while a composite speculative-grade bond yield actually rose from 1986’s 12.44% to the 13.05% of 1987-1989.

It should be noted that the increase in the after-tax cost of debt was greater following 1987’s corporate income tax cut because of the much higher corporate bond yields of that time and yet corporate debt still grew rapidly. In stark contrast, recent yields of 4.74% for the long-term Baa-grade industrials and 5.96% for speculative-grade bonds are substantially lower, which, in turn, lessens the degree to which corporate income tax cuts discourage balance-sheet leveraging.