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An analysis of FDIC data shows the leverage ratio did little to distinguish banks that have failed since 2008 from those that remained healthy.
May 8 -
The president of the Kansas City Fed responds to the ABA's James Chessen.
May 9 -
Sen. David Vitter, R-La., revealed significant changes Wednesday morning to his legislation with Sen. Sherrod Brown, D-Ohio, to address concerns over "too big to fail."
April 24
The Brown-Vitter bill has already had an interesting consequence in the few short days since its introduction. Not only has it caused an about-face by the megabanks, who are suddenly embracing Titles I and II of the DoddFrank Act, it also seems to have made them strong proponents of risk-based capital.
James Chessen of the American Bankers Association is the latest analyst to reflect that perspective,
But the problems with both these points of view is that, in their attempt to criticize the leverage ratio, they downplay all the problems with the current risk-based capital system, including how the big banks recently gamed that system simply by stocking up on the assets with low risk weights and, in some cases, moving higher risk-weighted assets off their balance sheet. As Federal Deposit Insurance Corp. Vice Chairman Thomas Hoenig
The large bank proponents also ignore the fact that the Brown-Vitter equity capital standard would go further than the leverage ratio and would be superior to that ratio since it would capture off-balance-sheet items. Furthermore, it would also include derivatives exposures without, in most cases, the benefit of netting. No longer could a large bank hide the true amount of its exposures to short-term debt by using structured investment vehicles, or confuse investors and the public about the amount of its derivative exposures. If the Brown-Vitter bill were enacted, large bank balance sheets would become more transparent and would more accurately reflect the relative financial strength of the institution. To give an example, Morgan Stanley's risk-based Tier 1 capital ratio at the end of the fourth quarter of 2012
No one is suggesting that banking regulators completely reject risk-based capital ratios. Indeed, risk-based capital ratios could serve as a backstop or check for any type of tangible equity leverage ratio. The Brown-Vitter bill specifically authorizes regulators to use them with respect to banks with over $20 billion in assets. However, the Brown-Vitter equity capital standard would not only provide incentives for the largest banks to downsize, it would also replace the confusing and misleading risk-based capital system with a straightforward way to determine the true health of a banking institution.
Christopher Cole is senior vice president and senior regulatory counsel for the Independent Community Bankers of America.