IT HAS taken almost two years, but the debate over the restructuring of American finance has at last reached the issue at the heart of the industry's reregulation: systemic risk. The idea is simple, the execution controversial. Policymakers want to help prevent the ailments of a single institution from infecting the system as a whole by limiting the exposures that firms have to any one counterparty.
The implementation, typically of the mind-numbing Dodd-Frank act, is horribly complex. The core provision on “single counter-party exposure limits” comprises only 81 words among the hundreds of thousands in the act. The final rules were supposed to be in place by January 22nd, but the Federal Reserve issued its initial proposal just weeks before, on January 5th, and the comment period, prompting a deluge of letters, ended only on April 30th. Some of the comments were incoherent rants.
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The ones from trade groups and financial firms are far from objective. But the depth and the extent of the criticisms will require a detailed response. The law calls for institutions to limit their exposure to any single institution to no more than 25% of their capital, but the Fed has gone beyond this (as permitted in the act). It has proposed that large, important institutions should have no more than 10% exposure to a counterparty. It also wants lenders to provide it with ongoing credit-exposure reports, configured to a mandated methodology. The gentlest line of opposition is simply that the Fed's net is cast too wide. M&T Bank, a large regional institution based in Buffalo, New York, says its business model of lending to individuals and small businesses presents no systemic risk at all, and yet it may still fall within the Fed's remit because of its size.
Others rail at the costs of compliance. SunTrust, another regional bank, wrote that the proposed possible reporting requirement “represents an enormous and, SunTrust believes, impossible burden to meet.” Others still object to the way the creditworthiness of the counterparty will be measured. “The proposed calculation methodology (for risk) will require costly system enhancements but will not accurately measure credit risk,” wrote Wells Fargo. Goldman Sachs has even tried to quantify the damage. New rules would push financing costs up, reduce GDP growth in America by 15-40 basis points over a year, and raise unemployment by 10-20 basis points, “eliminating 150,000 to 300,000 jobs”.
JPMorgan Chase added to the chorus, arguing that the rule made it harder to hedge risks and writing that the proposal “destabilises markets in the short term and makes them less efficient and resilient in the long term.” The letters from the banks are not entirely unsympathetic to the Fed's efforts. JPMorgan Chase, in particular, tries to guess at the Fed's thinking and provide an alternative road map. Download Adzan Merdu Trans Tv. There is little political patience nowadays for the idea that market discipline allows capital and business to flow to firms that are perceived to be sound, and away from those that are not. The demand instead is for a system that keeps disasters at bay through wise rules and prudent supervision. But the torrent of criticism still raises an awkward question: why should anyone believe regulators are wiser than markets?
Technical Editing Discussion and Application Worksheets Discussion and Application Worksheets Here you can find worksheets for the end-of-chapter activities. They are available for your download in several forms: • By chapter, in two versions (download chapters one-by-one, as you need them, or have students get them as needed) • online version, for completion at a computer workstation • print version, for completion on paper • By chapter, in compressed zip files (download all the chapter activities as separate files in one zip file) • end-of-chapter materials for hard-copy editing The workbook contains activities from Chapters 3, 4, 9, 10, 11, 12, 13, 15, and 16 that students may complete on paper. You could print the set for a coursepack. The workbook omits discussion activities. You can download the workbook. Chapter Title Online Print 1 Editing: The Big Picture 2 Readers, Users, Browsers, Problem Solvers.