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The GAO appears to confirm what The Clearing House Association and others who have carefully considered this issue already knew -- cost of funding differences among banks of different sizes have significantly declined or been reversed, suggesting that TBTF perceptions have substantially diminished.
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.
The Clearing House Association, joined by the American Bankers Association and Financial Services Roundtable, submitted a comment letter to the Federal Reserve on its proposed rule to implement Section 622 of the Dodd-Frank Act. The letter stresses the practical importance of ensuring that Section 622 is implemented in a manner that is transparent, predictable and, most importantly, avoids unnecessary and unintended restrictions on ordinary course business activity that falls outside of Section 622’s intended scope.
The Clearing House Association (TCH) submitted a comment letter to the U.S. banking agencies expressing general support for the agencies’ proposed revisions to the supplementary leverage ratio and providing suggestions for additional improvements.
An independent research report commissioned by The Clearing House Association and released today measures too-big-to-fail (TBTF) effects from 2009-2013 based on differences in market spreads for senior unsecured bonds issued by U.S. bank holding companies. Authored by John Lester and Aditi Kumar of Oliver Wyman, the report finds no evidence of TBTF effects on large bank funding costs.
The Clearing House Association (TCH) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) today in response to the agency’s January 2014 proposed guidelines that would establish minimum standards for risk governance and bank boards of directors for banks with $50 billion or more in total consolidated assets. In its letter, TCH reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.
An independent research report, commissioned by The Clearing House Association, and authored by a leading global management consulting firm Oliver Wyman, found that money market deposit rate advantages for the largest banks were just four basis points at the end of 2012. Further, the study found evidence that this small difference may not be attributable to TBTF perceptions – that is, potential perceptions among market participants that the government would intervene to prevent the failure of a large financial institution.
The Clearing House applauds the Administration’s call to the nation’s community of key innovators to enhance and support the USPTO. In response, The Clearing House pledges to develop educational materials and host education sessions with USPTO patent examiners with a focus on the most critical components of our financial infrastructure.
The Clearing House is proud to be a part of a new partnership between the financial services trade associations and retailer groups to address cyber-criminal attacks on the payments system.
TCH led a joint industry effort to comment on the U.S. LCR proposal, authoring a comprehensive comment letter that strongly supports U.S. implementation of the LCR as an important step in strengthening the resiliency of banks and the stability of the financial system.