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Ted Kaufman

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Too Big to Fail and the Volcker Rule

Posted: 03/ 5/2012 9:21 am

When I was in the Senate back in 2009-2010 there were disagreements about virtually every element of Wall Street reform. But everyone, Republican or Democrat, agreed that the American taxpayer should never again have to bail out a bank because it was "too big to fail"-- so large and so intricately a part of our financial system that if it wasn't bailed out it could cause another economic meltdown.

Many of us, led by Senators John McCain and Maria Cantwell, believed that the only foolproof way to do away with TBTF banks was to reinstate the Glass Steagall Act of 1933. For the next 66 years, Glass Steagall separated commercial banks, whose deposits were federally insured, from investment banks, which were free to engage in riskier investment strategies. But Glass Steagall was repealed in 1999. Wall Street banks took greater and greater risks, including credit default swaps and mortgage-backed securities. The result of this seems, in retrospect, to have been inevitable.

Our attempt to reinstate Glass Steagall went nowhere. Instead, what I have always thought of as a fig leaf -- the so-called Volcker Rule -- was attached to the Dodd Frank Wall Street Reform Act, which became law in July 2010. The can was kicked down the road; the Act left it up to regulators to write rules that would prevent banks from making the risky investments that led to the bailouts.

What we are seeing happen right now proves that universal agreement on a goal -- no possibility of a future bank bailout -- doesn't necessarily mean that goal will be achieved. Our major banks are still too big to fail. In fact they are bigger than they were back in 2008 before the wave of forced mergers where the big banks gobbled up Wachovia, Merrill Lynch, Washington Mutual and more.

You would be hard pressed to find an independent economist or business writer who doesn't agree with that TBTF assessment. "Independent" is the key word here. There are any number of economic voices associated with the Wall Street banks' relentless public relations campaign to protect them from "the cost of federal regulation." They want us to forget what the lack of financial regulation cost the U.S. economy back in 2008 -- in terms of jobs, lost homes and a ballooning deficit.

The lobbying campaign over the past few months to influence the regulators in charge of implementing the Volcker rule has been something to behold. A study conducted by Duke Law School Professor Kimberly Krawiec shows that between July 26, 2010 and October 11, 2011, 93.2 percent of those who visited with Securities Exchange Commissioners or staff about the Volcker amendment were financial institutions, law firms, accounting firms, trade associations, lobbyists or policy advisors who represented financial institutions. The remaining 6.8 percent represented public interest or union groups.

October 2011 was the month the regulators released a 300+ page draft proposal about implementing the Volcker rule. It included 1,300 questions, asking for public input. Has there been input since then? You bet. Press reports make it clear that the imbalance in lobbying cited by Professor Krawiec has gotten worse. In the past three months, Goldman Sachs alone has met with the regulators six times. When the February 13 deadline for comments was reached, an avalanche of mail from the Wall Street banks and their supporters poured into the SEC.

Given the one-sided input the regulators have received, it is difficult to imagine implementing a Volcker rule with real teeth. My initial reaction, that it was a fig leaf, is about to be proven true. In just one year's time, a rule that was supposed to confront the very real problem of banks making high-risk bets with government-insured deposits will have evolved into a watered-down version that will do little to solve our continuing TBTF problem.

Here's just one reminder about what that problem would entail. More than three years after it declared, we still have not resolved the relatively simple Lehman Brothers bankruptcy, mainly because of the lack of resolution authority across international lines. Can you imagine how long it would take to resolve a Citibank bankruptcy -- involving over $2 trillion in assets and hundreds of international relationships? The impact on the world's financial markets would be catastrophic.

Albert Einstein defined insanity as doing the same thing over and over again and expecting different results. You don't have to be an Einstein to recognize this TBTF insanity for what it is.

 
 
 
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11:11 PM on 03/11/2012
It's frightening that we are just as vulnerable to a crash now as we were the morning of Monday, September 15, 2008. I agree with the author that bringing back the "wall of separation" of Glass-Steagall is a very reasonable solution. It makes no sense to "commingle" a federally-insured bank with an aggressive investment house. This doesn't mean that people on Wall Street are bad people. It means that if there's no sensible framework of regulation for them, things will go out of control.

Imagine if there were no "wall of separation" between a federally-insured veteran's hospital, and a drug company. You'd see some pretty strange things going on, lots of money invested in bizarre drug research. Imagine there was no wall of separation between a fire department and weapons manufacturers. Again, this doesn't mean that the actors in private industry are bad. It's just crazy for the government to provide federal insurance to private companies, except for very specific public purposes, like banking.

That's exactly the situation we were in during 2008, and it's exactly the situation we're in right now.
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Gerald Serlin
Retired lawyer. Perserverantia Vincit
10:49 PM on 03/11/2012
Too big to fail is just another componenet of "crony capitalism". The government will play favorites, instead of allowing those who should fail, to fail. There should be no such thing as TBTF. Darwinism should be the rule. Whenever the govt. gets involved, things just get worse; or, as in the case of the Great Depression, things fail to improve as quickly.
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suddenfun
Subvert the dominant paradigm
09:55 PM on 03/11/2012
Re-instate Glass Steagall, it is the only way to go forward. Our system is too corrupt to do anything else and we cannot wait for the system to be fixed, we need this in place now. Return Glass Steagall.
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AlfredE69
Liberty Lovin' Tree Hugger
04:56 PM on 03/11/2012
Too big to fail is Un-American.
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wikwox
So there I was, playing the piano....
12:18 PM on 03/11/2012
There is no better example of the corruption of America's politicians than the Banking Crises, TARP and the blocking of reimposing Glass Steagall. The banks own many politicians and continue to largely do as they like, using your money as a back stop for when they fail. As noted in the article they continue to try and block what little protection has been enacted into law. We'll see yet another bank crises and no one really doubts it. Democracy has failed on this one, at least Ted Kaufman tried to set it right.
11:37 AM on 03/11/2012
Thank you Mr. Kaufman for all your hard work. Please keep it up. Sadly, something which should seem obvious to the vast majority of Americans will apparently take years to convince them of.
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tnkeating
Dyslexic agnostic insomniac
09:48 AM on 03/11/2012
And the pozi scheme goes on.
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Josh Crawford
Just the facts, man!
04:48 AM on 03/11/2012
I spent a week in 1995 with Arthur Leavitt (Chairman of the SEC) and Sandy Weill (CEO of Citigroup) and several of their friends on a Grand Canyon rafting trip (I was a guide on summer vacation from law school). They were all very nice and extremely intelligent men but I knew at the time that they were wrong about one thing: they were all for "self regulation" of the financial services industry by the financial services industry (i.e. letting the fox guard the hen house). They seemed to sincerely believe that this would be good for the country but I think the last 15 years proves how very wrong they were...Nice guys but horribly wrong on this issue...
04:42 PM on 03/05/2012
"93.2 percent of those who visited with Securities Exchange Commissioners or staff about the Volcker amendment were financial institutions, law firms, accounting firms, trade associations, lobbyists or policy advisors who represented financial institutions. The remaining 6.8 percent represented public interest or union groups." (The "little people".)
04:29 PM on 03/05/2012
Thank you, Mr. Kaufmann, for keeping your voice in this discussion, though every one of our voices seem to be falling into a Washington, D. C., void.
04:27 PM on 03/05/2012
Too bad Tim Geithner shows no indication of having either ears for hearing non bankers/non financial & relate interests have to say or eyes for reading what any opponent of those financial/banking & related interests write.

Can someone please tell us why Obama continues clinging to Geithner?
Zip Zinzel
If a Nation expects to be both Ignorant & Free . .
01:39 AM on 03/11/2012
I am a Progressive Dem, and a Keynesian
I have a degree in Business with minors in Accounting & Econ
AND I SUPPORT GEITHNER
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jstrate
03:22 PM on 03/05/2012
Is the problem regulatory capture of the long standing habit of members of Congress to solicit campaign contributions from the financial services industry? Perhaps it's both. Plainly, members of Congress don't care in the slightest about the public interest on this matter. If something goes wrong again, as it probably will, they can blame the industry and regulators again and an ignorant and gullible public will buy it.
02:47 PM on 03/05/2012
We in the UK, like you, used to have the "Glass Wall" seperating 'normal' bank activity from thehigh risk investment stuff. I remember my late father - he died in '83 - saying if and when - 'cos they were suggesting it here even then - the "Glass Wall comes down it'll be catastrophic.. Sadly too few voices were listened to amid the unbridled greed.
I'm minded of Bernard of Clairvauxs' words "Has not the Lord written upon sacks of gold.. 'beware danger if death' "...

Time for the wall(s) go back up again if we're ever to avoid the chaos..
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Stoopid American
Trooth, justice, and the American way ...
01:53 PM on 03/05/2012
The Volcker rule is insufficient. Two simple things must change:

1. Glass-Steagall, in its entirety, must be reinstated.

2. The Sherman Anti-Trust Act should be amended to define any company that is too big to fail as a de facto trust, that should be broken up into smaller entities that are no longer systemically threatening.

This will prevent the repeat of 2008. Anything short of this, and we are condemning ourselves to live through it again.
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JoAnn Kennedy
12:44 PM on 03/06/2012
Agreed, these too big to fail banks, corp's and merged industries are like the robber barons and trusts that brought US the first global/national depression of 1873. In addition, it's like history repeating itself over and over and over again. I remember sitting in the Jimmy Carter gas lines, and hearing the rhetoric from both sides of the aisle (R's & D's) to become more energy efficient and stop being dependant on Middle East oil. And here we are. More deep in debt, co-dependant and finacially dysfunctional.
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gutenmorgen
a.k.a. crowsnest
01:37 PM on 03/05/2012
Sir, there is one thing much bigger than banks that must not fail. It is called nation. Do you really believe that tinkering at the edges will save the nation from staring into another abyss in the future? I do not because of the nature of the beast..