Professor at Wharton. Financial regulation, administrative law.
Philadelphia, PA
Joined January 2019
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This memo on large bank CEO pay - increasing quite a bit through one time awards, with investors expressing concern in say-on-pay votes, is interesting throughout. corpgov.law.harvard.edu/2026…
Warsh wants the Fed to talk less, and people have observed that board members and reserve bank presidents give speeches all the time - except right before an FOMC meeting, which is why the last Fed speech, by Bowman on supervision, was published on 10/14. federalreserve.gov/monetaryp…
Anthropic's S-1 deploys the catastrophic/e term 10 times, 6 of which are about AI existential risk. Something of a bummer S-1, though by design, the form is dedicated to worst case scenarios. 1/2 sec.gov/Archives/edgar/data/…
Community bankers almost always lean right, but the Kansas Bankers Assn is spending $1 million against Republican senator Roger Marshall. The issue: the endless fight between bankers and retailers on swipe fees; he also wants to cap credit card rates. sunflowerstatejournal.com/ka…
I've been looking at trade group practices when it comes to filing suits, after ICBA filled suit against the OCC over its digital asset trust practices. The big ones don't never file suit against the feds - 11 times since 2010, same amount as their suits v. state and local govts.
Switzerland really wants to be a land of medium sized asset managers, and UBS is an extremely large asset manager, so maybe this divorce is inevitable, but it's a matter of standing down from the commanding heights. wsj.com/finance/banking/a-sw…
The internet has been consulted, and I'm a 60% legal realist and 40% legal positivist, which I'm totally sure is a stable perspective. jurisprudence-quiz.netlify.a…
Looking through the Fed's enforcement actions, it's notable that Prompt Corrective Action orders (to increase capital) amount to 2.1% of them. Congress promulgated PCA after the S&L crisis; it worried that too many insolvent institutions got regulatory forbearance. 1/2
I did a docket search on Westlaw, and the community bankers trade group, before the suit this month against the OCC over its trust chartering, joined three other lawsuits, the one against the fintech charter and two complaints against the NCUA that might be over the same case.
The largest Native American owned bank, if you squint, was started by Kevin Stitt, the governor of Oklahoma, and an enrolled member of the Cherokee Nation, with whom he is constantly feuding. And Bank of America started in 1904 as Bank of Italy.
This story from American Banker reveals that's the Fed's new 5-region directorate will be staffed with directors employed by the reserve banks "but [will] report directly to the Board's Deputy Director for Supervision." Financing without control, I guess. americanbanker.com/news/fed-…
I'm interested in this reorg of supervision into five regions to mirror the state bank supervisor regions by the Fed. Seems like something the reserve banks wouldn't like, though the supervisors won't move. Regional leaders paid by board or reserve banks? federalreserve.gov/newsevent…
Financial crime monitoring has essentially been number go up since 9/11. 4.1 million SARs filed last year, 2.1 million from banks, up 7% from 2024. Fair to say that there's a budding counter-reformation developing here, this time its crypto mixers. subscriber.politicopro.com/a…
I could see AI agents giving advice that turns regular deposits into hot money, but I think there will be real hesitancy about giving them the keys to accounts and empowering them to make the decisions. wsj.com/opinion/ai-will-be-a…
Using affiliates and subsidiaries is having a moment, what with the private equity and insurance thing, the OCC's aggressive interpretation of what you can do with a trust charter, and maybe this - though I don't think the DIF could remotely handle a GSIB failure.
