On the establishment side, we have folks like Treasury Secretary Janet Yellen. Even though she claims to have “focused on financial stability” throughout her career, she believes it was productive to enact “new macroprudential policies focused on mitigating systemic risk” in the wake of the 2008 financial crisis.
She argues that these regulations have “strengthened the financial system,” but she offers no direct evidence. (Yes, many banks have higher capital now versus 2007, but that could have been achieved without passing any new laws, much less the 2010 Dodd-Frank Act.) And if those new regulations worked so well, it stands to reason Yellen should not have had to bail out uninsured depositors in three banks that failed in 2023. If that bailout was necessary to save the world from financial catastrophe, those regulations could not have work as advertised.
Yellen also believes in Dodd-Frank’s Financial Stability Oversight Council.
For those lucky enough to be unaware, the FSOC is the multi-regulator council that is supposed to reduce future government bailouts by, among other things, identifying threats to financial stability. As hard as it is to believe, Congress decided that even though the United States already had more than 10 financial regulators who failed to even see a financial crisis coming, a good solution was to give those regulators even more responsibility.
Yellen recently argued that the FSOC was necessary to give regulators “a more holistic view of and approach to risks.” Again, the idea that nobody was regulating systemic risk prior to the creation of FSOC, in a holistic way or any other way, is undeniably false.
Regardless, here’s the kind of riveting risk analysis the FSOC produces. It’s 2019 annual report stated that “Firms with high levels of debt may be vulnerable to unexpected financial or economic events that may negatively affect their repayment and refinancing capacity.” Who knew?
And in 2022, with Yellen as Treasury Secretary, the FSOC warned that the commercial real estate market “faces a more uncertain outlook given elevated inflation, rising interest rates, a slowing economy, and the potential for structural changes in behaviors due to the COVID-19 pandemic.”
If it really is too much to expect the folks at the Fed and the FDIC to know about this uncertain outlook, Congress has all the evidence it needs to restructure the regulatory framework.
I’m much more aligned with my colleague, Mark Calabria, former director of the Federal Housing Finance Agency and former FSOC member. In his retrospective 2023 book, Calabria wrote “This may be the FSOC’s real strength, pointing out problems in our financial system for which none of its members bear any authority or responsibility.”