시역_경제_김형민

[김형민]

Fed연설이고, 미국의 지역(주 단위)은행에 대한 감독/규제를 어떻게 할 것인가에 대한 원론적인 스피치입니다.
https://www.federalreserve.gov/newsevents/speech/bowman20241002a.htm
Glosssary

Speech by Governor Bowman on building the community banking framework for the future

김형민_경제플러스_시역.docx

22.33KB

Administrative Procedure Act : 미국 행정 절차법

글로서리는 아니고 그냥 유용한 표현

(1) 탑다운 형식의 밀어붙이기식 탁상행정이 발생한다. : The “Push down” of standards + applies when  

(2) 바운더리 안에 들어간다 : be in scope

(3) 면밀히 살피다 : take stock of

(4) 소외된(=특히 기준이 미달한) : underserved +

(5) 법적인 맥락에서, 수반하다 : carry with it = accompany

(6) 의견수렴절차 : comment procedure

(7) 경계해야 한다 : should guard against

(8) 시험 등에서 상대평가 : (through) “grading on a curve” <-> grading on an absolute scale

(9) 단순비교, 기계적인 비교 : horizontal-like reviews.

(10) 자원재분배, 자원 전환 : divert resources from away other : relocate resources

It is an opportunity for us all to dig deeper into the community banking model and the important role of community banks now and into the future. Together, regulators work to ensure that the approach to supervision and regulation is fit for purpose, and that each element of both supervision and regulation acts in a complementary manner. Policy disagreements are a healthy part of the process, but we must also strive to build consensus where we can. At a minimum, we must understand and respect our counterparts' and colleagues' viewpoints. Ultimately, we all share the same goal of promoting a safe and sound banking system.

The strength of the U.S. banking system relies upon the diversity of its institutions, and facilitating an environment that allows each category of bank to thrive is essential to fostering a healthy financial system. For community banks, this includes building a framework that better supports the unique characteristics of these institutions. Today, my remarks will consider three foundational questions as we contemplate revising the community banking framework: (1) Given the continued evolution of the banking system, how should a community bank be defined? (2) Are we pursuing the most appropriate approach to supervision and regulation of community banks, and finally, (3) How can we build a policy framework that better supports and anticipates this evolution of the banking system now and into the future?

(1)One important aspect of this definitional question involves the natural evolution of banking, specifically as it relates to innovation. The "push down" of regulatory and supervisory standards often applies when a bank pursues activities that fit under the broad umbrella of "innovation." Innovation can be defined expansively to include engaging in bank-fintech partnerships, using (or considering using) digital ledger technology, or even providing traditional banking services to entities that touch the crypto-asset ecosystem. Innovation can present a challenging problem for both regulators and banks. If the "cost" of adopting innovation results in a bank's inclusion in a higher compliance tier, it may be difficult to encourage greater investment in innovation for smaller banks. Establishing appropriate regulatory thresholds does not force regulators to eliminate or purge innovation from the banking system, especially among community banks.4

When considering building a framework to support community banks, the definition is key—which banks will be in scope? The answer lies in the bank's business model, activities, and risk profile.

Where we have established fixed-dollar asset thresholds, we must commit to revisit and adjust them as needed. In my view, this is a principle that extends beyond the lines defining community banks to all regulatory and supervisory thresholds. While there is need for flexibility in both directions, it is apparent that over time economic growth and inflation will result in thresholds that are inappropriately low.

(2-1)Establishing a definition for community banks leaves open the fundamental question of regulatory and supervisory approach. Before turning to that discussion, we need to take stock of supervision and regulation today. What areas of the framework require review and attention?

Regulation can be a powerful and effective tool to promote bank safety and soundness, and U.S. financial stability. The special privileges that are granted with a banking charter—including deposit insurance and access to the discount window—all come with the responsibility and obligation to comply with the bank regulatory framework.

A robust presence of community banks, especially those that are remote and rural, enables access to credit, banking, and payment services in underserved markets and communities. These banks support local economies by serving consumers and small- and medium-sized businesses, building an economic foundation to drive business development and growth. But community banks, like any business, face the economic reality that accompanies running a successful business. Each must manage its costs—including personnel, funding, and regulatory compliance—in light of its revenues to achieve a reasonable return on equity.

When a bank's costs increase, there is, by necessity, a need to make changes if the bank hopes to maintain profitability and ultimately its survival. This usually involves either cutting costs or raising prices on banking services.

How do the realities of operating a business inform our current approach to regulation? The question becomes acutely relevant when regulators consider imposing new or revised regulations. Regulators should always ask 1) what problem does this new regulation solve, 2) what are costs of this approach, and 3) are there alternative approaches? Before discussing the path forward, I would like to note an example that highlights this concern.

The final Community Reinvestment Act (CRA) regulations issued in 2023 established new regulatory thresholds defining "small," "intermediate" and "large" banks, with the last category—large banks—including every bank with more than $2 billion in assets.5 In my view, this rulemaking represented a missed opportunity to rationalize the requirements of the CRA among community banks, and ignored the fundamental differences among banks with different balance sheets and business models.6 An approach that applies the same eval‎uation standards to a bank with $2 billion in assets as it does to a bank with $2 trillion in assets arguably represents a shortcoming in considering the fundamental differences among firms, and the disproportionate costs these standards may impose on the smallest banks.

(2-2) While regulation carries with it the obligation to comply with public notice and comment procedures under the Administrative Procedure Act, regulators have far more discretion in the supervisory process, and in issuing "guidance" that is technically non-binding but often operates as a de facto requirement. The development and implementation of new supervisory approaches and of guidance largely escape rigorous scrutiny due to the lack of formal procedural requirements for its development. This is true even though the expectations created by guidance can be equally or more impactful to banks than rules.

For example, the examination process often produces supervisory findings over-emphasizing non-core and non-financial risks, highlighting issues like IT and operational risk, management, risk management, and internal controls.7 These issues have filtered down from examinations and findings at the largest banks to the smallest, raising the question of appropriateness of application for smaller firms.

In the supervisory process, we should guard against being distracted by less relevant issues. The preval‎ence of supervisory findings related to nonfinancial metrics is in part driven by the time it may take to remediate certain issues. However, we should also scrutinize whether this trend is indicative of our supervisory focus—beyond financial risk and toward non-financial risks and internal processes—and whether that shift is appropriate. We should also be aware that due to the vast diversity in business models, size, and geographic footprint among banks, we should not expect every firm to follow the same standards and must be careful to prevent forcing uniformity through "grading on a curve." This risk can be exacerbated through any type of horizontal-like reviews. The supervisory findings made during the examination process inform bank ratings, which can have follow-on effects like limiting options for mergers and acquisitions (M&A) activity; raising the cost of liquidity; or diverting resources away from other, more important bank management priorities.

그 밖에 제가 해보고서도 이게 뭔말인가 싶어서 찾아봤던 것들.

The preval‎ence of supervisory findings related to nonfinancial metrics is in part driven by the time it may take to remediate certain issues : 그냥 냅두면 은행이 알아서 remediate해결하는데(시간이 알아서 해결해줄 건데), 그걸 감독 당국이 괜히 들쑤셔서 드는 행정적 시간낭비들 때문에 오히려 관리 감독할 (supervisory findings) 거리가 늘어나는 것.

예문 : The increase in customer complaints is in part driven by the time it takes to respond to inquiries during peak hours.

Be in part driven by the time it takes to ~ : to부정사 하는 게 별로 안중요한 원인이지만 뭔가 어쩔 수 없는 것인데, 주어의 상황을 악화시키거나 도드러지게 보이는 맥락에서 쓰는 표현