by David Schwartz J.D. CPA | Apr 19, 2013 | All, Formal Regulatory Remedies
On December 14, 2012, the Board of Governors of the Federal Reserve System (Fed) issued for public comment a rule proposal that, if adopted, could drastically alter the structure and operations of foreign banking organizations (FBOs) in the U.S. The Fed’s...
by David Schwartz J.D. CPA | Apr 19, 2013 | All, Disclosure Regimes, Formal Regulatory Remedies
At this point, we’re basically saying all repos should be accounted for as borrowings. FASB Chairman Leslie Seidman On January 15, 2013, the Financial Accounting Standards Board (FASB) proposed changes to accounting standards for repos intended to improve...
by David Schwartz J.D. CPA | Apr 19, 2013 | All, Formal Regulatory Remedies
These loopholes are bad policy even in the best of circumstances, but it would be unconscionable to allow them to continue if we can use revenue from closing them to avoid the devastating effect sequestration would have on national security, homeland defense, law...
by David Schwartz J.D. CPA | Apr 17, 2013 | All, Change Overview and Rationale, Disclosure Regimes, Traditions
The latest financial crisis was marked by a spectacular lack of understanding about the astounding levels of risk that had been allowed to build up throughout the system. Regulators and risk managers realized after the fact that the data they needed to understand the...
by David Schwartz J.D. CPA | Mar 24, 2013 | All, Formal Regulatory Remedies
Rather than responding appropriately to the crisis, which would include developing a modern regulatory system with the flexibility to adapt to changes in the global financial system, we instead have been saddled with an increasingly prescriptive and inflexible...
