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wave of consolidation occurred in 1994

Kenneth H. Thomas

not all customers will benefit from greater consolidation

U.S. federal government rolled out various laws in 1784 to encourage multiple banks in individual states.

In 1933 alone, about 4,000 commercial banks and 1,700 savings and loans institutions failed.

"Many small banks feel that they are being pushed out of existence by new regulations,

swing of the pendulum last year, consolidation returned to 1994 levels. But in contrast to previous times, much of the consolidation has been due to failures

Loretta J. Mester

"In the short term, I think consolidation will pick up as weaker banks go through mergers and acquisitions, and stronger banks take time to get their capital shored up" in their pursuit of greater efficiency and economies of scale,

experts expect consolidation to continue, and predict that the trend will leave the banking system better off in the long run. "We don't really need as many banks as we used to,"

have less than $1 billion of assets, but account for 92% of all banks and savings institutions,

Dodd-Frank Wall Street Reform and Consumer Protection Act was a death knell

institutions that will likely be hardest hit by all this activity will be the community banks

Their plight hasn't been lost on the FDIC, which has launched various initiatives to give community banks some relief.

guidelines that lighten requirements for how these banks manage customers whose accounts are consistently overdrawn.

borrowers with low incomes or bad credit are significantly less likely to default on loans if they borrow from a local bank than if they receive a loan from a distant bank or mortgage company.

Todd A. Gormley,

"Smaller firms and local individuals trying to get loans from larger banks could be a subset of the population that is worse off because of consolidation,

concentration in geographic markets

are an important factor in the reciprocal relationship between lender and borrower

consolidation also leaves a handful of banks controlling the majority of certain types of products.

Four "mega banks" -- Wells Fargo, Bank of America, JPMorgan Chase and Citigroup -- now hold three-fifths of the home mortgage market, which limits consumers' choice of products and their ability to shop around for competitive pricing. "It's a textbook issue of a concentration of power," Guttentag says. "A limited number of firms control the market, and they will engage in implicit collusion."

community banks play an important role in local economies. They typically have close relationships with individual customers

some cities, states and regions have just one dominant bank.

Pittsburgh metropolitan area, PNC Bank has 47% of the deposit share, according to the FDIC. The second-largest bank in the area is Citizens Bank of Pennsylvania, which has 8.5% of the deposit share.

no limits on deposit shares in certain markets, 1994's Riegle-Neal Act imposes a 10% cap on nationwide deposits for a single bank.

Treasury Department is now looking into modifying the cap to include all consolidated liabilities.

consumers need not worry

Mester

While the total number of banks may be declining, the number of branches isn't.

In the last 10 years, the number of bank branches nationwide has increased 15%, although that expansion has primarily involved banks with $500 million or more in assets. The number of branches dropped slightly for the first time in a decade in 2010.

Guttentag

the number of banks will continue to shrink, but he doubts the U.S. will ever look like, say, Canada -- which has just 22 banks. Indeed, if consolidation continues as it has over the past 20 years at the average annual rate of 3.3%, it would take 60 years for the total number to fall below 1,000 banks and nearly 130 years to get below 100.

if the number of banks shrinks from 6,000 to 100, if those 100 are operating in all market segments and if consumers have many options, there is no reason for concern," Guttentag

Cross-jurisdictional liabilities.

take into account the liabilities of all offices of the relevant bank to entities outside the home market and include all liabilities to non-residents of its home jurisdiction.

international banks’ activities outside their home jurisdiction

Size.

bank’s distress or failure is more likely to damage the global economy or financial markets if its activities comprise a large share of global activity.

ts failure is therefore more likely to damage confidence in the global financial system

Interconnectedness

contagion in respect of other institutions depending on the network of contractual obligations in which it operates.

Intra-financial system assets.

Intra-financial system liabilities

Wholesale funding ratio.

Substitutability.

systemic impact of a bank’s distress or failure is expected to be negatively related to the substitutability of its services.

lack of realistic alternatives to a major business line

Assets under custody

disrupt the operation of financial market

Payments cleared and settled through payment systems

these institutions and customers may be unable to process payments immediately, affecting their liquidity.

Value of underwritten transactions in debt and equity markets

impede new securities issuance.

Complexity.

failure is likely to be greater, the more complex its business, structure, and operations are.

Notional value of OTC derivatives.

Level 3 assets.

Trading book value and “available for sale” value.

The BCBS provides some opportunity for individual supervisors of banks to make adjustments to a bank's G-SIB criteria determined by reference to the above criteria but states that it believes the bar for any such adjustment should be high, and it only expects such adjustments in exceptional cases.

continuing review of banks against the relevant indicators,

not proposing to develop a fixed list of G-SIBs. Banks could therefore migrate in and out of SIB status over time

G-SIBs, each bank will grouped into a category of systemic importance based on its score under the indicator based test specified above.

there will be 28 G-SIBs

Assessment Methodology

“indicator based measurement approach”

Each of these indicators is given a 20% weighting and, as specified below, most of the indicators are made up of two or more sub-indicators

Each indicator’s score is then aggregated.

Agency problem

Shareholder discipline.

Contingent capital holder discipline.

Market information.

Cost effectiveness.

Trigger failure.

Cost effectiveness.

Complexity.

Adverse signalling.

Negative shareholder incentives.

contingent capital should not be capable of meeting the additional loss absorbency requirement for G-SIBs

for consideration at the next G-20 meeting in November 2011, and it is expected they will be endorsed at such meeting.

28 banks will initially be specified as G-SIBs

The effect on such banks will, however, be significant

the common equity requirement for the largest global banks increasing from the current 2% of risk weighted assets to 9.5% (and potentially 10.5%)

G-SIBs will have some time to plan for the new loss absorbency requirement. The BCBS is proposing that the requirement will be phased in at the same time as the new capital conservation and countercyclical buffers between 1 January 2016, becoming fully effective at the start of 2019

the minimum “cut-off score” in relation to which banks will be regarded as G-SIBs will be set by 1 January 2014, and national jurisdictions will be expected to incorporate the new rules into legislation by 1 January 2015.

new Basel III framework at the end of 2010, the BCBS mandated all banks to hold significantly more capital than is currently the case as well as introducing new leverage and liquidity ratios

The Basel III rules apply to all banks. In addition, the FSB and the BCBS have been considering additional rules to apply to the largest global banks to deal with concerns that such banks are regarded as too big to fail

Basel Committee on Banking Supervision (“BCBS”) and the Financial Stability Board (“FSB”) published two papers relating to entities regarded as globally systemic important financial institutions (“G-SIFIs”)

Additional Loss Absorbency Requirement

Background

y.   Cons

: Pros