LIVE FROM THE OCCUPATIONS OF NEW YORK CITY

OccupyWallStreet.net is brought to you by the NYC General Assembly to provide news, information and inspiration from the occupations of Wall Street and around the world.

Occupy the SEC Submits a New Letter to the FDIC

SEC Occupied

Occupy the SEC is a group of OWS activists, financial professionals, lawyers, and concerned citizens who read through the Volcker Rule draft line-by-line. They submitted a public comment letter responding to 244 of the 395 the questions the regulators have posed about the Volcker Rule. You can find their comment letter at http://occupythesec.org.

The group holds weekly meetings to discuss financial regulations and how we can act to be a light shining on the rulemaking process.

Occupy the SEC (“OSEC”) has submitted a letter to the FDIC regarding that agency’s proposed regulations implementing Title II of the Dodd Frank Act (“DFA”).  Title II of the DFA contains vital provisions that, if properly implemented, would help address the troublesome risks presented by “Too Big to Fail” (“TBTF”) financial institutions.

Title II seeks to allow for orderly resolution of troubled Systematically Important Financial Institutions (“SIFIs”) in a manner that spares taxpayers the undue burden of supporting the colossal financial conglomerates that led to the 2008 financial crisis.

Unfortunately, a weakly-implemented Title II would be nothing more than a backdoor-bailout for overleveraged SIFIs.  OSEC has encouraged the FDIC to impose stringent penalties for SIFIs that are required to fall under its receivership under Title II.  The mistakes made by the government in handing out a billion dollar under the Troubled Asset Relief Program (TARP), completely free of any meaningful warrants or conditions, must not be repeated.

OSEC encourages the FDIC to recoup compensation from culpable management at troubled SIFIs, and to set future limits on executive compensation at bridge financial companies under receivership.  Excessive executive compensation at trouble SIFIs only serves to drain vital capital.  Financial executives should not be permitted to profit from their managerial malfeasance, especially when relying on the government to ease their companies’ unwinding and reorganization.

OSEC also encourages the FDIC to require bloated SIFIs to spin off subsidiaries, which would reduce these conglomerates’ anticompetitive market power.  Requiring divestitures would also serve to dilute risk across a greater number of entities, which in turn would reduce the risk that any of those entities would will be considered “Too Big to Fail” due to systemic inter-connectedness.

The final regulations must contain serious disincentives for SIFIs to undergo Title II receivership, otherwise the Title II resolution process will become just another version of a government bailout.

Originally published on the Occupy the SEC blog.

Share +