减少美国金融系统的系统性风险

减少美国金融系统的系统性风险内容摘要：

scrutiny and loss of independence. At the outset, it is also worth noting that the Volcker Rules and related limitations on bank size announced by the Obama Administration on January 21, 2020 do not have much if any potential to reduce systemic risk. The Volcker Rules would prohibit bank holding panies and all of their subsidiaries from engaging in proprietary trading, as well as from investing in or sponsoring hedge fund and private equity operations. Although President Obama has characterized proprietary trading as trading unrelated to serving customers, a precise legal standard has not been given. The related size limitations were initially described as straightforward caps on each bank39。 s market share of nondeposit liabilities. As Deputy Treasury Secretary Neal Wolin describes, however, the size limits would not require banks to divest existing operations or restrict anic growth, but would instead limit banks39。 ability to gain market share through mergers and acquisitions. The Volcker Rules are unlikely to reduce systemic risk for several reasons. First, banks generally engage in relatively little proprietary trading. For example, Wells Fargo and Bank of America, two of the largest depositfunded banks, are estimated to earn less than 1% of revenues from proprietary trading. Second, activities that threaten the financial system do not occur only in banks. In fact, none of the most prominent failures of the financial crisisFannie Mae, Freddie Mac, AIG, Bear Stearns, or Lehmanwas a deposittaking bank. And third, focusing on proprietary trading ignores the real cause of the financial crisis: losses from lending and securitization. Goldman Sachs has estimated that losses from lending and securitization accounted for approximately 80% of overall credit losses incurred by . banks. Nor should we expect reductions in systemic risk to result from the size limitations. An institution does not pose systemic risk because of its absolute size, but rather because of its debt, its derivatives positions, and the scope and plexity of its other financial relationships. Because the problem is not size but interconnectedness, reform should focus on reducing the interconnections so that firms can fail safely. Furthermore, even if size were the right issue, Mr. Wolin39。 s testimony implies that the size limitations would not require any existing bank to shrink. If size is the source of systemic risk, presumably we should be concerned about it whether it is the result of acquisition, anic growth, or otherwise. The draft legislation introduced by Senator Dodd on March 15, 2020 (the Senate draft) contained a modified version of the Volcker Rules and size limitations. Though the Senate draft calls on the Financial Stability Oversight Council to conduct studies of whether these reforms will reduce systemic risk before they are implemented, studies are not needed to confirm that benefits from these reforms will be negligible. Outright restrictions on proprietary trading proposed in the Senate draft would apply to insured depository institutions, panies that control insured depository institutions, bank holding panies, and all subsidiaries of the foregoing. The Dodd proposal is even more strict than Chairman Volcker remended. According to Chairman Volcker it would be acceptable for Goldman Sachs to drop its bank charter and continue to engage in proprietary trading. However, under the Senate draft,。