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It's
true that putting things into perspective enables priorities to be
established and, more, executed. After slogging through 18 months of
writedowns, bank seizures and management failings, there is no better time
for the industry to take control of its own destiny. Here are five things to
consider when digging out of this recessionary ditch so the industry is
stronger in its aftermath.
1. Refine implementation of the Troubled Assets Relief Program and all of
its scattershot acronym progeny - CPP, TALF, etc. while well intended from
the outset in the face of a ballooning crisis, helped turn the markets into
a basket case of uncertainty. What's needed is an equity-led recovery plan,
the merits of which are outlined for taxpayers, recognized and used by
strong banks as a means to fuel sustainable performance over the long term
and welcomed by investors. Only then can the industry see stabilization.
2. Regulate the unregulated. The banking industry - already highly regulated
- needs to apply pressure to regulators to focus on the unregulated,
including mortgage brokers and investment banks. No-doc loans? Forget it. As
for derivatives, they should be traded on an exchange. Price transparency
will follow. Fast-track clearinghouses for credit default swaps, and mandate
that all CDS holders/issuers participate. Then draw up exchange contracts
for CDS.
Yes, there will be more regulation. But what is politically delightful is
often dreadful in the end. Remember when the chart lines were all pointing
up? That brought on the Great Deregulation. Now some critics want a cop for
every spreadsheet. Make the new rules simple and fair, but make sure they
apply to all.
3. Take on mark-to-market accounting. The Emergency Economic Stabilization
Act of 2008 required The Securities and Exchange Commission, the Federal
Reserve, and the Treasury Department to study the ramifications of
mark-to-market standards "on a financial institution's balance sheet [and]
the impacts of such accounting on bank failures," among other things. The
SEC welcomed "feedback at any time from investors, financial institutions,
auditors and others."
The report to Congress is due this month, but the drive to unseat this
onerous convention must continue in earnest. Why? Mark-to-market accounting
ranks toward the bottom of the list when it comes to how to accurately price
anything. |