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36 FINDING BALANCE FOR BANK REGULATION As the Federal Reserve and other regulators roll back some post-2008 regulations, some worry that the economy may be put at risk during the next downturn, the New York Times reports. "No individual thing jumps out, but if you look at the sum total, the direction of travel is not entirely encouraging," Jeremy Stein, a former Fed governor, said during a recent panel. "You need to be incredibly vigilant and really understand this stuff very well. It's very opaque, in many ways." Included in the changes are some changes to the Volcker Rule, originally aimed at preventing banks from trading for their own profit with depositors' money and other funds. e revised rule will ease restrictions on bank investments. Banks complained that the Volcker Rule's provision which forced them to prove that their short-term trades were allowable under the law, was burdensome and restricted legitimate trading, and is now scrapped. Martin J. Gruenberg, a member of the FDIC board of directors, dissented against the rule, saying, "e Volcker Rule will no longer impose a meaningful constraint on speculative proprietary trading by banks and bank holding companies benefiting from the public safety net." e Times reported that representatives from each of the biggest banks have met multiple times with Fed officials to talk about the stress capital buffer, a measure that would condense and streamline capital requirements, according to two people familiar with the matter. Each bank also used a public comment period in 2018 to send letters detailing specific suggestions for changes the Fed could make when it enacts the new standard. "We're comfortable with the capital regime that we're operating under," John Shrewsberry, Wells Fargo's CFO, said on a call with reporters. According to Fed research, bank capital should be in a range of 13% to more than 26% of a bank 's assets, and capital ratios at big banks stood at about 14% at the end of last year. According to Neel Kashkari, President of the Federal Reserve Bank of Minneapolis, "e biggest banks need substantially more capital," noting that changes that could weaken requirements are "concerning." Flexibility + Scalability 300+ financial institutions are benefiting from SWBC's flexible insurance tracking programs WHY SWBC? More than 30 years of lender-placed insurance experience Managing General Agent model leverages multiple "A" rated carriers Choose from multiple program options Lender-Placed Insurance Programs for Mortgage Servicers © 2019 SWBC. All rights reserved. 1055-A3145 0219 Learn more at swb.us/tracking Lender-Placed Insurance Real Estate Owned Insurance