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One of the many requirements of the Dodd-Frank Act is that all federal agencies must remove references to and reliance on credit ratings from their regulations and replace them with alternative methods for evaluating creditworthiness.
The Shadow Financial Regulatory Committee believes that the FDIC should use the same principles–actuarial fairness–by which the private insurance industry operates.
Europe's banks and entire monetary system are in crisis from the sovereign debt of financially weak governments. But the capital requirement for banks to hold such Euro denominated debt was zero. It was defined as "risk free," but has instead led to massive losses.
This statement is available here as an Adobe PDF.
The Shadow Financial Regulatory Committee (SFRC) is a group of publicly recognized independent experts on the financial services industry--including banking, insurance and securities--who meet regularly to study and critique regulatory policies affecting this sector of the economy.
The federal banking agencies and the office of Thrift Supervision recently proulgated a final rule implementing the requirement of Section 305 of the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA).
This statement is available here as an Adobe PDF.
The 30-year fixed-rate mortgage, the most common way U.S. buyers finance a home purchase, isn’t the ideal instrument its supporters claim it to be.






