Carl Aridas

In a landmark effort to both guide and spur artificial intelligence (AI) and machine learning (ML) development in the medical field, the US Food and Drug Administration (FDA) has released an Artificial Intelligence/Machine Learning (AI/ML)-Based Software as a Medical Device (SaMD) Action Plan. Background The plan was created by the FDA’s Digital Health Center of […]

Previously, I outlined the data that can be reported with the FR 2052a Complex Institution Liquidity Monitoring Report. My next blog will review the tools that can be used to help with reporting. With the need to consolidate entities on a line-by-line basis and to report such a large amount of information, whether on a […]

In early March, a series of programs were announced by the U.S. Department of the Treasury, and the Federal Reserve subsequently announced rules changes to leverage the impact of the programs.  The largest program announced, dollar-wise, by the Treasury Department was the creation and funding of the Emergency Capital Investment Program (ECIP).  The program was […]

In my last blog I discussed the consolidations required for success with the FR 2052a Complex Institution Liquidity Monitoring Report. My next blog will outline the data that can be reported. The FR 2052a report collects data for 10 distinct tables covering 115 product types, 14 counterparty types, 72 asset classes, and 75 maturity buckets […]

To misquote the great poet Alfred Lord Tennyson, “In the spring a young banker’s fancy lightly turns to thoughts of SNC Classifications.” SNC (pronounced like the candy bar but without the “ers”) stands for the Shared National Credit Program, which, since 1977, has assessed risk in the largest and most complex credits shared by multiple […]

In my last blog I outlined the recent changes to the FR 2052a Complex Institution Liquidity Monitoring Report. Now I want to discuss the consolidations required for success. The first challenge faced by institutions looking to comply with the new reporting requirements and thresholds is to determine which subsidiary institutions must be consolidated. As required […]

On February 18, the Federal Reserve Board announced a final rule that they claim is intended to reduce risk and increase efficiency in the financial system by applying derivative netting protections to a broader range of financial institutions. Sections 401-407 of the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA) validate netting contracts among […]

Previously, I discussed the history FR 2052a Complex Institution Liquidity Monitoring Report. My next blog will outline the recent changes to the report. As allowed in the FR’s 2052a guidelines, the Federal Reserve has already requested that monthly filers submit FR 2052a data on a more frequent basis and altered the asset and liquidity thresholds […]

Effective February 26, 2021, New York State has increased the maximum fee that check cashers in New York State may charge.  The increase is to 2.27 percent of the face amount of a check, draft, or money order.  The increase is permitted under Part 400.11 of New York State’s Superintendent’s Regulations which provides for an […]

The financial crisis of 2008 and 2009 highlighted the need for timely data to identify and monitor liquidity risks at individual firms, as well as in aggregate across the financial system, especially with respect to intra-company flows and exposures within a consolidated institution. Initially addressed through the Liquidity Coverage Ratio test, regulators soon recognized that […]

Last Friday, February 12, while many bankers were preparing for a long 3-day weekend or perhaps making preparations for Valentine’s Day celebrations, the Federal Reserve Board released the hypothetical scenarios for its 2021 bank stress tests.  In 2020, the Federal Reserve found that large banks were generally well-capitalized under a range of hypothetical events. The […]