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Bailey: “We are doing something important… helping a man get his own roof and walls.”
Potter: “You're worth more dead than alive.”
Banking Reform in the US
BANKING REFORM introduced granular LTV tables for traditional lending while treating $1.4T in NDFI (mortgage intermediaries, private equity funds, consumer & business credit) as one?
Governor Cook at 3/19/26 Fed Banking Reform meeting (56:31 to 57:06): "Finally, I am reserving judgement as to whether the down calibrations that are contributing to the material decline in capital requirements are actually making capital requirements more risk sensitive. Granular requirements are not necessarily equivalent to risk-sensitive requirements. Especially for exposures where our visibility may be quite limited. Better data and sightlines into banks exposures to certain non-bank intermediaries for example would give me greater comfort in assessing the proposed changes and the treatment of those exposures."
Ask and you shall receive Lisa.
Excluding non-depository financial institutions (NDFI), when compared to large banks, small banks have lent more in loans and leases in bank credit over the last 10 years by ~$1 trillion. Large banks have lent ~$849 billion more over that same time period to NDFIs.
What's the over/under on better underwriting for small banks? Does continued NDFI funding allow extend and pretend to continue?
Barr dissented to proposed changes.
Global Systemically Important Banks (GSIB) + KRE Regional Banking ETF Top 50%: NDFI loans to business credit intermediaries as % of total loans + $ amounts.
GSIB 12-31-25 total = 4.8% or $234 billion
KRE Top 50% 12-31-25 total = 2.5% or $49 billion
Steve Eismanon 4/17/26 The Real Steve Eisman Playbook: "Regional banks do not have the lion's share of exposure to private credit. In particular, the regional banks in the KRE ETF actually have very little exposure to private credit."
Charts show all banks combined + each bank individually.
Global Systemically Important Banks (GSIB) Total and Individual Non-Depository Financial Institution (NDFI) Loan Breakdown.
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