Come on. The damn thing is 900 pages long and the heads up I was supposed to get I never got because they were still playing with the language up until last night.
First rushes on the Volker Rule make it sound as though with the exception of the dabble into criminal complaints on CEOs--which appear not to be there--the Volker Rule as constructed places pretty harsh restrictions on the manner in which American banks at least can continue in this business which has been know as banking for the last, well, I don't know for how long if you consider the trading of foreign exchange which predates me. Fair to say, this is a sea change.
No comment until I see the language except to say as one commentator did earlier today that all the regulators around the world had better be on the same page otherwise the ownership of American banking shares might not be the place to be in the near…or far for that matter…future. Forum shopping the regulatory haunts may be the game of the future and bugger thy neighbor could become very much in vogue. And yet, for some of us, there is a bit of sangfroid in all this. It was probably about 40 years ago when two tiered employment at banks became part of the game. As regulations changed and technological change overwhelmed the industry, so too did the compensation structures at every institution. From a collegial work enviorment, came the dog eat dog mentality of the trader evirorment, the "rip your heart out" trading rather than the "sure you mean Cable at 1.5678, mate?" The institution meant nothing, the bonus everything and while we all wanted to make money, the effort became all-encompassing. I'm sure there are a lot at my age not disappointed in this at all; indeed, there are many like me who walked away because of it. "'Bout time The Masters of the Universe got theirs," many think tonight. I admit there is some of that in me who vainly argued that the direction in which were headed might not be the best for the long term future of the institution or industry. But when the "long term future" is defined as quarter to quarter, it's probably not a good argument. You win some and lose some…and the trader's line is "I just have to be right 51% of the time
The fun thing is beginning the watch as to how the institutions are going to get around these new marching orders and believe me, they are going to try. It will be harder this time because for once the politicians recognized they hadn't a clue and left the writing up to the regulators. Believe it or not, the regulators do know something about what they are regulating; their problem has always been enforcement. Now if the new rules are as tough as advertised and if they are enforced, the best thing is to probably sit back, accept a few lean years of profits and publicize the hell ut of the drop in banking employment and return to the political arena for relief. Worked before, should work again. Hope you watch with me. We start tomorrow.
Showing posts with label Volker Rule. Show all posts
Showing posts with label Volker Rule. Show all posts
Tuesday, December 10, 2013
Thursday, December 5, 2013
AN OBSERVATION AND A CONFIRMATION
According to reports published today, the banks lost what might be a big one in the argument about the Volker Rule over the strategy known as "portfolio hedging." You might remember that this was suddenly discovered by regulator and politicians alike (why not before,…who knows) in the debacle in J.P. Morgan's shop in London which became know as the "London Whale" scandal for it was claimed that the activity being undertaken was portfolio hedging.
Now if Jaime Dimond can be accused of one thing--and I have--is not knowing when to keep his mouth shut. To claim, as he did, that what happened was "portfolio hedging done badly" was crap. Worst of all everybody knew it was crap. Had he said, "these bastards tried to make an extra buck, got it wrong, tried to double down, got that one wrong too and we decided to liquidate the position when everybody in the world knew it was going to be one way traffic and as a result we lost $6 billion, so we fired everyone involved including some seriously senior people," Jamie might have skated…but he didn't. And given the excuse, the Carl Levins and Crazy Lizzys of the world were give the perfect opening and nailed everybody…maybe. We'll see how this comes out but if it is as reported, two things will happen: first, the price of credit goes up for everybody. Remember yesterday's post? Ain't no competition out there any more or a lot less of it. Secondly, feeling constrained, banks will look around for something else to do that they know nothing about, immediately become masters of the unknown and at some point screw that up as well. Hang around to see if I am right.
Which I may be if history is any guide. Remember a couple of years ago when I suggested that one of the things our buddies the Chinese would love to do is replace the U.S. Dollar as the world's only reserve currency? As of last month, the Reiminbi or Yuan--take your pick--became the second most used currency in the settlement of international trade replacing the Euro. It's way behind the dollar to be sure but these guys have been a functioning society for a few thousand years. They know how to wait. Repercussions? heck, I'm not smart enough. Ask Joe Biden when he resurfaces. He's our new Sino expert.
Wednesday, December 4, 2013
THE LACK OF BANKS
That has been the talk of the town Over Here lately. It seems that someone did the numbers and we are down to a mere 7,000 or so banks from nearly 20,000 about 30 years ago which is a hell of a drop but still a hell of a lot of banks. If one considers that Great Britain at one point in time dominated the world of finance and commerce with something like 5 or 6 indigenous banks and a handful of Colonial institutions (Hankers & Shankers, Standard, Chartered and merchant banks galore), it seems like an even more enormous number. But consider: the United States is an enormous and incredibly diverse country, in population, industry, geography and economy. What plays in Boston may not play on Broadway much less Omaha, so is there rightful concern that 7000 may not be enough as some have suggested to service this marketplace?
It is a really good question one having no easy answer. Throw into the equation that the banks no longer around tend to be the smaller, community banks who were unable to compete and closed or merged, or those that tried to compete and ran into trouble trying to remain profitable, or those that were simply badly managed and were shut down. Their market areas were assumed by bigger, often far removed institutions with no ties to the communities they supposedly served and hence, little understanding or empathy with the customers inherited. There was no Ben the Banker who would approve an equipment loan to his schoolmate Fred the Farmer despite two years of flood followed by drought because Ben knew that Fred would auction his first-born to pay him back. A credit officer far from the scene would approve or more likely than not disapprove that transaction. And so would be lost the first rule of credit: Know Your Customer.
This is not a little thing especially when the country finds itself desperately needing to grown to get us out of this economic malaise. In addition, in this period of consolidation caused in no little extent by the need to protect depositors through mergers, forced or otherwise, the result has been in too many cases punishment delivered to acquiring institutions for the sins of the acquired. resulting in a chilling effect on future credit-related operations.
Oh, I'm not trying to say that the Morgans and the B of As of this world are without sin, but after a while politically effected prosecutions and enforcement actions accompanied by clearly politically directed regulations take their toll. The reaction is, "who needs this," and banks stop doing what they are in the business of doing which is to take risk. And when that happens, well, you can see the result; diminished economic activity all-around.
Another thing happens. Scared out of making money in traditional ways, banks cast afield for new opportunities for profit in non-conventional areas. Disaster is often the result. We have seen this happen with conventional lending with the move to areas such as "structured finance," and capital market activities which all but a very few institutions understand well enough in which to be involved. Real danger there, but couple that with the coming implementation of the Volker Rule…about which I am damn near certain Mr. Volker wishes he had never begun the discussion…and another source of bank profitability is cut off and it will not be long before we are down to 5,000 banks and heading south. We haven't thought this thing all the way through I'm afraid as we tend to do most things. I mean, this is complex stuff…not something simple like providing health care for 325,000,000 people.
It is a really good question one having no easy answer. Throw into the equation that the banks no longer around tend to be the smaller, community banks who were unable to compete and closed or merged, or those that tried to compete and ran into trouble trying to remain profitable, or those that were simply badly managed and were shut down. Their market areas were assumed by bigger, often far removed institutions with no ties to the communities they supposedly served and hence, little understanding or empathy with the customers inherited. There was no Ben the Banker who would approve an equipment loan to his schoolmate Fred the Farmer despite two years of flood followed by drought because Ben knew that Fred would auction his first-born to pay him back. A credit officer far from the scene would approve or more likely than not disapprove that transaction. And so would be lost the first rule of credit: Know Your Customer.
This is not a little thing especially when the country finds itself desperately needing to grown to get us out of this economic malaise. In addition, in this period of consolidation caused in no little extent by the need to protect depositors through mergers, forced or otherwise, the result has been in too many cases punishment delivered to acquiring institutions for the sins of the acquired. resulting in a chilling effect on future credit-related operations.
Oh, I'm not trying to say that the Morgans and the B of As of this world are without sin, but after a while politically effected prosecutions and enforcement actions accompanied by clearly politically directed regulations take their toll. The reaction is, "who needs this," and banks stop doing what they are in the business of doing which is to take risk. And when that happens, well, you can see the result; diminished economic activity all-around.
Another thing happens. Scared out of making money in traditional ways, banks cast afield for new opportunities for profit in non-conventional areas. Disaster is often the result. We have seen this happen with conventional lending with the move to areas such as "structured finance," and capital market activities which all but a very few institutions understand well enough in which to be involved. Real danger there, but couple that with the coming implementation of the Volker Rule…about which I am damn near certain Mr. Volker wishes he had never begun the discussion…and another source of bank profitability is cut off and it will not be long before we are down to 5,000 banks and heading south. We haven't thought this thing all the way through I'm afraid as we tend to do most things. I mean, this is complex stuff…not something simple like providing health care for 325,000,000 people.
Thursday, October 25, 2012
BACK TO BASICS?
All quiet on the Euroland front which does me no good and them neither. Soooooo....
I've been meaning to get back to commenting on the state of banking regulation here and there but to be perfectly honest I really don't understand the state of play and everytime I ask someone supposedly in the know they claim not to know anything either. One thing we do know is that piece of rubbish known as Dodd/Frank, which was supposed to be up and running in July remains in the drafting room with a miriade of problems not the least of which is "the Volker Rule" which, as anticipated and predicted, has tured into a lawmakers nightmare. Definitionally, it was always bound to be difficult but despite claims that "we're almost there" and "it will be ready by the end of the year" it has fallen afoul of the classic D.C. syndrome of the "Turf War." You see, no less than five different entities are claiming ownership of this piece of business and while the banking boys (Fed, FDIC & Treasury) claim there are of one mind, they are not. Lay over that the Commodities lot led by the dreadful Gensler and the SEC which is being proven to be increasingly incompetent and you have a perfect crap-storm instead of the needed cooperation. Not that the banks care, mind you. The longer this goes on the better for them as any solution will arrive as a result of sheer exhaustion and not as a result of meaningful compromise. To be fair, this is an almost impossible task as was suggested when this stupidist of all legislation was passed and at some point if there is a God for banks this will be recognized.
If one really wants to limit the amount of market risk taken by governmentally insured institutions ban securities transactions entirely. If the institution still wishes to engage in such business have it be located in a seperately capitalized subsidiary, ban funding from the parent company regulate it as just another securities firm. While one is at it, change the status of the Goldmans and Morgan Stanlies of this world, get them the hell away from the discount window and have the compete on an equal basis with the new entities...funding from the market at market rates and NOT from their parent or sister companies.. Oh, a clear statement from the git-go that these firms are NOT too big to fail will do more to insure proper risk management than anything else. Remember, banks die on the liability side: no funding, no bank. If lenders are convinced there is no bail out they we act accordingly and do their homework.
Now this is going to result in probably far lower profits but hey, you can't have everything. There is, however, the issue of the (mostly) European universal banks and the competative advantages they could have if regulation of this sort were adopted. This is real, but it is real in a far broader context than what has been explored here. Basel III for instance which I plan to introduce tomorrow...unless Euroland gives me an opening. Fat chance of that.
I've been meaning to get back to commenting on the state of banking regulation here and there but to be perfectly honest I really don't understand the state of play and everytime I ask someone supposedly in the know they claim not to know anything either. One thing we do know is that piece of rubbish known as Dodd/Frank, which was supposed to be up and running in July remains in the drafting room with a miriade of problems not the least of which is "the Volker Rule" which, as anticipated and predicted, has tured into a lawmakers nightmare. Definitionally, it was always bound to be difficult but despite claims that "we're almost there" and "it will be ready by the end of the year" it has fallen afoul of the classic D.C. syndrome of the "Turf War." You see, no less than five different entities are claiming ownership of this piece of business and while the banking boys (Fed, FDIC & Treasury) claim there are of one mind, they are not. Lay over that the Commodities lot led by the dreadful Gensler and the SEC which is being proven to be increasingly incompetent and you have a perfect crap-storm instead of the needed cooperation. Not that the banks care, mind you. The longer this goes on the better for them as any solution will arrive as a result of sheer exhaustion and not as a result of meaningful compromise. To be fair, this is an almost impossible task as was suggested when this stupidist of all legislation was passed and at some point if there is a God for banks this will be recognized.
If one really wants to limit the amount of market risk taken by governmentally insured institutions ban securities transactions entirely. If the institution still wishes to engage in such business have it be located in a seperately capitalized subsidiary, ban funding from the parent company regulate it as just another securities firm. While one is at it, change the status of the Goldmans and Morgan Stanlies of this world, get them the hell away from the discount window and have the compete on an equal basis with the new entities...funding from the market at market rates and NOT from their parent or sister companies.. Oh, a clear statement from the git-go that these firms are NOT too big to fail will do more to insure proper risk management than anything else. Remember, banks die on the liability side: no funding, no bank. If lenders are convinced there is no bail out they we act accordingly and do their homework.
Now this is going to result in probably far lower profits but hey, you can't have everything. There is, however, the issue of the (mostly) European universal banks and the competative advantages they could have if regulation of this sort were adopted. This is real, but it is real in a far broader context than what has been explored here. Basel III for instance which I plan to introduce tomorrow...unless Euroland gives me an opening. Fat chance of that.
Friday, February 24, 2012
...FUTURE CONTINUED
THERE IS A SURFEIT OF LIQUIDITY ON WALL STREET. IT GENERATES FEES AND SHORT TERM GAINS BUT HAS LITTLE SOCIAL WORTH. IT IS THE OPPOSITE OF USEFUL. IT DISAPPEARS WHEN MOST NEEDED AS IN THE 'FLASH CRASH' OF 2010, THUS EXACERBATING COLLAPSES." So wrote Mr. Eisinger and what he wrote is really important except he hadn't a clue.
The problem with folks like he they start their writing from a premise which is uniquely their own and all then follows whether correct or not. They are not reporters or educators in any sense but lecturers which is perfectly ok except when someone tries to apply like concepts to solve the wrong problem. Let me digress for just a bit to illustrate thepoint.
In late 2007, I called an old regulator buddy, since retired, on the subject of Goldman Sachs and their liquidity position. He told me that at the time he believed that Goldman had spare liquidity of over $100 billion dollars in committed facilities, meaning they were paying some sort of fee to insure availability. My comment was, "Until they need it." "Yeah," said he, "but nobody understands that." I don't think that Mr Eisinger does either because this little tale is merely the tip of the iceberg.
I've said something like this before but it bears repeating. Banking, at it's core is a pretty simple business. A bank takes deposits and makes loans profiting from what ever interset rate diffenential they can obtain. There is an old saying that banks "borrow short and lend long" meaning the duration of their deposit base is always shorter than the duration of the loan portfolio, and because of the duration difference they can borrow money (accept deposits) and a cheaper rate than that at which it is loaned back out. Of course that means that banks have to constantly roll over deposits for they fund the business and if they are smart, they put into place liquidity facilities to insure that they always have funding.
Over the centuries the business of banking has changed with new products, new business lines, even entirely new business, but what has not changed is that banks have to borrow money to fund all of these things and theydo BUT there are, today a hundred--well, perhaps not that many--way for banks to obtain funding. No longer does the banker rely upon Ma and Pa Kettle with their checking account, savings accound, certificate of deposit or Christmas Club. Today, bankers get their deposits from people and entities thousands of miles away and, if done through a broker or a money fund, people they do not know and will never meet. Whereas Ma and Pa's money was pretty much always there the duration of today's funding is often overnight and highly unreliable during any period of concern. But what of liquidity facilities such as the one over at Goldman you ask? When people get scared and you try to use them, committed or not, they aren't there. "But I Paid a Fee!" say you. "Sue Me," says the provider. Welcome to October 2008.
What Mr. Eisinger missed in his very interesting piece is the most important thing of all. The Volker Rule, indeed the whole pile of nonsense that is Dodd/Frank is supposed to regulate a multi-trillion dollar international banking system that is funded in exactly the same manner as was The Bank of New York at its founding in 1784! This is the risk on the street and not a word is devoted to it in Dodd/Frank. Good luck.
---------------------------------------------------
Little Paulie Krugman was at it again in the Times this morning. Desperate to justify an increase in the national debt by $5 trillion in the past 3 years, he has been arguing that fiscal dicipline is the wrong way to go...just look at Europe. A few weeks ago he was effusive in his prais for Mario Draghi in opening the ECB with its version of Free Money For Everybody in order to stimulate the economy. Today, he tried to quote every Republican economist he could think of to support his case. Readers of this space will no doubt remember my opining that the real reason for Paulie's desperation was that the democratic socialism model of western Europe was about to end and with it The Leader's dreams for the U.S. Poor Little Paulie. While he was babbling away in the Times, Super Mario gave his first inerview in the Wall Street Journal. What did he say? Only that the European model had to end. Oops.
The problem with folks like he they start their writing from a premise which is uniquely their own and all then follows whether correct or not. They are not reporters or educators in any sense but lecturers which is perfectly ok except when someone tries to apply like concepts to solve the wrong problem. Let me digress for just a bit to illustrate thepoint.
In late 2007, I called an old regulator buddy, since retired, on the subject of Goldman Sachs and their liquidity position. He told me that at the time he believed that Goldman had spare liquidity of over $100 billion dollars in committed facilities, meaning they were paying some sort of fee to insure availability. My comment was, "Until they need it." "Yeah," said he, "but nobody understands that." I don't think that Mr Eisinger does either because this little tale is merely the tip of the iceberg.
I've said something like this before but it bears repeating. Banking, at it's core is a pretty simple business. A bank takes deposits and makes loans profiting from what ever interset rate diffenential they can obtain. There is an old saying that banks "borrow short and lend long" meaning the duration of their deposit base is always shorter than the duration of the loan portfolio, and because of the duration difference they can borrow money (accept deposits) and a cheaper rate than that at which it is loaned back out. Of course that means that banks have to constantly roll over deposits for they fund the business and if they are smart, they put into place liquidity facilities to insure that they always have funding.
Over the centuries the business of banking has changed with new products, new business lines, even entirely new business, but what has not changed is that banks have to borrow money to fund all of these things and theydo BUT there are, today a hundred--well, perhaps not that many--way for banks to obtain funding. No longer does the banker rely upon Ma and Pa Kettle with their checking account, savings accound, certificate of deposit or Christmas Club. Today, bankers get their deposits from people and entities thousands of miles away and, if done through a broker or a money fund, people they do not know and will never meet. Whereas Ma and Pa's money was pretty much always there the duration of today's funding is often overnight and highly unreliable during any period of concern. But what of liquidity facilities such as the one over at Goldman you ask? When people get scared and you try to use them, committed or not, they aren't there. "But I Paid a Fee!" say you. "Sue Me," says the provider. Welcome to October 2008.
What Mr. Eisinger missed in his very interesting piece is the most important thing of all. The Volker Rule, indeed the whole pile of nonsense that is Dodd/Frank is supposed to regulate a multi-trillion dollar international banking system that is funded in exactly the same manner as was The Bank of New York at its founding in 1784! This is the risk on the street and not a word is devoted to it in Dodd/Frank. Good luck.
---------------------------------------------------
Little Paulie Krugman was at it again in the Times this morning. Desperate to justify an increase in the national debt by $5 trillion in the past 3 years, he has been arguing that fiscal dicipline is the wrong way to go...just look at Europe. A few weeks ago he was effusive in his prais for Mario Draghi in opening the ECB with its version of Free Money For Everybody in order to stimulate the economy. Today, he tried to quote every Republican economist he could think of to support his case. Readers of this space will no doubt remember my opining that the real reason for Paulie's desperation was that the democratic socialism model of western Europe was about to end and with it The Leader's dreams for the U.S. Poor Little Paulie. While he was babbling away in the Times, Super Mario gave his first inerview in the Wall Street Journal. What did he say? Only that the European model had to end. Oops.
Tuesday, October 18, 2011
WHEN WILL THEY EVER LEARN
The Grauniad announced today that the EU rescue facility would be leveraged to upwards of 2 trillion Euros. A typo no doubt, then again the newspaper gets it wrong so many times that one thinks it must be affiliated with The Times with whom it shares a unique view of the world from the far left. Unaware of the reputation of the source, the stock boys bought everything in sight and reversed a dreadful daily performance to a 140 point DOW gain at the close. For the life of me I simply don't understand how this mob on Wall Street has any credability left. Alost makes one want to pull out one's bell-bottom, psychedelic-dyed, 1969 bottoms, get stoned and join the sit in at Zuccotti Park. Radical, Dude. Maybe these guys are right...now we just gotta figure out what they're right about but aint it fun?
Come to think of it, the take over Wall Street movement has a lot in common with the Street's reaction to the events in Europe: neither mob has the slightest idea of what the hell is going on. What astonishes me is the complete absence of any comment from the Exchange executives condemming the "trading on rumor" activities of the past few sessions for, after all, this is real money we're talking about here. It is clear that no thought is going into this thing at all with key words and the push of a button (or however the hell they do it) moving markets by 300 points in the blink of an eye. They all seem to have bought their algorithms from the same vendor as well because once it starts it's one way traffic from then on. I wonder if there is anything about this in Dodd/Frank?
Speaking of that legislative jewel, I have spent more than a few hours pouring over it and for the life of me I have never reaad a more confusing, inpenatrable, improbable mis-mash in my life. It's so bad the the high priced and high powered firm of Jones, Day, Reavis & Pogue have actually developed a web site to walk interested parties through the morass and developments in the formation of laws to implement the legislation. Unless you are getting tired of self-flagelation, don't go there. Stick with the whips, chains or whatever you have handy. If away from home, poke yourself in the eye but DON'T GO THERE! Aside from the fact that the legislation was written in large measure to score political points and extract a pound of flesh, what is worse it seems to have been written with really very little thought or actual knowledge of the activities it seeks to regulate.
The latest argument and the one receiving the most press primarily because of its sponsor is that over the "Volker Rule" which seeks to ban trading on the part of deposit takers for one's own account or in the acronym, "Prop Trading." A number of institutions have already shut down their prop trading desks in anticipation of the rules being written but was has recently occurred has been a disagreement as to what constituties prop trading not just beetween the industry and the rule-writers but among the rule-writers and enforcers as well. What, for example is the best way to fill a client's order? To operate essentially in the "spot" market or to pre-position product that as a result of the relationship with the client creats the awareness of a future demand? Does that constitute prop trading? To an extent part of the problem is that the Fed doesn't like Treasury, Treasury doesn't like the commodity boys and they all loath the FDIC which is in part a legacy of The Bair of Very Little Brain. It also is a reflection of how poorly the legislation was drafted in the first palce...which is of course a microcausim of the mess that is Washington is at the present moment. As a result of all of this, I've decided that I simply can't comment on how issuess should be resolved--I have neither the resources nor the time--but reserve my efforts to commentary as to the manner in which they are resolved and the possible future effect these decisions will have. To the extent I can offer suggestions I shall, but allow me to express my apologies for the self-imposed limitations of a solitary comintator. Dodd/Frank has beaten me. I have the solice of being certain I will not be alone. Later, dudes.
Come to think of it, the take over Wall Street movement has a lot in common with the Street's reaction to the events in Europe: neither mob has the slightest idea of what the hell is going on. What astonishes me is the complete absence of any comment from the Exchange executives condemming the "trading on rumor" activities of the past few sessions for, after all, this is real money we're talking about here. It is clear that no thought is going into this thing at all with key words and the push of a button (or however the hell they do it) moving markets by 300 points in the blink of an eye. They all seem to have bought their algorithms from the same vendor as well because once it starts it's one way traffic from then on. I wonder if there is anything about this in Dodd/Frank?
Speaking of that legislative jewel, I have spent more than a few hours pouring over it and for the life of me I have never reaad a more confusing, inpenatrable, improbable mis-mash in my life. It's so bad the the high priced and high powered firm of Jones, Day, Reavis & Pogue have actually developed a web site to walk interested parties through the morass and developments in the formation of laws to implement the legislation. Unless you are getting tired of self-flagelation, don't go there. Stick with the whips, chains or whatever you have handy. If away from home, poke yourself in the eye but DON'T GO THERE! Aside from the fact that the legislation was written in large measure to score political points and extract a pound of flesh, what is worse it seems to have been written with really very little thought or actual knowledge of the activities it seeks to regulate.
The latest argument and the one receiving the most press primarily because of its sponsor is that over the "Volker Rule" which seeks to ban trading on the part of deposit takers for one's own account or in the acronym, "Prop Trading." A number of institutions have already shut down their prop trading desks in anticipation of the rules being written but was has recently occurred has been a disagreement as to what constituties prop trading not just beetween the industry and the rule-writers but among the rule-writers and enforcers as well. What, for example is the best way to fill a client's order? To operate essentially in the "spot" market or to pre-position product that as a result of the relationship with the client creats the awareness of a future demand? Does that constitute prop trading? To an extent part of the problem is that the Fed doesn't like Treasury, Treasury doesn't like the commodity boys and they all loath the FDIC which is in part a legacy of The Bair of Very Little Brain. It also is a reflection of how poorly the legislation was drafted in the first palce...which is of course a microcausim of the mess that is Washington is at the present moment. As a result of all of this, I've decided that I simply can't comment on how issuess should be resolved--I have neither the resources nor the time--but reserve my efforts to commentary as to the manner in which they are resolved and the possible future effect these decisions will have. To the extent I can offer suggestions I shall, but allow me to express my apologies for the self-imposed limitations of a solitary comintator. Dodd/Frank has beaten me. I have the solice of being certain I will not be alone. Later, dudes.
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