Editor's Note: This is a monthly publication on economic trends and financial policy issues. In this publication you can read "The Longbrake Letter", an analysis of economic trends and conditions written by Bill Longbrake, as well as commentary on financial regulation and policy written by members of the law firm Barnett, Sivon & Natter, P.C., a Washington, DC based law firm that specializes in financial services law.

ISSUE: #18, October 2011

The Longbrake Letter
- Bill Longbrake
Optimism has returned to financial markets as fear of recession has waned in the U.S. and as Europeans stitch together plans to manage an eventual Greek sovereign debt default. However, nothing really has happened that changes the formidable economic challenges facing the United States and Europe. In this month's letter Bill Longbrake describes the forces that are reshaping global political and economic systems, discusses the inadequacy and ineffectiveness of policy responses to these forces and comments on the possible impact of the developing “Occupy Wall Street” movement.

Vikram Pandit's Suggestion for Transparency in Comparative Risk Assessment — Summary and Reaction
- Bob Barnett & Bill Longbrake
At a Bretton Woods gathering recently, Vikram Pandit, CEO of Citigroup, argued that transparency and greater understanding of capital accounts in banks could be obtained through novel use of a hypothetical balance sheet. That approach is summarized and Bill Longbrake provides a reaction to it.

Information Sharing with the CFPB
- Ray Natter
The CFPB will have access to confidential supervisory information from the OCC and the FDIC pursuant to MOUs signed with both of these agencies. This article explains the status of these MOU agreements and what protections that include regarding further dissemination to third parties.

Nonbank SIFI Designations
- Jim Sivon
There recent court decisions have touched on the DFA preemption amendments to the National Banking Act. This article explains how these opinions support the OCC's interpretation of the DFA language as not changing the traditional preemption conflict standard as described by the Supreme Court in the Barnett Bank case.

Three Recent Cases Support OCCs Construction of the Preemption Language in the Dodd-Frank Act
- Ray Natter
The CFPB will have access to confidential supervisory information from the OCC and the FDIC pursuant to MOUs signed with both of these agencies. This article explains the status of these MOU agreements and what protections that include regarding further dissemination to third parties.

A Brief Note on the Guaranteed Mortgage Package
- Bob Barnett
Ten years ago, two roads leading to a uniform mortgage shopping document diverged. HUD took the well traveled one by abandoning its plans for a guaranteed mortgage package. Here is a look-back at that proposal.

     
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