This month marks the fifth anniversary of the Dodd-Frank financial regulation act that, for better or worse, will likely change the way Wall Street operates forever.
Part of that legislation requires banks to write their own “wills” — that is, the steps they would take in the event of a bankruptcy or a major financial upset.
Basically, regulators like the FDIC and the Federal Reserve want the banks to be prepared to dismantle themselves without damaging the financial system if there’s another financial crisis.
They have been doing this for a number of years now, but it’s not often taken very seriously. Last year, the regulators were extremely unimpressed with the banks’ wills and threatened a forced restructuring if they didn’t make “significant progress” this year.
Twelve major banks reported their wills this year, but it could be months before regulators decide whether the plans are acceptable.
Some of them are more detailed than others. As the Financial Times’ Barney Jopson and Ben McLannahan note, JPMorgan, Bank of America, and Wells Fargo all expected to survive, albeit with stripped down businesses, while Citigroup, Morgan Stanley, and Goldman Sachs would essentially “cease to exist.”
That’s a pretty unimaginable scenario for a Wall Street king like Goldman Sachs. It’s so unbelievable, in fact, that we wonder whether the bank execs believe it could happen either.
Regardless, here are the highlights from the wills:
- The main bank, JPMorgan Chase Bank, N.A., would remain “open, funded, capitalised and operating,” but would shrink in size by one-third.
- Broker-dealer subsidies would also remain open but would shrink by two-thirds.
- J.P. Morgan Ventures Energy Corporation would be liquidated.
- The bank would still provide clients in the corporate, commercial and retail divisions with banking products and services.
- The global markets, or trading, division would be wound down or sold.
- Loan and deposit portfolios would be shrunk down.
- Consumer banking and global wealth and investment management would remain “core” businesses.
- Overall, the company would shrink in size from $US2.1 trillion to about $US1.2 trillion.
- The “surviving bank” would not wind down any particular subsidiaries or divisions, but rather shrink the entire institution to 30% of its current size.
- The bank would keep retail checking and savings accounts, payment services, credit cards, mortgage lending, and commercial lending — but it would discontinue retail brokerage products and services.
- Citigroup Parent would enter into bankruptcy proceedings.
- Broker-dealer entities would be wound down.
- Banking businesses would be “divested through a series of M&A transactions and initial public offerings, as well as asset sales.”
- Each business segment would follow the same path, and wind up “significantly smaller and less systemically important than Citi.”
- Morgan Stanley, too, would enter bankruptcy proceedings.
- While the parent company entered into insolvency proceedings, it would wind down or sell off subsidiaries, like the wealth management division and the institutional securities businesses.
- During bankruptcy proceedings, Goldman Sachs would sell off and wind down assets in an “orderly manner.”
- “At the conclusion of the resolution of GS Group, the firm would have sold or unwound all of its assets, and third-party creditors of our material entities, other than parent company stakeholders, would have been repaid in full.”