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Kevin Fromer

President and Chief Executive Officer

This week we learned that bank regulators may re-propose their rule to implement the Basel III Endgame in the United States.&nbsp; The potential changes were outlined in a <a href="https://www.federalreserve.gov/newsevents/speech/barr20240910a.htm">speech</a> by Federal Reserve Vice Chair for Supervision Michael Barr and were the first public explanation of the “broad and material” changes announced by him and Fed Chair Powell earlier in the year.As we await a re-proposal, it is worth considering some initial observations.First, it is important to consider the potential capital impact of 9 percent.&nbsp; In a world in which the largest U.S. banks are demonstrably very highly capitalized and strong, and in which the U.K. has announced its Basel III Endgame will result in an impact of less than 1 percent and the EU stands at 5.6 percent, we still fundamentally question why this proposal raises capital for U.S. banks, and why our policymakers would choose that outcome for the U.S. economy.&nbsp; Basel III Endgame was never intended to increase capital requirements. Given the array of strong prudential safeguards that have been enacted over the past 15 years, it is entirely unclear as to why any measurable increase in large bank capital is needed.&nbsp;Second, the process for reconsidering the proposal is an unusual one.&nbsp; We expect to see revisions that have been agreed by the Fed, the OCC, and the FDIC, but we will not see potential revisions of areas that are still being considered. Commenters will have to determine if their concerns were addressed and to what extent, or completely unaddressed.&nbsp; In addition, the re-proposal likely will be complex and lengthy.Third, the original proposal lacked critical economic analysis, including cost-benefit analysis, that is essential for the public to have and consider.&nbsp; Many decisions in the original proposal lacked justification, and for us, defied explanation.&nbsp; Hopefully, a re-proposal will address these serious shortcomings.The most meaningful changes previewed would alter the imposition of higher capital charges for certain credit exposures, equity exposures, and operational risk.&nbsp; What appears to be largely unaddressed, however, are very significant and higher charges for <a href="https://fsforum.com/a/media/basel-iii-endgame-market-making-requirement-threatens-liquidity,-economy,-and-financial-stability.pdf">exposures</a> associated with trading, market making, and underwriting.&nbsp; These activities are already subject to additional, stringent regulation post-financial crisis, including capital requirements.&nbsp; And they are no less important for the wide range of large companies, mid-market businesses, pensions, state and local governments and other institutions, like universities, which use the services of major banks to access capital, invest, grow and contribute to society. These bank customers serve people and businesses across the country, so not addressing these issues could, as experts have found, increase the costs or reduce the availability of the services they provide.In addition, the re-proposal appears to fall short of providing sensible capital requirements for lending to a wide swath of creditworthy businesses in the United States. The proposal of July 2023 provided a lower capital charge to corporates deemed to be “investment grade” if they are publicly traded (think General Motors), but would apply higher capital charges for companies that are arguably equally credit worthy but privately held (think Chick-fil-A).&nbsp; As we have pointed out, there are a relatively small number of publicly traded companies in the U.S., and many more private ones that would be subject to higher capital charges that are not justified by elevated credit risk.&nbsp; The re-proposal would carve out companies that are “regulated entities” like pensions and mutual funds, but everyone else – essentially non-financial companies – would still be subject to a higher capital treatment.&nbsp; There is no connection between whether a company is high risk or low risk and whether it issues publicly traded securities.&nbsp; If the re-proposal affirms this observation, we believe there will be significant interest in further work on this issue.We look forward to reviewing the re-proposal.&nbsp; It is important we get this right.

BankNotes Blog

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Despite the demonstrated strength of the largest U.S. banks, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, on split votes, issued a proposal in July 2023 to increase capital requirements. The proposal offers no reason or justification for material increases in capital requirements and would harm American households, businesses, and the broader economy. 

Given the complexity of the proposal, its many and significant negative impacts, and the lack of evidence in support of its changes, the agencies should repropose the rule and include the motivations, data and analysis that demonstrate the need for proposed changes.

Basel 3 Endgame 

Basel III Endgame: Where Things Stand

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Sean Campbell

Chief Economist, Head of Policy Research

<h3>Introduction</h3>In July, the Government Accountability Office (GAO) issued a <a href="https://www.gao.gov/assets/gao-24-106206.pdf">report</a> that examined the scope and quality of regulatory analysis performed by the three banking agencies (FDIC, Federal Reserve, OCC) in promulgating bank regulations.&nbsp; The report found that “the analyses regulators conducted for many of the 22 major capital and liquidity rules (issued 2012–2021) that GAO reviewed did not consistently reflect leading practices.”&nbsp; Further, the GAO also found that “they did not always identify alternative approaches or quantify benefits and costs.”&nbsp; The findings of this report are important in light of the pending Basel III Endgame proposal and deserve significant attention from the public.&nbsp; In this blog, we briefly review the report and its findings, and discuss the implications for the Basel III Endgame capital proposal.<h3>The GAO’s Key Findings and Recommendations</h3>The GAO report is highly detailed and specific, but the key findings in the report can be summarized as follows.First, the prudential agencies’ analysis did not always reflect key elements of good regulatory analysis.&nbsp; Importantly, the report states that the reviewed analyses did not always: 1) establish a baseline by indicating what would happen if the rule were not adopted, 2) consider and evaluate alternatives beyond the proposed regulation, and 3) assess the benefits and costs of a proposed regulation.&nbsp; Each of these elements is a critical aspect of good regulatory analysis that should be included in any rigorous analysis of a proposed regulation.&nbsp;&nbsp;Second, the Federal Reserve and FDIC did not consistently document the regulatory analysis that was conducted.&nbsp; In effect, the analysis that was included in the agencies’ public rulemakings were not “backed up” with any significant or detailed documentation explaining how or why certain conclusions were reached.&nbsp; In describing its finding, the GAO indicated that “the Federal Reserve’s documentation of its regulatory analysis (other than descriptions in Federal Register notices) did not consistently include information that would allow a qualified third party to understand the basic elements of its analysis.”&nbsp; This finding is particularly concerning as it casts doubt on the entire process by which regulatory analysis is conducted and decisions are reached.&nbsp; Put simply, if analysis is not sufficiently documented so that a qualified third party can understand how conclusions were reached, how can those conclusions be relied upon to support durable regulatory policy?Third, the agencies performed few retrospective reviews.&nbsp; In assessing whether a regulation is appropriate, it is critical to analyze the regulation on both a prospective and retrospective basis.&nbsp; Prospective reviews are critical, but are also, by their very nature, uncertain.&nbsp; Often, the impact of a rule will depend on future events that are difficult to forecast.&nbsp; This is where good retrospective analyses come into play.&nbsp; After a rule has been in place for a significant period of time, regulators should consider the impact of the rule as a means of cross-checking the initial prospective analysis.&nbsp; Such analyses have the potential to identify key areas for improvement that would have been difficult to identify before the regulation was put in place.As a result of these findings, the GAO made two specific recommendations to the Federal Reserve and OCC (no recommendations were made to the FDIC).<ol><li>Policies and procedures for consistently performing regulatory analyses that align with leading practices, including for documenting analyses, should be developed and implemented. (Recommendation made to the Federal Reserve)</li><li>Policies and procedures for systematically performing retrospective reviews of regulations should be developed and implemented. (Recommendation made to the Federal Reserve and OCC)</li></ol><h3>The Implications of the GAO Report for the Basel III Endgame Proposal</h3>As discussed, the GAO report did not include the Basel III Endgame proposal in its scope, but the GAO’s findings and recommendations are highly relevant to the Basel III Endgame (B3E) proposal.Importantly, as has been noted by a wide array of commenters including public interest groups such as the <a href="https://www.urban.org/research/publication/bank-capital-notice-proposed-rulemaking">Urban Institute</a>, the regulatory analysis contained in the B3E proposal is lacking in several respects, many of which were identified in the GAO report. &nbsp;A key limitation of the B3E proposal is that in many cases, the proposal simply provides no cost-benefit justification for the rule other than an unsupported assertion that the benefits outweigh the costs.&nbsp; As discussed in the GAO report, it is critical that the agencies fully explain the analysis and methods that they use to arrive at their conclusions and that the analysis provide sufficient data so that a qualified third party can ascertain how the conclusions are reached.Recently, Federal Reserve Chair Powell has discussed the possibility of a B3E re-proposal in light of the “broad and material” changes that are expected to be necessary in light of the received comments.&nbsp; In addition to re-proposing the rule, it is critical that any re-proposal of B3E be paired with an extensive cost-benefit analysis that adheres to the standards of good regulatory analysis identified in the GAO report.In order to achieve this result, it will be necessary that the GAO’s recommendations are adopted and fully implemented before any re-proposals are made to ensure that the important shortcomings identified by the GAO are fully addressed.Rigorous and transparent cost-benefit analysis is the hallmark of good, durable policymaking.&nbsp; The GAO report is important because it clearly identifies several key aspects in which banking agency regulatory analysis falls short of the mark.&nbsp; Adopting the GAO’s recommendations and fully implementing them in the context of any B3E re-proposal will help ensure that the resulting proposal is appropriate for the banking sector and the broader economy.&nbsp;&nbsp;The GAO report also identified the need to conduct regular, retrospective reviews of regulations.&nbsp; This finding is directly in line with previous statements of Federal Reserve officials that a “holistic review” of large bank capital standards would be conducted.&nbsp; Despite these statements, however, the B3E proposal was issued without first conducting a holistic, retrospective review of the existing large bank capital framework.&nbsp; The lack of a holistic review is itself highly problematic because of the large number of capital and related reforms that have been adopted since the financial crisis.&nbsp; Ultimately, it is not possible to assess the adequacy of the B3E proposal without first rigorously assessing the state of the current large bank capital framework with a holistic, retrospective review.Finally, the call for more regular retrospective reviews has wider implications well beyond B3E.&nbsp; As a specific example, the Federal Reserve has yet to perform a retrospective review of the GSIB surcharge as it indicated it would do when the rule was finalized in 2015.&nbsp; More broadly, the Federal Reserve has publicly committed itself to retrospectively <a href="https://www.federalreserve.gov/monetarypolicy/review-of-monetary-policy-strategy-tools-and-communications.htm">review</a> its monetary policy framework every five years.&nbsp; A similar, rigorous, review of the bank regulatory framework should be performed at a similar frequency.&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;<h3>Conclusion</h3>The recent GAO report makes important findings that should have a significant impact on the approach that banking regulators take to promulgating regulations.&nbsp; Several of the findings contained in the GAO report are directly relevant to the current B3E proposal.&nbsp; Specifically, the B3E proposal does not adequately quantify the costs and benefits of the proposal, and the proposal was not paired with a holistic, retrospective review of the large bank capital framework.&nbsp; Any future re-proposal of B3E should fully conform with the recommendations of the GAO report.&nbsp; A comprehensive cost-benefit analysis of B3E that holistically accounts for the existing large bank capital framework will result in a more grounded, appropriate and durable capital framework for large banks and the broader economy.&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp;&nbsp;&nbsp;&nbsp;

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The Forum advocates for appropriate policy and regulation that promotes a strong, diverse financial system and supports the needs of our economy and American competitiveness.

Regulatory, other topics 

Playing Catch Up on Cost-Benefit Analysis: Regulators Need to Up Their Game on Basel III Endgame

<h3>Introduction</h3>This Spring, Federal Reserve Vice Chair for Supervision Michael Barr gave a <a href="https://www.federalreserve.gov/newsevents/speech/barr20240520a.htm">speech</a> previewing some changes to large bank liquidity regulations that may be proposed by the banking agencies.&nbsp; In particular, the Vice Chair indicated that the “regulatory adjustments we are considering would ensure all large banks maintain better liquidity risk management practices going forward.”&nbsp; The largest banks, however, already maintain heightened liquidity risk management practices.&nbsp; In this post, we review the current requirements for Forum members (U.S. GSIBs), discuss the lack of any nexus between the regional bank turmoil of last Spring and the state of Forum members, and make some recommendations to ensure that any proposed liquidity regulations are appropriately targeted, thoughtful, and, critically, informed by data and analysis.<h3>SVB as a Pretext for Tighter U.S. GSIB Liquidity Regulation: A Shoe That Does Not Fit&nbsp;&nbsp;</h3>The events of Spring 2023 that resulted in the failures of Silicon Valley Bank (SVB) and Signature Bank and stirred turmoil among a variety of U.S. regional banking organizations have been cited on several occasions as evidence that all large banks need tighter regulations for liquidity, or the assets banks have available to quickly meet short-term obligations.&nbsp; Unfortunately, this assertion misapplies the lessons from last Spring and does not recognize the liquidity profile and regulatory framework for U.S. Global Systemically Important Banks, or GSIBs.The failure of SVB, Signature Bank and the turmoil that roiled some regional banks in 2023 had absolutely nothing to do with U.S. GSIBs.&nbsp; SVB and Signature were smaller regional banks that were not subject to the broad and extensive panoply of liquidity regulations that apply to U.S. GSIBs.&nbsp; More specifically, these regional banks, and other banks with similar size and activity profiles, were not and are not subject to:<ul><li>The most stringent form of the Liquidity Coverage Ratio (LCR) and Net Stable Funding Ratio (NSFR)</li><li>Resolution-based liquidity requirements (RLAP, RLEN)</li><li>A supervisory liquidity oversight program through the Federal Reserve’s Large Institution Supervision Coordinating Committee (LISCC) – only U.S. GSIBs are covered by the Federal Reserve’s <a href="https://www.federalreserve.gov/supervisionreg/large-institution-supervision.htm">LISCC supervisory program</a>.</li></ul>These requirements represent much more than an inscrutable regulatory alphabet soup.&nbsp; The extreme focus on U.S. GSIB liquidity since the financial crisis has had a transformative effect on the liquidity profile of U.S. GSIBs.&nbsp; To wit: consider the following chart and commentary from the Federal Reserve’s most recent Financial Stability <a href="https://www.federalreserve.gov/publications/files/financial-stability-report-20240419.pdf">Report</a>.<figure class="image"><img src="https://fsforum.com/a/media/8.8.24-blog.png"></figure>In particular, the Federal Reserve said regarding High Quality Liquid Assets (HQLA), “U.S. GSIBs continued to hold more HQLA (liquid assets) than required by the LCR – the requirement that ensures banks hold sufficient HQLA to fund estimated cash outflows for 30 days during a hypothetical stress event.”&nbsp; As the chart, and the statement in the Financial Stability Report clearly show, U.S. GSIBs maintain ample liquidity that is well ahead of other U.S. banks.&nbsp; In the face of such clear and unambiguous data, it is difficult to fathom why regulators would think that U.S. GSIBs require even stricter liquidity requirements.&nbsp;&nbsp;&nbsp;Finally, two specific events that unfolded during last year’s regional banking turmoil clearly demonstrate the liquidity strength of Forum members.&nbsp; First, as documented in <a href="https://libertystreeteconomics.newyorkfed.org/2023/05/bank-funding-during-the-current-monetary-policy-tightening-cycle/">research</a> conducted by the Federal Reserve, Forum members actually gained deposits during this period as households and businesses sought the safety and stability provided by Forum members with their high levels of capital, liquidity and overall resilience.&nbsp; Second, amid the unfolding turmoil, Forum members were called upon to help stabilize another struggling bank, First Republic, and contributed the majority of a $30 billion <a href="https://www.bankingdive.com/news/largest-banks-deposit-30b-in-ailing-first-republic-bank-JPmorgan-SVB-Wells-Fargo-contagion/645270/">liquidity injection</a> to First Republic to provide regulators more time to resolve the failing bank.&nbsp;The strong liquidity profile of Forum members as well as the actual events of Spring 2023 clearly indicate that U.S. GSIBs do not have any liquidity problems requiring redress.&nbsp; Rather, Forum members are a source of liquidity strength and resilience that supported the banking sector and the entire economy during that challenging period.&nbsp; Accordingly, any suggestion that the events of SVB “clearly show” a need for more and tighter liquidity regulation for Forum members is plainly inconsistent with the clear and incontrovertible facts from that event.<h3>A Way Forward on Liquidity Regulation</h3>Vice Chair Barr’s speech clearly indicates that regulators are preparing to suggest some important changes to bank liquidity regulation.&nbsp; The issues that regulators are considering are quite complex and would impact the entire economy.&nbsp; Accordingly, regulators should be committed to getting it right rather than getting it done.A precondition to getting it right is clearly defining the problem to be solved with due regard for differences in the state of liquidity profiles and liquidity regulation across the banking sector.&nbsp; Accordingly, before any new liquidity regulations are proposed, banking regulators should release a data-based, comprehensive analysis of the existing liquidity regulatory framework that clearly identifies the specific problem that needs to be addressed.&nbsp; Importantly, the report should clearly account for the graduated stringency of regulation that is applied to larger and larger banks with Forum members being subject to the most stringent liquidity requirements.&nbsp; The analysis and data used to arrive at its conclusions should be available for public comment.&nbsp;Recently, the banking sector has dealt with a capital proposal that was subsequently followed by a data collection that is being used to further define and refine the policy proposal.&nbsp; This approach has raised several legitimate and difficult to cure process concerns that should be avoided in the context of any future liquidity proposals.&nbsp; These process concerns can be squarely addressed by taking a systematic, thoughtful, and data-based approach to liquidity regulation that clearly communicates the specific problem at hand before any proposals are issued.&nbsp;&nbsp;Following the release of the analysis and a review of the comments, regulators may come to the view that changes to the liquidity regime are warranted.&nbsp; If that is the case, banking regulators should begin by first issuing an Advanced Notice of Proposed Rulemaking (ANPR).&nbsp; An ANPR is often used by regulators to thoughtfully engage with the public and seek information prior to issuing a specific proposal.&nbsp; The use of an ANPR gives regulators the opportunity to gather data and information that can be helpful in calibrating a regulatory proposal.&nbsp; Such public engagement is a hallmark of a deliberate and thoughtful regulatory process that puts “Getting it Right” ahead of “Getting it Done.”<h3>The Federal Reserve Should Put Discount Window Reform Ahead of Any New Regulation</h3>Finally, it is important to consider other important lessons from the recent regional bank turmoil.&nbsp; One clear lesson from the 2023 turmoil is that the Federal Reserve’s discount window is in serious need of reform.&nbsp; The events surrounding SVB revealed that the Federal Reserve’s <a href="https://www.federalreserve.gov/monetarypolicy/discountrate.htm">discount window operations</a> – which allow financial institutions to borrow from the Federal Reserve – have not kept pace with basic advancements in information technology that have transformed our whole economy in the past thirty years.&nbsp; An antiquated and largely manual discount window cannot possibly serve a modern banking system that is defined by sophisticated and highly automated information technologies.&nbsp; The deficiencies of the discount window are so glaring that Congress has offered <a href="https://www.warner.senate.gov/public/index.cfm/pressreleases?id=37CA4518-D604-41DB-B020-C8365668E702">legislation</a> to “reform the Federal Reserve’s discount window for the 21st century economy.”&nbsp; Launching a raft of new liquidity regulations before addressing longstanding and significant problems with the discount window would be a clear case of putting the cart before the horse.&nbsp; The discount window is an integral component of the bank liquidity landscape, so ensuring that it operates efficiently and effectively should be a precondition to any new regulation.&nbsp; &nbsp;A modernized and well-functioning discount window will itself improve bank liquidity throughout the entire banking sector and complement existing bank liquidity regulation.&nbsp;&nbsp;&nbsp; &nbsp;<h3>Conclusion</h3>Increasingly regulators are asserting that the large bank liquidity framework needs repair.&nbsp; The assertion is largely based on the idiosyncratic failure of a few smaller institutions last Spring that bear no resemblance in any way, shape, or form to Forum members.&nbsp; The use of that historical episode as a pretext for more stringent GSIB liquidity regulation is wholly inconsistent with the unambiguous facts concerning the liquidity profile of U.S. GSIBs and that unfortunate event.&nbsp; If regulators are determined to launch an effort to change the existing liquidity regime, they should begin by providing the public with a data-based and comprehensive analysis that clearly identifies the specific shortcomings that need to be addressed.&nbsp; Any subsequent proposals should be preceded by an ANPR to facilitate a deliberate and thoughtful approach to regulation that will prove to be appropriately calibrated and durable. Finally, regulators would do well to turn their attention to addressing clear deficiencies with the discount window before launching a raft of new and unproven liquidity regulations.&nbsp; &nbsp;&nbsp;&nbsp;&nbsp; &nbsp;&nbsp;&nbsp; &nbsp; &nbsp;&nbsp;&nbsp;

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The nation’s largest banks are subject to the most stringent liquidity standards among U.S. banks. These standards ensure that the largest U.S. banks have sufficient liquid resources, such as cash, to meet liquidity needs such as when customers withdraw money from their accounts. Since 2009, the U.S. GSIBs have tripled their liquid assets, allowing them to remain strong and continue to lend and support the economy in the face of headwinds.

Liquidity 

Getting It Right Before Getting It Done – Large Bank Liquidity Regulation

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to expand affordable homeownership opportunities for people in underserved communities.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts</h2>Abigail Suarez, Head of Community Development, Corporate Responsibility<h3>Describe how JPMorganChase is taking a holistic approach to addressing the housing crisis.</h3>As a firm, we’re committed to expanding economic opportunity and driving inclusive economic growth. When communities thrive, our business does, too. The housing crisis is complex and requires multifaceted solutions, which is why our strategy aims to tackle both housing supply and demand constraints. We are leveraging our philanthropic dollars, business practices, and policy expertise as part of a coordinated, holistic approach to make housing more accessible and affordable. To give a recent example: in an effort to expand homeownership opportunities for underserved communities, we announced a $20 million philanthropic commitment to non-profit organizations working to address this issue, expanded access to a consumer lending product that provides eligible customers with lower interest rates or down payment assistance, and published policy recommendations for <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/advancing-affordable-sustainable-homeownership.pdf">Advancing Affordable, Sustainable Homeownership</a>. Our combined resources and expertise enable us to deliver impact alongside our local partners.<h3>JPMorganChase recently released a paper on <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/tackling-persistent-residential-vacancy-blight-and-abandonment.pdf">Tackling Persistent Residential Vacancy, Abandonment, &amp; Disrepair</a>, which outlined place-based strategies to tackle housing supply. How are you implementing these strategies in your own work?</h3>&nbsp;Households across the country are struggling to find affordable places to live, but the solutions to this issue vary depending on the market—in some areas the answer is <a href="https://www.jpmorganchase.com/newsroom/stories/2024-housing-supply-solutions">increasing housing production</a>, while other areas may need strategies to reactivate vacant or abandoned homes as safe places to live. This paper on residential vacancy is part of our What Works series, which shares insights and lessons learned drawn from our experience working with public, private and community partners to drive inclusive economic growth. The paper discusses the importance of&nbsp; building local capacity to address housing affordability challenges, a principle reflected in a $6 million commitment we made in Baltimore to increase affordable homeownership and stabilize housing supply. Our approach is informed by over half a decade of partnership with local city organizations and leaders who are finding innovative approaches to reduce the number of vacant homes in Baltimore. Working in silos is rarely effective, and we’re proud to show up in local communities as listeners and partners to tackle big challenges and catalyze progress.<h3>Another obstacle to homeownership is the problem of heirs property. Why is tackling heirs property important and what is JPMorganChase doing to address it?</h3>Homeownership is a primary means of building and passing wealth across generations—however, the issue of heirs property puts this at risk. Heirs property occurs when a homeowner dies without a will and their property is informally inherited by multiple descendants. Left unaddressed, this unstable homeownership status compromises the ability of residents to pass the property on to descendants and makes them vulnerable to foreclosure or a forced sale. To address this issue, we announced more than $9 million in philanthropic funding to support free legal assistance, estate planning services, and appraisal reform in underserved communities, as well as highlighted support for state and federal policy reforms to address this issue.&nbsp;We also published papers on <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/supporting-heirs-property-owners-through-natural-disaster-and-resiliency-programs.pdf">Supporting Heirs Property Owners Through Natural Disaster and Resiliency Programs</a> and <a href="https://www.jpmorganchase.com/content/dam/jpmc/jpmorgan-chase-and-co/documents/addressing-the-undervaluation-of-property.pdf">Solutions to Build Household Wealth by Addressing the Undervaluation of Property</a> to amplify insights and recommendations informed by our business, philanthropic, and policy expertise. By addressing the problem of heirs property, we can help more individuals benefit from the generational wealth-building power of homeownership.<h2>Value Add</h2>JPMorganChase announces plans to expand access to consumer, business and community banking services for customers across Iowa<figure class="image image_resized" style="width:82.6%;"><img src="https://fsforum.com/a/media/chase-heartland.png"></figure>JPMorganChase has committed to open more than <a href="https://media.chase.com/news/chase-makes-multi-billion-dollar-investment-in-its-branch-network">500 new branches, renovate approximately 1,700 locations and hire 3,500 employees across the country over the next three years</a>. This multi-billion dollar commitment will contribute to local economic growth through construction, ongoing community investments and local hiring, bringing opportunity to thousands of local residents.&nbsp;<a href="https://www.cnbc.com/2024/08/05/jpmorgan-chase-opens-more-small-town-branches-in-middle-america.html">As part of this nationwide expansion</a>, CEO Jamie Dimon, senior leaders from across the firm, community partners, employees and elected officials came together in Des Moines to announce the <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/jpmorganchase-expands-banking-services-in-iowa">expansion of the firm’s services to customers and communities across Iowa</a>. The firm’s Iowa footprint will expand from eight branches to more than 30 across the state by 2030, including new branches in Des Moines, Waterloo, Cedar Rapids, Sioux City, Iowa City and Ames. This commitment&nbsp;is part of the firm’s broader goal to serve 50% of the population in each of the 48 contiguous states within an accessible drive time and builds on 39 years of support for clients and communities in Iowa.<h2>Capital Gains</h2>What we’re doing in WashingtonForum President and CEO Kevin Fromer <a href="https://fsforum.com/news/forum-comments-on-reconsideration-of-capital-regulations">issued</a> a statement following Federal Reserve Vice Chair for Supervision Michael Barr’s remarks on U.S. capital regulations. “We look forward to reviewing the revisions and participating fully in the public comment process. Getting this right is essential for the U.S. economy,” Fromer said.<h2>Our Two Cents</h2>Research from the ForumThe BankNotes Blog Spotlighted:<ul><li>A report from the Government Accountability Office on the banking agencies’ regulatory analysis, which <a href="https://fsforum.com/news/playing-catch-up-on-cost-benefit-analysis-regulators-need-to-up-their-game-on-basel-iii-endgame">emphasizes</a> significant implications for finalizing the Basel III Endgame capital proposal.</li><li>The strong liquidity profile of Forum members and the need for thoughtful and data-based analysis before <a href="https://fsforum.com/news/getting-it-right-before-getting-it-done-large-bank-liquidity-regulation">proposing</a> new liquidity regulations for large banks.</li><li>A proposal by the Federal Reserve and global regulators through the Basel Committee on Banking Supervision to <a href="https://fsforum.com/news/gsib-scores-and-window-dressing-where-is-the-smoking-gun">increase</a> the cost and burden of GSIB score reporting, which is not supported by regulatory data on both GSIBs and non-GSIBs.</li></ul><h2>Checking the Balance</h2>Members in the NewsBank of America <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/07/bofa-celebrates-20-years-of-paid-summer-internship-program---stu.html">celebrated</a> two decades of supporting youth employment and economic opportunity through its signature philanthropic program, Student Leaders. The program has provided 4,500 students with work experience and leadership skills to help build future careers.BNY <a href="https://urldefense.com/v3/__https:/america250.org/news/america250-announces-first-ever-americas-field-trip-awardees/__;!!OiWDNh-9Pw!9ZfEqv9afxrLbGkEk59IdvjAw0JIn1F--1LTM1BDv5vMT2GbGhkwUt2qHWx4cskmLbNY2vmSRZo1KTU$">sponsored</a> America250’s “America’s Field Trip,” a nationwide scholastic contest encouraging students to reflect on what America means to them. The firm helped bring 75 students from 27 states and territories to the nation’s most historical and cultural landmarks including the New York Headquarters of BNY, the country’s oldest bank.Citi’s latest Securities Services Evolution whitepaper focuses on the next frontier for the industry with the growing applicability of technologies, including distributed ledger technology and digital assets, and the significant potential for tokenization. <a href="https://www.linkedin.com/posts/citi_securities-services-evolution-2024-disruption-activity-7236977206336401409-rIAX">Watch an explainer video</a> and read more on these developments that continue to transform the securities landscape <a href="https://www.citibank.com/icg/docs/Citi_Securities_Services_Evolution_2024.pdf?linkId=575991464">in the whitepaper</a>.Goldman Sachs 10,000 Small Businesses <a href="https://urldefense.com/v3/__https:/www.al.com/news/birmingham/2024/09/goldman-sachs-commits-3-million-to-boost-alabamas-small-rural-businesses.html__;!!O2kDR7mm-zSJ!tPfgEVHyVMku67u8Cx4uOF0ywOCofLR2DfFmxS2BzokhfvFOYXgNQH4C-BAS6r0xi7_JESNJCLAQFBSj$">announced</a> an expansion of the program to Alabama, which includes a $3 million commitment to community development financial institutions focused on small businesses, and marks the initiatives fifth launch state to date – on track to meet its goal of reaching 20 states in five years.JPMorganChase <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/jpmorganchase-unidos-philanthropic-commitment">announced</a> joint policy recommendations and a $6 million commitment to UnidosUS focused on building organization capacity and supporting homebuyer readiness, expanded access to credit, increased housing supply, and the preservation of Latino homeownership.Morgan Stanley celebrated the 2024 graduates of its <a href="https://www.morganstanley.com/about-us/supplier-diversity/small-business-academy1">Small Business Academy</a>, a partnership between its Supplier Diversity Program and the Institute for Inclusion. Through 12 weeks of instructor-facilitated learning and a year-long mentorship program, the Academy enables small businesses to differentiate themselves in the procurement process, strengthen their business acumen and expand their professional networks.State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2024/State-Street-Announces-Issuance-of-1-Billion-of-Senior-Debt/default.aspx">announced</a> an issuance of $1 billion of senior debt, which includes five broker-dealers owned by underrepresented groups who have underwritten 40% of the securities in the issuance.Wells Fargo <a href="https://stories.wf.com/wp-content/uploads/2024/07/Open-for-Business-Fund-Impact-Report-Fact-Sheet.pdf">shared</a> its recent community impact report of the company’s Open for Business Fund, a roughly $420 million national small business recovery effort to help those hardest hit during and after the COVID-19 pandemic. Launched in 2020, grantees report the Open for Business Fund has now benefited more than 336,000 small businesses, empowering them to keep or create more than 461,000 jobs in communities across the nation.

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The Forum File, 2024 Edition #5

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to support underrepresented entrepreneurs.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts&nbsp;</h2>Selma Bueno is the Global Head of Morgan Stanley’s Inclusive Ventures Group<h3>Tell us about the Morgan Stanley Inclusive Ventures Lab and what makes it unique.</h3>The <a href="https://www.morganstanley.com/about-us/diversity/inclusive-ventures-lab">Morgan Stanley Inclusive Ventures Lab</a> was launched in 2017 to advance a more equitable investment landscape. We run a five-month accelerator program for founders of technology and technology-enabled startups in the seed to Series A funding round stage to develop and scale their businesses. In 2021, we expanded the Lab from North America to Europe, the Middle East and Africa, enabling us to support even more innovation and inclusion globally.&nbsp;What makes our program unique is its holistic approach to supporting portfolio companies. We invest $250,000 in each business, as well as provide a tailored curriculum, mentorship, networking, office space for the duration of the program and access to external advisors.To date, 92 companies, with a combined valuation of $923 million, have been through our accelerator program. The founders have collectively raised over $200 million in additional funding since their participation in the Lab.<h3>How does the Lab’s work align with Morgan Stanley’s Core Values?</h3>At Morgan Stanley, we are guided by five Core Values: do the right thing; put clients first; lead with exceptional ideas; commit to diversity and inclusion; and give back. I am proud to lead an initiative that integrates each of our values.The Lab was created to help shift the investment landscape and level the playing field for underrepresented entrepreneurs because it is the right thing to do, both for the founders we support and for the marketplace as a whole. By spotlighting innovative companies and giving them the platform and network they might need help accessing, we are driving innovation in business broadly.Our Lab’s cohort companies receive the full suite of Morgan Stanley resources and an ecosystem of internal and external partners to provide much-needed investment and guidance – as any client would. In connecting the founders with mentors and with one another, we are building a community in which previously overlooked entrepreneurs can succeed.<h3>Can you tell us how some of the Lab companies are driving inclusivity in the marketplace themselves?</h3>Many of our founders are leveraging their diverse backgrounds and communities’ values to address important gaps in the market and, in turn, advance a more equitable society.Some companies are working to tackle the critical issue of inequity in healthcare, like <a href="https://healthinherhue.com/">Health in Her HUE</a>, which connects Black women and women of color to culturally sensitive healthcare providers and <a href="https://www.gomedhaul.com/">MedHaul</a>, an online marketplace for healthcare providers to book non-emergency medical transportation for patients, based on their special needs.In the education tech space, <a href="https://imagilabs.com/">imagi</a> is using proprietary, inclusive education tools to empower kids to code, increase engagement among girls and help close the gender gap in tech early on.And <a href="https://www.zirtue.com/">Zirtue</a>, a relationship-based lending app that simplifies loans between friends and family, is making it easier than ever for people to access funds by tapping into the power of community support.What all of our cohort companies have in common, regardless of industry or product offering, is the founders’ innate desire to build a better world.&nbsp;<h2>Value Add</h2><figure class="image"><img src="https://fsforum.com/a/media/ivl-founders_crop-(002).jpg"></figure>The Inclusive Ventures Lab Demo Day is our annual showcase where founders can put all they have learned in the accelerator program to the test and raise their profiles with potential investors, business partners and customers.We hosted our ninth Demo Day in February for our largest audience yet of portfolio companies and potential investors. The investment firms in attendance represented over $40 billion of dry powder and indicated a high level of interest in the startups following the event.This latest showcase emphasized both market connectivity, with AI and sustainable solutions as cross-cutting themes, and the sheer range of innovation in our Lab, with companies representing industries such as healthcare, customer service, supply chain, recruiting and cybersecurity.In today’s challenging funding environment, it is incredibly important that we can provide our participating founders with the opportunity to attract capital, expand their networks and bring their game-changing products to scale.<h2>Capital Gains</h2>What we’re doing in Washington<figure class="image image_resized" style="width:79.95%;"><img src="https://fsforum.com/a/media/picture9.jpg"></figure>Forum Chief Economist Sean Campbell <a href="https://fsforum.com/news/icymi-transparency-in-stress-testing-essential-to-achieving-a-more-effective-efficient-and-resilient-financial-system">testified</a> before the House Financial Institutions and Monetary Policy Subcommittee on the need for greater transparency in the stress testing process. “Aligning stress tests with the public process afforded other bank regulatory standards would help improve public trust, promote economic stability, and ensure banks can support the economy to their fullest potential,” Dr. Campbell told lawmakers. Read Dr. Campbell’s full testimony <a href="https://fsforum.com/a/media/forum-dr.-sean-campbell-testifies-on-stress-testing_6.26.24.pdf">here</a> and learn more about stress testing <a href="https://fsforum.com/a/media/stress-testing-for-the-largest-us-banks.pdf">here</a>.&nbsp;Forum President and CEO Kevin Fromer <a href="https://fsforum.com/news/stress-tests-underscore-capital-strength-of-nation-s-largest-banks">issued</a> a statement in response to the Federal Reserve Board’s 2024 stress test results. “The results affirm that the additional capital requirements in the Basel III Endgame proposal are not justified,” Fromer said.The Forum <a href="https://fsforum.com/news/basel-changes-to-capital-surcharge-calculation-unwarranted">submitted</a> a comment letter on the proposed revisions to the methodology for capital surcharges for Global Systemically Important Banks to the Basel Committee on Banking Supervision. “Financial regulations that are not appropriately calibrated result in an inefficient financial system that misallocates capital in a way that can have a detrimental effect on the businesses and households that our member institutions serve, and on the U.S. and global economies as a whole, with no clear corresponding benefit to the resilience of the financial system,” the Forum said.<h2>Our Two Cents&nbsp;</h2>Research from the ForumThe Forum <a href="https://fsforum.com/a/media/forum-value-and-resiliency2024_q1.pdf">released</a> its latest data on the value and strength of the nation’s largest banks.<h2>Checking the Balance</h2>Members in the NewsThe Bank of America Boston Marathon Official Charity Program <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/05/128th-boston-marathon--presented-by-bank-of-america-raises-recor.html">raised</a> $45.7 million, contributing to the marathon’s record total of $71.9 million in charitable funds raised this year. The funds went toward nearly 160 non-profit organizations in the Greater Boston community.BNY <a href="https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fwww.bnymellon.com%2fus%2fen%2fabout-us%2fnewsroom%2fcompany-news%2fthe-bank-of-new-york-mellon-corporation-introduces-updated-brand-bny.html&amp;c=E,1,klT35NUTsdUE8BdfT4UgWK1NuEOweXGzypcGVvsnG3INnu37FDoIoScI-Qc2tEiUAfOJodmwKYFxO1EsM5Re-Xc9fYsphx-mJKI0KwjsK55IQDvc&amp;typo=1">introduced</a> its new brand name and logo. The updated brand marks the firm’s evolution from America’s oldest bank, formerly known as BNY Mellon, to a global financial services leader.Citi Global Perspectives and Solutions <a href="https://www.citigroup.com/global/insights/citigps/ai-in-finance">published</a> a new report on AI &amp; Finance: Bot, Bank &amp; Beyond. The report analyzes the role that artificial intelligence might play in changing the way both consumers and companies bank.Goldman Sachs <a href="https://www.goldmansachs.com/our-firm/history/ipo-anniversary/index.html">commemorated</a> the 25th anniversary of its initial public offering. The firm’s leaders from past and present convened to ring the bell at the New York Stock Exchange.JPMorgan Chase <a href="https://www.jpmorganchase.com/newsroom/press-releases/2024/baltimore-philanthropic-commitment">announced</a> an $8.45 million philanthropic commitment to nonprofit organizations and programs across the city of Baltimore to support economic and community development. The funding addresses residential vacancies to stabilize the affordable housing supply, supports commercial corridor revitalization, and promotes small business growth.Morgan Stanley Foundation <a href="https://www.morganstanley.com/press-releases/morgan-stanley-foundation-8-million-grant-to-feeding-america#:~:text=Morgan%20Stanley%20(NYSE%3A%20MS),among%20children%20and%20underserved%20populations.">announced</a> an $8 million grant over four years to Feeding America to support the establishment or expansion of child and family feeding programs. Since 2009, Morgan Stanley’s funding for Feeding America has totaled more than $50 million, helping to deliver more than 356 million meals to children and families.State Street <a href="https://www.statestreet.com/us/en/asset-owner/insights/2024-markets-and-financing-research-retreat">hosted</a> its 2024 Markets and Financing Research Retreat. In collaboration with academic partners, guest speakers and strategists, the event dissected market trends, inflation, and other proprietary data-driven indicators.Wells Fargo Foundation <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2024/100-Black-Men-of-America-and-Wells-Fargo-Expand-Junior-Investment-Club-with-600000-Grant/default.aspx">granted</a> $600,000 to 100 Black Men of America, a youth mentorship organization. This grant helps expand the organization’s Junior Investment Club, a curriculum-based simulation game that introduces young people to investing.

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The Forum File, 2024 Edition #4 

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting one bank’s work to help close the racial wealth gap and increase economic mobility for communities of color across the nation.We hope you enjoy reading this edition and please do not hesitate to share your feedback.Kevin Fromer, President and CEO, Financial Services Forum<h2>Penny for Your Thoughts</h2>Harold Butler is the head of Citi’s Diverse Financial Institutions Group<h3>Why did Citi set up a specific group to lead its work with diverse financial institutions?</h3>At Citi, our mission is to enable economic growth and progress. One of the most meaningful ways we are bringing this mission to life is through our commitment to help close the racial wealth gap and increase economic mobility for communities of color in the U.S.I have the privilege of leading Citi’s Diverse Financial Institutions Group – also known as DFIG – which helps institutionalize our company’s commitment to racial equity and serves as a centralized hub to lead and expand our engagement with diverse financial institutions.We know that diverse financial institutions are central to the financial services ecosystem. They are the trusted source of banking and access to capital for many communities across the country. At Citi, we are committed to supporting and strengthening these organizations to help scale this work.<h3>How does DFIG fit into Citi’s approach to using business integration to help address the racial wealth gap?</h3>We know from <a href="https://www.citigroup.com/global/insights/citigps/closing-the-racial-wealth-gap">our own research</a> that the mission of closing the racial wealth gap also presents great economic opportunity both for our country and for firms like Citi that lean into the upside. But we also knew making progress would require us to be intentional about our efforts and make a shift from a short-term, time-bound commitment to a longer-term outlook.By integrating DFIG into Citi’s Markets business, we are enabling Minority Depository Institutions (MDIs) and diverse broker-dealers to get involved in transactions that will grow fee and interest income for these firms. DFIG connects them with the right people at Citi who can make introductions and open up the chance for these firms to play a role in certain capital markets transactions where they might not typically have access or exposure. Citi’s DFIG is unique among Wall Street firms in playing this type of role.<h3>What brought you personally to this work?</h3>I didn’t cut my teeth as a banker. I worked on the sales side in technology at Freddie Mac and Microsoft before transitioning to banking. A professional connection brought me to Citi and I’m a big believer in building a business or a career through relationships with trusted professionals.I got into the DFIG work because we were trying to help one of Citi’s largest clients meet a goal it had related to inclusion for its suppliers. I saw a chance to leverage some of the relationships I cultivated over time to help our client achieve its goals. This helped to fuel what is now DFIG.<h3>How has this work progressed over the last couple of years since Citi originally launched DFIG in 2022?</h3>I know that the day-to-day engagements in Citi DFIG are contributing to closing the racial wealth gap. It is obviously going to take time, but we can feel things are changing. The 13 MDIs that Citi is supporting through equity investments are now positioned better than they’ve been in 40 years. That’s saying something.We’ve learned a lot over the past few years about the challenges many underserved communities are facing. That information empowers us to think about how we do business differently. Banks are the heartbeat of communities. Much like the heart pumps blood to the different parts of the body, investments in communities act much the same way and banks are the catalyst for making that happen.<h2>Value Add</h2>Citi Convenes Executives and Policymakers for DFIG Summit<figure class="image image_resized" style="width:100%;"><img src="https://fsforum.com/a/media/jane-and-steve-benjaminv2.jpg"></figure>The second annual Citi DFIG Executive Summit brought together leaders from more than 80 MDIs and diverse broker dealers and asset managers at the Landsdowne Resort in Leesburg, Virginia, in early May. After launching the summit last year at Citi’s headquarters in New York, the second edition held closer to the nation’s capital enabled several policymakers to participate and share their perspectives on the government’s role in advancing this work.Citi CFO Mark Mason kicked off the conversation in a fireside chat with U.S. Treasury Deputy Secretary Wally Adeyemo while Citi CEO Jane Fraser and Steve Benjamin, Senior Advisor to the President and Director of the White House Office of Public Engagement, spoke to attendees over lunch. Finally, U.S. Deputy Commerce Secretary Don Graves sat down with Jarryd Anderson, co-chair of the Financial Services Group at Paul, Weiss, to talk about the public-private partnership to advance economic growth.Participants also heard from Citi leaders and other outside experts on industry trends, training platforms and innovative solutions to common challenges. Breakout sessions tailored to participant interests and social components of the programming fostered the networking and collaboration that are pillars of the DFIG approach.This annual gathering serves to further drive Citi DFIG’s mission of working with our partners to create revenue-generating opportunities, share expertise, and drive an even greater impact in diverse communities.<h2>Capital Gains</h2>What we’re doing in WashingtonIn our latest BankNotes Blog, Forum Chief Economist and Head of Policy Research, Sean Campbell, <a href="https://fsforum.com/news/federal-reserve-financial-stability-report-underscores-strength-of-america-s-largest-banks-and-wayward-regulatory-policy">examined</a> how the Federal Reserve’s Financial Stability Report underscores the strength of the nation’s largest banks through their strong levels of capital and liquidity. “The Federal Reserve and other regulators should take stock of its own financial stability assessment as they chart the course for regulatory reform,” Campbell wrote.The Forum <a href="https://fsforum.com/a/media/fsf_factsheet_impact-on-muni-bonds.pdf">released</a> a fact sheet on Basel III Endgame’s impact on municipal bonds.<h2>Our Two Cents</h2>Research from the ForumThe Forum <a href="https://fsforum.com/a/media/forum-value-and-resiliency_2023q4.pdf">released</a> its latest data on the value and strength of the nation’s largest banks.<h3>Checking the Balance</h3>Members in the newsBank of America <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2024/03/new-bofa-platform-connects-small-businesses-to-cdfi-capital-and-.html">launched</a> a new Access to Capital Connector, an online platform designed to connect entrepreneurs and small business owners to local Community Development Financial Institutions and other business support organizations.BNY Mellon <a href="https://www.bnymellon.com/us/en/about-us/newsroom/press-release/bny-mellon-collaborates-with-accenture-to-drive-accelerated-growth-for-clients-130384.html">collaborated</a> with Accenture, a leading professional services company, to modernize financial services offerings and help their joint clients drive growth.Citi CEO Jane Fraser <a href="https://www.cnbc.com/2024/05/07/biden-set-to-meet-with-executives-from-citi-united-airlines-others.html">joined</a> other business executives in a White House meeting with President Biden to discuss the economy with a focus on supporting businesses and workers.Goldman Sachs <a href="https://www.goldmansachs.com/media-relations/press-releases/2024/fourth-annual-market-madness-competition.html">held</a> its fourth-annual Market Madness competition, a program dedicated to supporting students at Historically Black Colleges and Universities and granted $1 million to Spelman College.JPMorgan Chase <a href="https://www.jpmorganchase.com/news-stories/20million-housing-affordability-commitment">announced</a> $20 million in new philanthropic funding to eight organizations across the U.S. working to expand homeownership opportunities for underserved communities. Additionally, the firm is expanding its Chase Home Lending program, increasing the homebuyer grant from $5,000 to $7,500 in 8,500 neighborhoods across the U.S.Morgan Stanley <a href="https://www.morganstanley.com/press-releases/morgan-stanley-strengthens-alliance-for-children-s-mental-health">announced</a> a $20 million commitment over the next five years to its Alliance for Children’s Mental Health, bringing the firm’s total funding to $50 million since launch in 2020. The Alliance will strengthen its work delivering programming and research, as well as advancing solutions through its Innovation Awards.State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2024/State-Street-Earns-MLTs-Hispanic-Equity-at-Work-Bronze-Certification-and-Black-Equity-at-Work-Bronze-Recertification/default.aspx">earned</a> the Hispanic Equity at Work Bronze Certification and the renewal of its Black Equity at Work Bronze Certification by Management Leadership of Tomorrow, a non-profit dedicated to advancing racial equity in the workplace.Wells Fargo Home Lending <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2024/Wells-Fargo-Expands-Down-Payment-Grant-Program-to-Help-Bridge-Homeownership-Gap/default.aspx">expanded</a> its $10,000 Homebuyer Access grant program to additional communities in the eight metropolitan areas where the program was launched in 2023. This expansion provides greater opportunities for Black and Hispanic homebuyers and helps increase homeownership for underserved communities.&nbsp;

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The Forum File, 2024 Edition #3

The Forum File

CONTACT: Laura Peavey(202) 457-8770lpeavey@fsforum.com&nbsp;Forum Responds to FDIC Request for Information on DepositsThe Forum urges the FDIC for a data-driven assessment on bank deposits before pursuing regulatory changes.Washington, D.C. – The Federal Deposit Insurance Corporation (FDIC) should engage in a comprehensive, data-driven assessment of bank deposits before proposing any regulatory change, the Financial Services Forum told the agency Friday.Responding to a Request for Information (RFI) on deposits issued by the FDIC, the Forum outlined several areas for the agency to engage in its confidential supervisory collection and analysis process. In addition, the Forum suggested broadening publicly available data on operational deposits in the Call Report, which would help improve public transparency on deposit funding in the banking sector.The Forum also noted that the RFI is motivated by and devotes significant attention to the March 2023 regional bank failures. In its submission, the Forum provided context to these events and highlighted that Forum members – the eight U.S.-based Global Systemically Important Banks – operate strong balance sheets with ample liquidity and have been a source of strength in times of financial market stress, including during the March 2023 banking turmoil.“The Forum strongly believes that the current proposal to modify the existing brokered deposit rule must be accompanied by a detailed, data-based analysis of the characteristics and risks of the affected deposits before the proposal is moved forward,” Forum President and CEO Kevin Fromer said. “Importantly, such data and analysis must inform any future proposed changes to the regulatory treatment of these or other deposit types.”The Forum’s full letter can be found <a href="https://fsforum.com/a/media/rfi_fsf_response_final.pdf">here</a>.&nbsp;###The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve&nbsp;millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. Visit our website:&nbsp;<a href="http://www.fsforum.com/">fsforum.com</a>Follow us on Twitter&nbsp;<a href="https://twitter.com/fsforum">@fsforum</a>&nbsp;and&nbsp;<a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>&nbsp;

Press Releases

Forum Responds to FDIC Request for Information on Deposits

CONTACT:&nbsp;Barbara Hagenbaugh(202) 457-8783bhagenbaugh@fsforum.com&nbsp;Forum Welcomes Laura Peavey to Communications TeamFormer House Financial Services Committee communications director to serve in key role working with media and external stakeholdersWashington, D.C. – The Financial Services Forum announced that Laura Peavey today has joined the organization as Director of Media and Outreach.“Laura has a clear wealth of financial policy knowledge and a strong communications background after working for nearly a decade on Capitol Hill in leading communications roles,” Forum President and CEO Kevin Fromer said. “We are excited for her to join the Forum team representing the nation’s largest banks in Washington.”Peavey previously was the Communications Director of the House Financial Services Committee, where she served as the primary, on-the-record spokeswoman for Chairman Patrick McHenry (R-NC) and the majority members of the committee. In that role she worked with members of the media across the country, developed communications strategies to build awareness about legislative priorities, and managed the communications team. She led the committee’s communications response during a number of defining moments, including the Covid pandemic, the GameStop short squeeze, the FTX collapse, the March 2023 banking turmoil, debt ceiling negotiations, and Chairman McHenry’s service as Speaker Pro Tempore. &nbsp;Prior to her role on the committee, Peavey served as press secretary for the House Rules Committee, as deputy press secretary for Sen. Joni Ernst (R-IA) and as a press assistant for Rep. Michael Burgess (R-TX).A Texas native, she holds a degree from The Mayborn School of Journalism at the University of North Texas.&nbsp;###&nbsp;The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States.&nbsp; Forum member institutions are a leading source of lending and investment in the United States and serve&nbsp;millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. Visit our website: <a href="http://www.fsforum.com/">fsforum.com</a>Follow us on Twitter <a href="https://twitter.com/fsforum">@fsforum</a> and <a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Forum Welcomes Laura Peavey to Communications Team

CONTACT: Barbara Hagenbaugh(202) 457-8783bhagenbaugh@fsforum.com FDIC Proposed Rule on Brokered Deposits is UnwarrantedProposed changes to brokered deposit regulations would unnecessarily reverse recently established policy, disrupt stable, long-term deposit relationships, and harm the economyWashington, D.C. – A proposed rule from the Federal Deposit Insurance Corporation (FDIC) to amend its regulations related to brokered deposits would lead to higher costs for consumers and businesses across the economy, the Financial Services Forum said Thursday.Brokered deposits are funds collected by a broker from multiple customers and deposited into a bank. As financial institutions navigate market challenges, brokered deposits play a vital role in diversifying funding sources and enhancing overall stability. In 2020, the FDIC significantly modernized its brokered deposits regulations following a multi-year comment period. If adopted, the proposed rule would reverse recently established policy without adequate reasoning or justification, potentially destabilizing the brokered deposit marketplace and creating unnecessary costs to the economy.In a letter to the FDIC, the Forum stated that reversing existing rules would disrupt long-established arrangements. The proposed rule would impose significant costs to the banking sector, including the U.S. Global Systemically Important Banks, which are subject to the most stringent prudential requirements. That would ultimately result in higher costs for consumers and businesses and act as a drag on the economy as a whole.“This rapid reversal of existing regulatory practices would impede the practice of safe and sound banking by reducing consistency and transparency surrounding the FDIC’s expectations,” Forum President and CEO Kevin Fromer said. “The FDIC should not engage in such a broad rulemaking that would unnecessarily destabilize its own recently settled approach without first understanding the potential costs and benefits of the Proposal.”The Forum’s full letter can be found <a href="https://fsforum.com/a/media/fsf---brokered-deposits-comment-letter.pdf">here</a>.&nbsp;The Forum also joined a letter on the topic with The Bank Policy Institute, American Bankers Association, U.S. Chamber of Commerce, Financial Technology Association, Independent Community Bankers of America, and Securities Industry and Financial Markets Association. The full letter can be found <a href="https://fsforum.com/a/media/joint-trades-brokered-deposits-comment-letter-11.20.24.pdf">here</a>.&nbsp;###The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve&nbsp;millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. Visit our website:&nbsp;<a href="http://www.fsforum.com/">fsforum.com</a>Follow us on Twitter&nbsp;<a href="https://twitter.com/fsforum">@fsforum</a>&nbsp;and&nbsp;<a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

FDIC Proposed Rule on Brokered Deposits is Unwarranted

This op-ed was featured in <a href="https://www.americanbanker.com/opinion/basel-myths-are-all-too-real-for-the-financial-services-industry">American Banker</a>.&nbsp;To the editor,In a recent BankThink ("<a href="https://www.americanbanker.com/opinion/debunking-the-myths-about-the-basel-iii-endgame-regulation">Debunking the myths about the Basel III endgame regulation</a>," Jan. 18, 2024), the author is absolutely correct that the conversation about the possible increase in capital requirements must be based on facts. But from the very first sentence, the piece is filled with inaccuracies.First, just a<a href="https://www.bis.org/bcbs/implementation/rcap_reports.htm"> handful</a> of countries have implemented the agreement struck in Basel, Switzerland, in 2017. Like the United States, most of the jurisdictions around the world are at various stages of creating their rules. Thus far, the United States is proposing to increase capital to a<a href="https://fsforum.com/a/media/key-takeaways-b3e-comments.pdf"> much larger degree</a> for its global systemically important banks (GSIBs) than other jurisdictions. The U.K. is proposing a 3.2% increase for its GSIBs versus a 5.6% increase for the EU and an estimated 30% for U.S. GSIBs. The U.S. proposal's many inconsistencies with the international Basel agreement and Basel III endgame proposals in other jurisdictions would worsen, rather than improve, already substantial international discrepancies in capital requirements. Such divergences would harm the American economy and the ability of U.S. companies to compete internationally. So much for the stated goal of harmonizing international capital rules.Second, the implementation of the Basel III endgame for the largest U.S. banks has absolutely nothing to do with the regional banking turmoil last year. To the contrary, because of their strong capital positions, the largest U.S. banks were called upon by the government to step in and support the financial sector in March, putting billions of dollars of unsecured deposits into First Republic Bank to squelch contagion and give the Federal Deposit Insurance Corp. time to wind down the ailing institution.Federal Reserve Chair Powell has<a href="https://www.youtube.com/watch?v=627kC040sPU"> said</a> repeatedly that the nation's largest banks are "very strong" and a "source of strength." The largest U.S. banks have supported small and large businesses, households and communities, and helped to ensure smooth functioning financial markets during significant economic headwinds, such as the COVID-19 pandemic. In the past 15 years, U.S. GSIBs have more than tripled their common equity tier 1 capital to more than $900 billion. The largest U.S. banks also are subject to annual supervisory stress testing and have maintained capital<a href="https://www.federalreserve.gov/newsevents/pressreleases/bcreg20230628a.htm"> well in excess</a> of hypothetical losses estimated by those stress tests. These tests assume no emergency government support during an economic downturn.Finally, contrary to the author's statements, the largest U.S. banks and their more than 735,000 employees are<a href="https://fsforum.com/our-impact/essential-to-the-u-s-economy"> essential</a> to the strength and the competitiveness of the U.S. economy, supporting countless American households, businesses and governments every day, including those in historically underserved communities. In just one example, Forum members have invested more than $9.2 billion in Community Development Financial Institutions and committed more than $525 million to minority depository institutions since the beginning of 2020.The<a href="https://www.fdic.gov/resources/regulations/federal-register-publications/2023/2023-regulatory-capital-rule-large-banking-organizations-3064-af29.html"> comment letters</a> in response to the proposal are still coming in, but organizations across the country — including the NAACP, small businesses, manufacturers, local lawmakers and others — have raised concerns with the Basel endgame proposal, including its potential impact on people in historically underserved communities.The financial crisis was 15 years ago. The nation's largest banks are strong and they are essential to our economy. Higher capital requirements would do more harm than good. And that's a fact.&nbsp;Kevin Fromer is the President and CEO of the Financial Services Forum. &nbsp;

Opinion

Letter to the editor: Basel 'myths' are all too real for the financial services industry

This article originally appeared on <a href="https://fortune.com/2023/12/06/us-economy-could-face-perfect-storm-basel-iii-endgame-goes-into-effect-finance-banks-kevin-fromer/">Fortune</a>.&nbsp;The past three years of economic volatility have exacted a profound toll on many Americans, testing the resilience of households and businesses alike. During this period, the largest banks, fundamentally strengthened by a series of changes, have served as a source of support by extending enormous amounts of credit, helping customers navigate uncertainty, and stabilizing the broader banking sector at a critical moment. Now, as the CEOs of these banks gather on Capitol Hill, Congress must ask itself if proposed regulations on capital jeopardize the essential work of these institutions.The capital regulation plan known as Basel III Endgame will increase capital requirements by 20% or more for the eight largest U.S. banks. This is an excessive move, considering the <a href="https://fsforum.com/a/media/capital-and-the-nation%E2%80%99s-largest-banks.pdf">tripling</a> of high-quality capital for these banks over the past 15 years. Higher capital requirements, <a href="https://www.federalreserve.gov/newsevents/pressreleases/powell-statement-20230727.htm">as noted by Federal Reserve Chair Jerome Powell</a>, raise the cost of–and reduce access to–credit.The plan will certainly compound the burden of higher post-pandemic interest rates,&nbsp;<a href="https://www.urban.org/sites/default/files/2023-09/Bank%20Capital%20Notice%20of%20Proposed%20Rulemaking.pdf?utm_source=newsletter&amp;utm_medium=email&amp;utm_campaign=newsletter_axiosmarkets&amp;stream=business">particularly for those with lower incomes</a>. Americans will have a harder time getting a loan, securing a mortgage, or saving for their retirement or a child’s college education.The impact isn’t limited to individual consumers. Small businesses&nbsp;<a href="https://fsforum.com/news/capital-insights-new-bank-capital-rules-will-handicap-small-businesses">relying</a>&nbsp;on credit and farmers&nbsp;<a href="https://www.americanbanker.com/opinion/basel-endgame-will-drive-up-costs-for-american-farmers-and-consumers">needing</a>&nbsp;funds for operations and equipment will face difficulty securing much-needed capital.A chorus of voices from the left and the right have come out against this proposed rule. Bipartisan consensus is rare these days, so the growing coalition of policymakers, advocacy groups, and community leaders warning against the negative impacts of stricter capital requirements is not something to take lightly. Senator&nbsp;<a href="https://www.politico.com/newsletters/morning-money/2023/09/14/the-calls-are-coming-from-inside-the-house-dems-rap-biden-bank-cops-00115837">Mark Warner (D-Va.)</a>&nbsp;has emphasized the potential compounding effect of tougher capital standards, high interest rates, and disruptions in the commercial real estate market as a “perfect storm.” Senator&nbsp;<a href="https://financialservices.house.gov/calendar/eventsingle.aspx?EventID=409027">John Tester (D-Mont.)</a>&nbsp;stated that he is worried about how this will impact working Americans, explaining he has “some concerns about the proposed changes, and what its impact will be on workers and households, small businesses, access to credit, and the overall vibrancy of our capital markets.”&nbsp;In a&nbsp;<a href="https://www.banking.senate.gov/imo/media/doc/basel_iii_banking_gop_letter.pdf">letter</a>&nbsp;to regulators, 39 Senate Republicans, led by Senator Tim Scott (R-S.C.), highlighted the resilience of the well-capitalized U.S. banking system and argued the proposal would negatively impact the economy while making credit costlier and more difficult to obtain for millions of Americans.Given these concerns, it is fair to ask why capital increases of this size are necessary. But no one seems equipped to provide an answer. On the contrary, the predominant official assessment of the banking sector, and the largest banks in particular, has been laudatory. As a matter of fact, every hypothesized loss the proposal aims to address has been experienced under real-life stress tests such as the pandemic, and the largest U.S. banks have continued to support the economy despite those losses under current capital requirements.Reflecting on the years of reform under the Dodd-Frank Act and Basel III, Chair Powell&nbsp;<a href="https://www.youtube.com/watch?v=627kC040sPU">highlighted</a>&nbsp;improvements in the banking system’s resilience, stating, “The large banks in the United States are very strong, well-capitalized, a lot of liquidity and they’ve been a source of strength, I think, through the last couple of events.”The future path of the U.S. economy is far from certain and hardworking Americans will pay a price if regulators demand new, unjustified capital requirements. Policymakers must demand extensive changes to the Basel III Endgame proposal so the banking sector can continue its essential role in the U.S. economy–and to avoid taxing consumers and businesses for no appreciable benefit to financial stability.Kevin Fromer is the president and CEO of Financial Services Forum.

Op-ed: The U.S. economy could face ‘a perfect storm’ if Basel III Endgame goes into effect. Here’s why

This op-ed was featured in the <a href="https://www.americanbanker.com/opinion/dont-delay-public-input-on-feds-review-of-capital-requirements">American Banker's BankThink.&nbsp;</a>&nbsp;<blockquote>Last month, Federal Reserve Vice Chair for Supervision Michael Barr outlined the Federal Reserve's agenda to make the financial system safer and fairer by improving banks' safety and soundness. Barr <a href="https://www.federalreserve.gov/newsevents/speech/barr20220907a.htm">called for a holistic review</a> of the bank capital framework, including a review of leverage and capital requirements for large banks. We welcome the Fed's review. And we urge the Fed to be more transparent about it.</blockquote>Mr. Barr is right. Currently, the U.S. capital framework is comprised of a dizzying array of moving parts: risk-weighted assets, stress capital buffers, surcharges on global systemically important banks, countercyclical buffers and leverage buffers, just to name a few. All these requirements are implemented separately, sometimes with several years between rules. No singular element of the capital regime determines overall capital requirements — rather, the various constraints knit together in complex and unpredictable ways to determine the overall amount of capital required of large banks. Given that capital requirements strongly influence the cost and amount of lending by banks in our economy, getting the mix of requirements right is critical, as is transparency around this process.&nbsp; Right now, all we know is that the Fed expects to complete its review this fall, and will only seek public input on proposed capital rules that are informed by the findings of the review after it is complete. We don't know much about how the review is being conducted, but we do know it is happening quickly — and without public input. But waiting for public input until so late in the game — once the direction of travel is set — is too late and risks consequential errors based on a lack of full information. The Federal Reserve should commit to seeking public feedback on its holistic review of the capital framework before the review is finalized and before any subsequent capital rules are proposed. Public feedback is crucial for several reasons.&nbsp; First, regulators' analysis can be improved by taking input from a variety of stakeholders, including academics and practitioners with significant expertise in bank capital.&nbsp; Second, public input will help ensure an evenhanded approach in reviewing the capital framework. A review solely conducted by regulators runs the risk of tipping the scales in a direction confirming existing policy preferences, even if there may be data supporting other perspectives.&nbsp; For example, studies have found that central bank-sponsored research on quantitative easing's effectiveness is more positive than other research on the topic. A full, open review of the capital framework soliciting input from a wide array of stakeholders will help ensure a thorough, unbiased and informed assessment.&nbsp; Most important, any study of the capital framework either implicitly or explicitly embeds a value judgment about the appropriate trade-off between economic growth and financial stability. Regulators are charged with maintaining financial stability, but they are not solely in charge of determining how society balances safety versus growth. Finding the right balance between growth and stability requires weighing the costs and benefits of additional financial stability measures against the impact on job creation and living standards. That debate must be informed by the views of all relevant stakeholders. The Federal Reserve and other agencies reviewing regulations routinely do so with public input. At least every 10 years, the bank regulatory agencies are <a href="https://egrpra.ffiec.gov/">required</a> by federal law to gather public input and review existing regulations. During the last cycle, regulators traveled the country for in-person meetings and collected written feedback. At one of these meetings, Federal Reserve Board Chairman Jay Powell <a href="https://www.federalreserve.gov/newsevents/speech/powell20150204a.htm">explained that</a> creating balanced, effective and thoughtfully calibrated regulations to avoid undue burden requires input from stakeholders. Researchers' review of the capital framework should also adhere to existing transparency standards for published academic research — and all of the data and analysis should be made public. The economics literature is replete with examples of studies that came to drastically incorrect conclusions because of simple data errors that were later uncovered by other researchers. Most academic journals now require that the data and programs used to conduct any analysis be made public before the results are published.&nbsp; The stakes are too high to accept even a small probability of an errant mistake. A comprehensive review of the capital framework and soliciting public input are necessary to ensure a safe and sound banking system in balance with the promotion of economic growth. Doing one without the other will be counterproductive — and risks reaching an outcome that does not reflect the needs of our economy.&nbsp;

BankThink Op-ed: Don't Delay Public Input on Fed's Review of Capital Requirements

Letters

Forum Response to Request for Information on Deposits

Brokered Deposits Comment Letter

Joint Trades Letter on Brokered Deposits

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The Role of Big Banks in Community Infrastructure

Forum President and CEO Kevin Fromer highlights how the nation's largest banks fund essential community infrastructure projects, showcasing their commitment to fostering growth and prosperity in America's cities and counties.

Video

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Increases in capital requirements would harm American households, businesses, and the broader economy. Regulators must carefully consider the economic impact of higher capital requirements, because they affect the whole economy, not just banks.

Capital, other topics

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<ul><li>We hold more than $4.2 trillion in loans, accounting for 40% of total lending to businesses and households.</li><li>We provide more than $679 billion, or nearly half, of all consumer loans by banks in the U.S., supporting everything from the purchase of a new car to furnishing a new home.</li><li>Lending by our institutions accounts for 34% of total commercial and industrial (C&amp;I) lending by banks, helping businesses grow and contribute to the economy.</li><li>We represent a major source of lending to small businesses in communities across the country, holding $126 billion in small business loans&nbsp;and allowing the economy to grow at both a local and national level.</li><li>We also collectively meet nearly three-quarters of the bank funding needs of other financial institutions, supporting community banks, insurance companies and mortgage finance companies, for example, which then provide important services to businesses and households.</li></ul>

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Lending

Our institutions lend to consumers, businesses and other financial institutions, promoting savings and investment that positions individuals and entities at all layers of the U.S. economy for resiliency and success. At the same time, we are supporting consumers, governments, and businesses of all sizes in growing and creating American jobs.

<ul><li>We underwrite nearly three-quarters of debt and equity transactions – such as initial public offerings – among large institutions in the U.S., providing a critical service that other U.S. institutions cannot offer on a similar scale.</li><li>With $4.2 trillion of mutual funds and annuities under management, we support the retirement and other savings needs of many Americans.</li><li>We finance a significant portion of state and local government expenditures for vital projects, like hospitals, roads, bridges, and schools, through $120 billion in municipal securities holdings. Additionally, we support a large portion of federal government expenditures through $1.1 trillion in U.S. Treasury securities holdings.</li></ul>

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Liquid Capital Markets

Our institutions help foster deep and liquid capital markets, ensuring the U.S. government and private institutions are able to effectively finance public spending and investments in the real economy. 

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Our Employees

Our institutions collectively employ more than 750,000 people, offering a variety of benefits and opportunities to help our employees achieve their personal and professional goals.

Forum members increased credit to businesses and households by 10%
to nearly $8.3 trillion in 2020.


Essential to the U.S. Economy    

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Big Banks and Their Role in Small Business Lending  

Forum President and CEO Kevin Fromer discusses the vital role played by the nation's largest banks in supporting small businesses through lending, and the significance of meeting the needs of American companies as the foundation for a strong economy. 

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Understanding the Role of Big Banks in American Competitiveness

Forum Chief Economist Sean Campbell discusses the important role that the nation’s biggest banks play in helping American companies compete internationally and explains how American international competitiveness is critical to ensuring the success and vibrancy of the U.S. economy.

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Maintaining the international competitiveness of U.S. companies is vital to the success and vibrancy of the U.S. economy. The nation’s largest banks provide crucial support for American companies competing overseas. The Forum supports policies that enable large U.S. banks to continue their vital support of the American economy on the global stage. 

International Competitiveness

Videos

Fact Sheet

Basel III Endgame - Harming our Capital Markets and the U.S. Economy 

The Largest U.S. Banks are Invested in MDIs

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<ul><li>As part of its 5-year, $1.25 billion commitment to closing the racial wealth gap Bank of America is working to drive systemic change by investing in CDFIs and MDIs, developing financing solutions for minority owned small businesses and entrepreneurs of color, and partnering with national and local nonprofits to support workforce development, entrepreneurship, and home ownership. As part of the $1.25 billion, Bank of America committed $50 million to support MDIs. To date, $36 million of equity capital has been invested in 21 MDIs across the country. This is in addition to approximately $100 million in deposits to MDIs, and the bank’s existing $2 billion CDFI portfolio.</li><li>As part of its $1 billion strategic initiative to close the racial wealth gap, Citi has committed $100 million to MDIs to expand access to banking and credit in communities of color. Citi has allocated more than $50 million so far and the bank has closed nearly $15 million in affordable housing loan participations for MDIs to build revenue and capacity. Citi also emphasizes engagement and mentorship. Through collaboration with <a href="https://www.deloitte.com/global/en.html">Deloitte</a> and the <a href="https://www.nationalbankers.org/">National Bankers Association</a>, Citi has established an MDI technical assistance program to support talent development, enhance technology, and expand business networks.</li><li>Goldman Sachs has deployed over $206 million in capital to support Black-led MDIs, including a $130 million commitment to Hope Enterprise Corporation, a leading MDI and CDFI in the South, to establish the “Deep South Economic Mobility Collaborative,” a public-private partnership with seven cities and nine historically Black colleges and universities across the South. The Collaborative will provide credit and support services to entrepreneurs of color, particularly Black women entrepreneurs, in historically disadvantaged neighborhoods.</li><li>As part of its $30 billion commitment to advance racial equity, JPMorgan Chase is providing diverse-led financial institutions with additional access to capital, connections to institutional investors, specialty support for Black-led commercial projects, and mentorship and training opportunities. In 2020, the firm committed to investing $50 million in Black and Latinx-led MDIs and CDFIs. With nearly $60 million already deployed to nine MDIs, the commitment has been increased to $75 million, which could generate access to as much as $750 million in community lending.</li><li>Morgan Stanley has provided <a href="https://www.businesswire.com/news/home/20200730005759/en/Morgan-Stanley-Announces-14-Million-to-Support-CDFI-Carver-Bancorp-Inc.">commitments</a> to MDIs in the form of grants, including to Carver Savings Bank in Harlem; Industrials Bank in Washington, D.C. and Newark, N.J.; and Citizens Bank in Atlanta. The grants will help the banks assist small businesses that were affected by COVID-19, particularly those that did not receive federal relief loans, and will support additional investments into technology systems to improve delivery of customer, mortgage and business lending services.</li><li>State Street <a href="https://newsroom.statestreet.com/press-releases/press-release-details/2024/State-Street-Announces-100-Million-Program-for-Minority-Depository-Institutions-and-Community-Development-Financial-Institutions/default.aspx">announced</a> a $100 million program to provide low-cost, stable deposit funding to Minority Depository Institutions and Community Development Financial Institutions. As partners with Optus Bank and Mechanics &amp; Farmers Bank, State Street will support the firms’ collective missions of addressing inequities in our communities by working toward a more just and equitable future.</li><li>Wells Fargo has <a href="https://newsroom.wf.com/English/news-releases/news-release-details/2021/Wells-Fargo-Invests-in-Five-Additional-Black-Owned-Banks/default.aspx">committed</a> $50 million in investments in MDIs. Above and beyond the equity investments, Wells Fargo is engaging in long-term partnerships with MDIs, including providing bank coverage teams for each MDI, providing technical assistance, fee-free ATM access for MDI customers, selling some shuttered branches to MDIs and looking at selling certain loan portfolios to MDIs.</li></ul>

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Supporting CDFIs and MDIs

We are supporting hundreds of Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) by providing over $11.5 billion in capital and financing since the beginning of 2020.

<ul><li>Bank of America&nbsp;in 2020&nbsp;<a href="https://newsroom.bankofamerica.com/press-releases/bank-america-announces-four-year-1-billion-commitment-supporting-economic">committed</a> $1 billion over four years to help local communities address economic and racial inequality. The firm has also <a href="https://newsroom.bankofamerica.com/press-releases/community-development/smithsonian-announces-race-community-and-our-shared-future#:~:text=Bank%20of%20America's%20%2425%20million,economic%20opportunity%20in%20minority%20communities.">committed</a> an additional $25 million to the Smithsonian to fund its Race, Community and Our Shared Future initiative, <a href="https://newsroom.bankofamerica.com/press-releases/corporate-philanthropy/bank-america-expands-support-boys-girls-clubs-america-1">provided</a> a $1 million grant to the Boys &amp; Girls Clubs of America, and made a $22.1 million <a href="https://newsroom.bankofamerica.com/press-releases/corporate-philanthropy/bank-america-expands-support-boys-girls-clubs-america-1">investment</a> in 2020 Neighborhood Builders and Neighborhood Champions in Support of Local Organizations.&nbsp; &nbsp;&nbsp;</li><li>BNY Mellon&nbsp;has <a href="https://www.bnymellon.com/us/en/about-us/newsroom/company-news/bny-mellon-commits-20-million-to-fund-the-future-workforce.html">committed</a> $20 million to community colleges and a select group of local and national organizations to support workforce training programs in traditionally underrepresented minority groups and communities. Additionally, the bank made an initial pledge of $1.5 million to organizations including My Brother’s Keeper, the NAACP Legal Defense and Education Fund, the Southern Poverty Law Center, the National Network for Safe Communities and the Vera Institute of Justice.</li><li>Citi <a href="https://www.citigroup.com/citi/news/2020/200923a.htm">launched</a> more than $1 billion in strategic initiatives in 2020 aimed at closing the racial wealth gap. The bank also <a href="https://www.citigroup.com/citi/news/2020/200117a.htm">launched</a> the $150 million Citi Impact Fund to make equity investments in ‘double bottom line’ private sector companies, with a focus on women and minority owned businesses.</li><li>Goldman Sachs&nbsp;has launched the One Million Black Women <a href="https://www.goldmansachs.com/our-commitments/sustainability/one-million-black-women/index.html">initiative</a>, a $10 billion investment initiative to advance racial equity and economic opportunity by investing in Black women with the goal of impacting the lives of at least 1 million Black women by 2030. It has also <a href="https://www.goldmansachs.com/media-relations/press-releases/current/gs-fund-for-racial-equity.html">created</a> the Goldman Sachs Fund for Racial Equity, which launched with $10 million – building on the more than $200 million the firm has granted over the past decade to organizations serving communities of color – and aims to support organizations addressing racial injustice, structural inequity and economic prosperity.</li><li>JPMorgan Chase&nbsp;in 2020 <a href="https://www.jpmorganchase.com/news-stories/jpmc-commits-30-billion-to-advance-racial-equity">committed</a> $30 billion to advance racial equity over the next five years through growing Black- and Latinx-owned businesses, improving financial health and access to banking in Black and Latinx communities and accelerating investment to build a more diverse and inclusive workforce.</li><li>Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/press-releases/morgan-stanley-announces-10-million-to-support-national-urban-le">announced</a> $10 million in grants to support the National Urban League, aimed at supporting financial literacy, homeowner counseling and workforce development programs. The firm also <a href="https://www.morganstanley.com/press-releases/morgan-stanley-commits--5-million-to-naacp-legal-defense-and-edu">committed</a> $5 million on top of matching employee contributions to the NAACP Legal Defense and Education Fund to support its work in fighting for racial justice.</li><li>State Street&nbsp;in 2020 <a href="https://www.statestreet.com/content/dam/statestreet/documents/New_Commonwealth_Racial_Equity_and_Social_Justice_Fund_Press_Release.pdf">announced</a> a five year, $5 million commitment to the New Commonwealth Racial Equity and Social Justice Fund, which supports Black- and brown-led organizations that are working on economic empowerment, youth civic engagement, healthcare equity and criminal justice reform.</li></ul>

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Combatting Inequality

We are dedicated to combatting inequality through a series of important initiatives. These initiatives support minority owned small businesses and provide funding for community organizations that are dedicated to closing the racial wealth gap.

<ul><li>In the most recent year, Bank of America Community Development Banking (CDB) provided $7.85 billion in loans, tax credit equity investments and other real estate development solutions, which helped build strong, sustainable communities through affordable housing and economic development across the country. This included more than 13,000 housing units for individuals, families, seniors, veterans and the formerly homeless. In addition, Bank of America continues its <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2021/02/bank-of-america-triples-affordable-homeownership-commitment-to--.html#:~:text=Bank%20of%20America%20today%20announced%20it%20will%20triple,than%2060%2C000%20individuals%20and%20families%20to%20purchase%20homes.">$15 billion Community Homeownership Commitment</a> to help 60,000 individuals and families purchase affordable homes by 2025.</li><li>BNY Mellon helps build stronger and more resilient communities by providing financing for affordable housing. Every year, the firm provides letters of credit and equity in the form of Low-Income Housing Tax Credits (LIHTC) to its clients. In 2022, BNY Mellon <a href="https://www.bnymellon.com/content/dam/bnymellon/documents/pdf/2022-esg-report.pdf">offered</a> 10 LIHTC equity investments, producing 938 housing units.</li><li>Citi offers its financial services to affordable housing developers across the nation through <a href="https://www.citibank.com/icg/sa/citicommunitycapital/">Citi Community Capital</a>. In 2022, Citi Community Capital <a href="https://www.citigroup.com/global/news/press-release/2023/citi-ranked-number-one-u-s-affordable-housing-lender-for-2022">provided</a> $6 billion to finance more than 35,000 affordable housing units and over $7.4 billion to finance multifamily affordable housing, education, and other community development projects. Additionally, Citi was <a href="https://www.citigroup.com/global/news/press-release/2023/citi-ranked-number-one-u-s-affordable-housing-lender-for-2022">recognized</a> as the Top U.S. Affordable Housing Lender for the 13th straight year in Affordable Housing Finance Magazine’s annual ranking.</li><li>In 2023, Goldman Sachs’ Essential Housing Impact Partnership—formed by the Michaels Organization, Goldman Sachs Asset Management’s Urban Investment Group, and the Community Development Trust – <a href="https://tmo.com/essential-housing-impact-partnership-acquires-90-affordable-communities/">invested</a> $1.2 billion in the acquisition of 90 affordable housing communities. This investment ensures the preservation of more than 10,000 affordable apartment homes for families and seniors with low and moderate incomes.</li><li>As part of JPMorgan Chase’s efforts to help close the housing affordability gap in Washington D.C., the firm in 2023 <a href="https://www.jpmorganchase.com/news-stories/jpmorgan-chase-announces-new-business-and-philanthropic-commitments">announced</a> a $7.5 million philanthropic commitment to three D.C. based non-profits that work to improve affordable housing. The firm also announced the expansion of Chase Home Lending’s $5,000 Homebuyer grant to communities in the D.C. region. Since 2021, JPMorgan Chase’s commitment to close the housing affordability gap has helped preserve or create more than 12,500 housing units and serve more than 46,000 households.</li><li>Morgan Stanley’s Community Development Finance (CDF) group is the firm’s key driver for supporting affordable housing. In 2022, CDF financed over 75 affordable housing developments for a total of over $1.5 billion in new construction, preservation and rehabilitation of affordable housing. In 2023, CDF continues to address the growing housing affordability crisis by investing in projects like Pinyon Apartments, with a $51 million equity investment for the new construction of 252 affordable homes for families in Reno, Nevada and Villages of East River, a $37.4 million equity investment for the substantial renovation of 202 units of deeply affordable housing with services for families in Washington, DC.</li><li>State Street Bank also makes equity investments in affordable multifamily housing communities throughout the US as part of our Tax Advantaged Investment group and through our participation in the Low Income Housing Tax Credit (“LIHTC”) program. Our current LIHTC portfolio includes 939 properties, encompassing over 79,000 affordable units.</li><li>In 2022, 3,000 Wells Fargo employees <a href="https://www08.wellsfargomedia.com/assets/pdf/about/corporate/diversity-equity-inclusion-report.pdf">volunteered</a> with Habitat for Humanity. Wells Fargo also provided $7.75 million to the organization to renovate and repair more than 380 affordable homes across the nation. Since 2010, Wells Fargo and the Wells Fargo Foundation have donated more than $129 million to Habitat for Humanity International and local affiliates in support of affordable and sustainable housing, including support for new home construction and repairs, helping older adults age in their homes, and neighborhood revitalization and disaster response efforts.</li></ul>

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Commitment to Affordable Housing

Forum members are playing a leading role in promoting affordable housing throughout the country. In 2023, Forum banks created or preserved more than 244,773 affordable housing units.

<ul><li>Wells Fargo launched the <a href="https://www.wellsfargo.com/jump/enterprise/banking-inclusion-initiative/">Banking Inclusion Initiative (BII)</a>, a 10-year commitment to accelerate the access of unbanked communities to affordable, low-cost banking and provide financial education for minority families. In addition, they’ve introduced Community Connections Branches within LMI neighborhoods specially designed around the needs of diverse communities, which feature redesigned spaces created to deliver one-on-one consultations, improve digital access, and offer financial health seminars. Through the BII, Wells Fargo is helping to increase access to digital solutions by deepening existing relationships with Minority Depository Institutions and fintechs, whose customers can use Wells Fargo’s ATM network without incurring fees from the bank.</li><li>Located in areas that have historically lacked access to traditional banking service, <a href="https://www.jpmorganchase.com/impact/racialequity/financial-health">Chase</a> Community Center branches host free financial health workshops and skills training, serve as a pop-up shops for small business clients, and provide free Wi-Fi access. Each community-style branch is led by a dedicated community manager, hired locally to build trust/engage the community, increase awareness of financial health resources, and address specific needs of the neighborhood. These initiatives among others support JPMorgan Chase’s goal to open 1 million new accounts for the underbanked and unbanked by 2025. Since the launch of the initiative in 2020, the bank has helped nearly half a million US households access low-cost checking accounts and reached more than 250,000 people through financial education events.</li><li>Citi developed Citi Financial Pathways to expand banking access and support financial progress for all. By bringing together some of Citi’s inclusive products, services, and tools, Citi Financial Pathways was designed as a launch point to empower and help its customers make informed decisions about their financial futures. Individuals can explore ways to achieve their goals with strategies to manage money, understand credit, grow wealth, finance a home and run a business. Links to a variety of personal finance articles and money management resources offer additional guidance and context to help individuals take the next step on their path to financial wellness.</li><li>Bank of America operates 1,100 financial centers in low- to moderate-income neighborhoods, helping to connect the unbanked and underbanked to the products and financial education they need. These centers are staffed by trained professionals, many of whom are multilingual, and that feature tools and resources such as kiosks with interactive, self-guided financial education content and conference rooms offering free Better Money Habits education seminars in English and Spanish. The bank also offers <a href="https://bettermoneyhabits.bankofamerica.com/en">BetterMoneyHabits.com</a> to all consumers, and clients have 24/7 access to the bank’s industry leading mobile and online banking platforms.</li></ul>

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Bringing Those Outside of Banking In

Forum members have long been on the frontlines in the effort to bring unbanked and underbanked Americans into the financial mainstream.

<ul><li>Bank of America&nbsp;has committed to spending nearly $2 billion annually with diverse businesses through its <a href="https://about.bankofamerica.com/en-us/what-guides-us/vendor-management.html#fbid=tlM4qFkwCad">Supplier Diversity program</a>.</li><li>BNY Mellon&nbsp;has established a dedicated <a href="https://www.bnymellon.com/us/en/supply-chain-responsibility-program/supply-chain-responsibility-program-statement.html">Supply Chain Responsibility program</a> to build and maintain a diverse supplier base, as well as host workshops and expos to support diverse vendor development.</li><li>Citi actively seeks diverse suppliers through minority and women business development organizations and participation in various trade show activities while utilizing diverse suppliers and consultants through their <a href="https://www.citigroup.com/citi/suppliers/who.htm">Supplier Diversity program</a>.</li><li>Goldman Sachs&nbsp;has <a href="https://www.goldmansachs.com/our-commitments/sustainability/our-vendor-program/vendor-diversity/">committed</a> to increasing spending with diverse vendors by 50 percent by 2025.</li><li>JPMorgan Chase&nbsp;has set a goal of continually exceeding $1 billion in spending with <a href="https://www.jpmorganchase.com/about/suppliers/supplier-diversity">diverse suppliers</a> each year.</li><li>Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/about-us/supplier-diversity">partners</a> with supplier diversity organizations like the Women’s Business Enterprise National Council and the National Minority Supplier Development Council.</li><li>State Street&nbsp;has committed to increasing its spending with diverse suppliers over the next three years in order to strengthen Black- and Latinx-owned businesses.</li><li>Wells Fargo&nbsp;aims to spend 15 percent of its procurement budget with diverse suppliers through the bank’s <a href="https://www.wellsfargo.com/about/diversity/supplier-diversity/commitment/">Supplier Diversity program</a>.</li></ul>

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Supporting Diverse Suppliers

Our institutions are committing to partner with diverse vendors and suppliers to support minority and women-owned businesses.

<ul><li>BNY Mellon&nbsp;started the&nbsp;<a href="https://www.bnymellon.com/us/en/about-us/diversity-inclusion.html">IMPACT</a>&nbsp;network to help cultivate a diverse and inclusive workplace by promoting the recruitment, retention, professional development and advancement of multicultural employees.</li><li>JPMorgan Chase&nbsp;has multiple&nbsp;<a href="https://careers.jpmorgan.com/us/en/about-us/diversity">Business Resource Groups</a>&nbsp;(BRGs) that help foster networks of employees and connect women and minority employees with each other to provide mutual support and sharing.</li><li>Morgan Stanley&nbsp;has established an ‘<a href="https://www.morganstanley.com/articles/diversity-hiring-black-banking-professionals">Experienced Professionals Program</a>’ to recruit Black professionals with two or more years of post-graduate or work experience for full-time positions to help expand the talent pool of Black financial professionals.</li><li>State Street&nbsp;helps create a diverse workforce through its&nbsp;<a href="https://www.statestreet.com/values/social-consciousness.html">Global Inclusion program</a>, which offers mentoring, events and performance goals focused on diversity and inclusion, and employee networks.</li></ul>

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Diverse Talent 

Our members recognize that a diversity of talent bolsters competitiveness around the world, helps foster economic opportunity, and leads to better results for consumers, clients, and communities.

We invested more than $11.5 billion in Community Development Financial Institutions since the beginning of 2020. 

Economic Opportunity and Inclusion

The Largest U.S. Banks are Invested in CDFIs

Fact Sheets

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Member News

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State Street Corporation

Ron is chairman and chief executive officer of State Street Corporation. He is also a member of State Street Corporation’s Board of Directors. Ron was previously president and chief operating officer of State Street Corporation, and before that president and chief executive officer of State Street Global Advisors, the investment management arm of State Street Corporation. He joined State Street in 2015. Prior to State Street, Ron was president of Asset Management &amp; Corporate Services for Fidelity Investments, responsible for all Fidelity asset management organizations and Fidelity’s corporate functions and enterprise technology. He served at Fidelity from 2010 to 2014. Prior to joining Fidelity, Ron served as president and chief executive officer of BNY Mellon Asset Management in Boston, a position to which he was named in 2007. During this time, he also served as vice chairman of Bank of New York Mellon Corporation and was a member of its Executive Committee. Additionally, Ron oversaw all of Bank of New York Mellon’s activities in Asia. Prior to the 2007 merger of Bank of New York and Mellon, he was vice chairman of Mellon Financial Corporation and president and chief executive officer of Mellon Asset Management. He served at Mellon and Bank of New York Mellon from 1997 to 2010. Prior to Mellon, Ron was with McKinsey &amp; Company, Inc., from 1986 to 1997 and was elected a partner in 1992. He founded the Investment Management practice worldwide and was co-founder and co-leader of the firm’s North American Personal Financial Services practice. Additionally, he was a member of the Worldwide Property &amp; Casualty Insurance practice. During his tenure with McKinsey, Ron served in the firm’s Boston, New York, and Stockholm offices. Ron received his Bachelor of Arts degree in political science from Syracuse University in 1980 and his Master of Business Administration from Harvard Business School in 1986. Ron serves on the boards of Unum Corp. and Rhode Island Commerce Corporation. He also serves on the boards of Beth Israel Lahey Health, The Boston Foundation, IYRS School of Technology and Trades, Syracuse University and WBUR. Ron’s philanthropic and civic interests include corporate governance, retirement/healthcare policy and funding, education, and climate. He has led several initiatives on gender equality. Ron is a frequent speaker and writer, and an avid offshore sailboat racer.

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Ronald O'Hanley

State Street Corporation Chairman And Chief Executive Officer, Forum Chair

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Citigroup

Jane Fraser is the Chief Executive Officer of Citi, the world's most global bank, serving millions of consumers, businesses and institutions across 160 countries and jurisdictions. She is the first female CEO in the firm’s history. Jane has deep experience across Citi’s consumer and institutional businesses and, in many ways, she helped shape Citi into the company it is today. Before becoming CEO in February 2021, she was President of Citi and CEO of the Global Consumer Bank, responsible for all of Citi’s Consumer businesses, including Retail Banking and Wealth Management, Credit Cards, Mortgage and Operations and Technology in 19 markets. Before that, she was the Chief Executive Officer of Citigroup Latin America from 2015 to 2019. From 2013 to 2015, she was the Chief Executive Officer of the U.S. Consumer and Commercial Banking and CitiMortgage. From 2009 to 2013, Jane served as the Chief Executive Officer of Citi's Global Private Bank. Prior, Jane was the Global Head of Strategy and Mergers &amp; Acquisitions for Citi from 2007 to 2009. She joined Citi in 2004 in the Corporate and Investment Banking division. Before joining Citi, Jane was a Partner at McKinsey &amp; Company. She started her career at Goldman Sachs in the Mergers &amp; Acquisitions department in London and then worked for Asesores Bursátiles in Madrid, Spain. Jane serves as a Board Member for the Business Roundtable and the Council on Foreign Relations. She is Vice Chair for the Partnership for New York City and a member of Harvard Business School’s Board of Dean’s Advisors, the Stanford Global Advisory Board and the Economic Club of New York. Jane has an M.B.A. from Harvard Business School and an M.A. in economics from Cambridge University. She is married with two children.

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Jane Fraser

Citigroup Chief Executive Officer, Forum Vice Chair

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Bank Of America

Brian Moynihan leads a team of more than 200,000 employees dedicated to making financial lives better for people, companies of every size, and institutional investors across the United States and around the world. Bank of America is recognized as a top employer by Working Mother magazine and Military Times. The company is also listed on Fortune magazine’s list of the Best Workplaces for Diversity and the Best Workplaces for Parents. It was also named one of the Best Places to Work for Disability Inclusion by the U.S. Business Leadership Network and the American Association of People with Disabilities. In 2018, Euromoney recognized Bank of America as the World’s Best Bank and the World’s Best Bank for Diversity and Inclusion, as part of their annual Global Awards for Excellence. Bank of America was also named the 2019 Catalyst Award winner, honored for supporting the continued development, empowerment and advancement of women in the company and around the world. Moynihan participates in several organizations that focus on economic and market trends, including the World Economic Forum International Business Council, the Financial Services Forum, the Bank Policy Institute (chair), the Business Roundtable, and the American Heart Association CEO Roundtable (co-chair). He is also a member of the Federal Advisory Council of the Federal Reserve Board. Moynihan leads the company’s Global Diversity and Inclusion Council and is a member of the museum council for the Smithsonian’s National Museum of African American History and Culture. Moynihan is also a member of the Brown University Corporation’s Board of Fellows and the Congressional Medal of Honor Foundation Board.

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Brian Moynihan

Bank Of America Chairman Of The Board And Chief Executive Officer

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BNY 

Robin Vince is President and Chief Executive Officer of BNY and a member of its Board of Directors. Previously, he was Vice Chair of BNY and CEO of Global Market Infrastructure. In that role, he oversaw BNY’s Clearance and Collateral Management, Treasury Services, Markets and Execution Services and Pershing businesses. Prior to joining BNY in October 2020, Robin was the Chief Risk Officer of Goldman Sachs and a member of the Management Committee. He joined Goldman Sachs in 1994 and held many leadership roles, including Treasurer, Head of Operations, Head of Global Money Markets, COO of the EMEA region and CEO of Goldman Sachs International Bank, among others. He served on several key subsidiary boards and governance committees. He was named managing director in 2002 and partner in 2006. Robin is a member of National Geographic Society's Hubbard Council and serves on the Board of Advisors of The Hospital for Special Surgery.

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Robin Vince 

BNY Chief Executive Officer 

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The Goldman Sachs Group, Inc.

David Solomon is Chairman and Chief Executive Officer and a member of the Board of Directors of The Goldman Sachs Group, Inc. Previously, he was President and Chief Operating Officer and prior to that, he served as Co-Head of the Investment Banking Division from 2006 to 2016. Before that, Mr. Solomon was Global Head of the Financing Group, which includes all capital markets and derivative products for the firm’s corporate clients. He joined Goldman Sachs as a Partner in 1999. Mr. Solomon is a member of the Board of Trustees of Hamilton College and serves on the board of The Robin Hood Foundation.

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David Solomon

The Goldman Sachs Group, Inc. Chairman and Chief Executive Officer

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JPMorganChase 

Jamie Dimon is Chairman of the Board and Chief Executive Officer of JPMorganChase, a global financial services firm with assets of $2.5 trillion and operations worldwide. The firm is a leader in investment banking, financial services for consumers, small business, commercial banking, financial transaction processing and asset management. Dimon became CEO on January 1, 2006 and one year later also became Chairman of the Board. He was named President and Chief Operating Officer upon the company’s merger with Bank One Corporation on July 1, 2004. Dimon joined Bank One as Chairman and CEO in 2000. Dimon began his career at American Express Company. Next, he served as Chief Financial Officer and then President at Commercial Credit, which made numerous acquisitions and divestitures, including acquiring Primerica Corporation in 1987 and The Travelers Corporation in 1993. Dimon served as President and Chief Operating Officer of Travelers from 1990 through 1998 while concurrently serving as Chief Operating Officer of its Smith Barney Inc. subsidiary before becoming co-Chairman and Co-CEO of the combined brokerage following the 1997 merger of Smith Barney and Salomon Brothers. In 1998, Dimon was named President of Citigroup Inc., the global financial services company formed by the combination of Travelers Group and Citicorp. Dimon earned his bachelors degree from Tufts University and holds an MBA from Harvard Business School. He serves on the boards of directors of a number of non-profit institutions including the Clearing House and Harvard Business School. Additionally, he is the Chairman of the Business Roundtable and serves on the executive committee of the Business Council and the Partnership for New York City, and is a member of the Financial Services Forum, Financial Services Roundtable and Council on Foreign Relations.

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