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Trump - Dodd-Frank Reform

lol if they havent written or implemented any of the new rules, how has it "crippled" small business? Settle down and stop contradicting yourself.

$10.4 billion is what percentage of the gross community banking industry? Sounds like a big number so Im interested to hear how much of a slice of the overall industry that makes up.

I am for the little guy. In fact, my wife and I just took out a small business loan last month from a microlender.

I'll add that I am not against tweaking to account for economies of scale etc, but you haven't said what the reform is, so I am assuming you want to rip the regs away.

That isn't a contradiction. There are lots of rules that have come on line and many others that have been delayed for years and will add lots of new and added costs when they do. The roll out of this law has been an epic mess - something you likely know if you do any legal work for corporate clients.

Never mind some of the regulations are completely pointless - something the SEC itself has tacitly acknowledged. Take, for instance, Conflict Mineral reporting obligations. Those obligations are a complete joke - trying to require all companies whose products contain any of a series of minerals to confirm their ultimate source was not the DRC. Even a relatively small manufacturer will have a very complex multi-layered supply chain and for years almost no companies have been able to make a "Conflict Mineral" free declaration. In turn the SEC has repeatedly stayed certain requirements of these regs. If we were that concerned with funding war lords it would have been more efficient to just send in the friggin' marines (hint, that is sarcasm). Never mind all the unintended consequences that have resulted from these regs that the SEC has stayed and courts have found unconstitutional. https://www.sec.gov/news/statement/reconsideration-of-conflict-minerals-rule-implementation.html
 
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75% of my work is for banks, and Dodd Frank defs fucked them. The big banks are still lending but it takes them 2x longer to get a deal done. The medium and small banks just aren't really lending except to the absolute best borrowers. They have just put their heads back in their shells. Its a huge problem, and probably one of the main reasons we still haven't seen good sustained GDP growth during the recovery, even though we are adding jobs.


Typical over-governing. A real problem presents itself that could use government intervention, but then sloppy, overreaching, overregulating reactions cause problems in the industry that may be bigger than the original problem itself.

The same thing has happened in the healthcare/hospital world but doesnt get as much pub.
 
I'm not sure yet whether W&B realizes that small banks can choose to lend to things other than businesses yet. Waiting for the lightbulb to go off to end the Facepalm

Or he can just keep arguing with the posters who work in the industry.
 
lol none of the anti- DF posters on this thread have been able to prove that DF has "crippled" investment for small businesses. Some anecdotes with no specifics. I conceded it has been one of many factors in slower growth of investment but continue to maintain my opinion that it is not "crippling" small business investment because no one has proven that except with #feelings

IN what industry? Banking? lol

I'm in the small business industry.
 
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So I offered you math a few posts ago and you just tossed it aside. It's almost bizarre that you'd want the big banks to get even bigger. That's been one of the results. Think about it. Banks represent 85% of the capital for small businesses. Small banks represent 51% of that capital. Small banks are being absorbed and closing at faster rates than before D-F. D-F and the costs it places on those banks are a significant part of that equation. And you, of all people, is leaning on the WSJ to refute what the ICBA, Ben Bernake and the Federal Reserve Bank and others are laying out as the stats.? This isn't us vs. you. It's asking you to actually dig a bit. We get you think D-F is there to protect consumers. But if a byproduct of that is that it hurts small banks and small communities, is that not something you'd want to ensure is fixed? Never mind we're 6 years into the law and all the required regulations have not even been proposed and numerous ones that have don't work and have led to a lot of unintended consequences (80,000 plus pages will do that).
 
So I offered you math a few posts ago and you just tossed it aside. It's almost bizarre that you'd want the big banks to get even bigger. That's been one of the results. Think about it. Banks represent 85% of the capital for small businesses. Small banks represent 51% of that capital. Small banks are being absorbed and closing at faster rates than before D-F. D-F and the costs it places on those banks are a significant part of that equation. And you, of all people, is leaning on the WSJ to refute what the ICBA, Ben Bernake and the Federal Reserve Bank and others are laying out as the stats.? This isn't us vs. you. It's asking you to actually dig a bit. We get you think D-F is there to protect consumers. But if a byproduct of that is that it hurts small banks and small communities, is that not something you'd want to ensure is fixed? Never mind we're 6 years into the law and all the required regulations have not even been proposed and numerous ones that have don't work and have led to a lot of unintended consequences (80,000 plus pages will do that).

Correlation is not causation. You keep saying "since Dodd Frank small banks have failed etc etc etc" A lot of shit has happened in the economy since Dodd-Frank that has had an effect on Community Banks and their ability to make loans to small businesses. I put in the WSJ link to highlight that, and the quote was from a representative of Community Banks, the leader of their advocacy group IIRC.

You are heaping all the blame onto DF when, like I said, it is just one of many factors.
 
Hopefully laws that act as safeguards to prevent another financial meltdown like the one last decade are either kept in place, or new ones are put in.

Also, I really hope that there are laws kept on the books that require advisors to act in the best interest of their clients so people don't continue to get taken advantage of by banks and "advisors".

These are the parts that are needed, however all the huge compliance parts are the ones driving the community banks out of the market and that is a shame because that takes a lot of the small business people out of the game on loans the big banks won't make. Banks have to come up with 5% to cover what they have on hand and with the low interest rates, margins are small. Plus with more and more of the old higher interest rate loans having been refinanced or finally being retired, those loans are gone at higher rates. One of my son's fixed income funds in his company's hedge funds is paying over 7% and one of their main buyers has been the small to medium banks who are trying to stay afloat. They can make over 7% while still being able to pay this ridiculous 5% Dodd-Frank payment.
 
no its no irrelevant at all, it is germane. The argument was that DF hurt community banks' bottom lines and in some cases shuttered them, leaving fewer options for small businesses (crippling was the term) to invest. A profitable thriving community bank is able to offer more/better loans and take more risk, no? And the more community banks are open and thriving is better for small business - it was your argument. :noidea:

your quote:

No, that wasn't the argument. The argument is that they aren't making small business loans any more. Whether the community bank is profitable or shuttered is largely irrelevant; the only thing relevant is whether they are making the small business loans.

That was not the argument they were making. They are moving the goalposts.

The argument is that D/F hurts small business.

How?

By putting more regs on small banks, who are small businesses' main lenders.

How?

The new regs meant more compliance costs, and small banks don't have the profits of the bigs, and therefore couldn't absorb the added cost and still offer loans to small businesses like they did before.

How does that affect small businesses?

Many community banks closed, limiting the options for small businesses to find loans.


Is it accurate?

Many closed, but new regs played only a partial role in this, and other factors played a larger role ie: low rates and heavy recession toll on economy.

Again, no. Whether the bank closed or not, the point is that it isn't making small business loans any more. There could be community banks on every corner making millions in profit each year on deposit accounts, that is not relevant to the point that they aren't making small business loans any more because of DF, which is what is strangling small business financing.
 
They aren't making small business loans any more? I just got one, another family member just one, and a friend of my just got one. We are immersed in the small business world in my suburb, and not being able to get a loan is never talked about in our circles. There is my anecdote. :noidea:

Small business loans are down among small banks, but again, regulations is but one of many factors. You seem unable to comprehend that and want to lump it all on the regs, which is a single factor and, given the shitshow poorly regulated banks rained down on consumers, a likely a necessary evil. I'm open to reforms, but you nor the OP have brought them up, you just keep going Dodd Frank Dodd Frank Dodd Frank...


To wit:

During the 2008 financial crisis, small businesses were hampered in securing bank credit because of a perfect storm of their falling sales and weakened collateral, and growing risk aversion among lenders. Those days are not over. While lingering cyclical factors from the crisis may still be constraining access to bank credit, there are also structural barriers that seem to be preventing banks, both large and small, from ever fully returning to the small business market.

Cyclical Factors Linger From The Recession
In the recent recession small-business sales were hit hard and may still be soft, undermining their demand for loan capital. Income of the typical household headed by a self-employed person declined 19 percent in real terms between 2007 and 2010, according to the Federal Reserve's Survey of Consumer Finances. And a survey by the National Federation of Independent Businesses (NFIB) noted that small businesses reported sales as their number one problem for four straight years during the crisis and subsequent recovery.

In addition, collateral owned by small businesses lost value during the financial crisis, potentially making small business borrowers less creditworthy today—in fact, small business credit scores are lower now than before the Great Recession. The Federal Reserve's 2003 Survey of Small Business Finances indicated that the average PAYDEX score of those surveyed was 53.4. By contrast, the 2011 NFIB Annual Small Business Finance Survey indicated that the average small company surveyed had a PAYDEX score of 44.7. Moreover, the values of both commercial and residential real estate, which represent two-thirds of the assets of small-business owners and are often used as collateral for small-business loans, were decimated during the financial crisis.

On the supply side, banks remain more risk averse in the recovery then they were prior to the recession. Measures of tightening on loan terms, including the Federal Reserve Senior Loan Officer Survey, for small businesses increased at double-digit rates during the recession and recovery, and have eased at just single-digit rates over the past several quarters. Loosening has been much slower and more tentative for small firms than for large firms.

Regarding points of access to capital, community banks have long been crucial to small business lending. But community bank failures have been high and few new ones have started up. Troubled and failed banks reached levels not seen since the Great Depression during the financial crisis of 2008, with the failures consisting mostly of community banks. This environment—where troubled local banks appear unable to meet re-emerging small firm credit needs—would be an ideal market for new banks, but new charters are down to a trickle. In fact, a year recently went by with no new bank charters issued by the Federal Deposit Insurance Corporation (FDIC), the first time that happened in the agency's 80-year history.


Perhaps the most compelling cyclical factor tightening the loan spigot is the concern that increased regulatory requirements may be hurting small-business lending. Banks have been raising their capital reserves to comply with new standards initiated by risk-averse bank examiners and other regulators post-crisis. They are also hoarding deposits, which undermines their ability to underwrite small-business loans.


Federal Reserve economists have recently modeled that increasing regulatory burdens are forcing banks to hire additional full-time employees focused on oversight and enforcement, which can hurt the return on assets of some community banks by as much as 40 basis points. Other studies have found that an elevated level of supervisory stringency during the most recent recession is likely to have a statistically significant impact on total loans and loan capacity for several years—approximately 20 quarters—after the onset of the tighter supervisory standards.

Structural Barriers Continue To Depress Bank Lending
Structural barriers also appear to be impeding bank lending to small businesses, including consolidation within the banking industry, high search costs, and higher transaction costs associated with small business lending.

A decades-long trend toward consolidation of banking assets into fewer institutions is eliminating a key source of capital for small firms. Community banks are being consolidated by big banks, with the number of community banks falling to less than 7,000 today, down from over 14,000 in the mid-1980s, while average bank assets continues to rise. This trend was exacerbated by the financial crisis. The top 106 banks with greater than $10 billion in assets held 80 percent of the nation's $14 trillion in financial assets in 2012, up from 116 firms with 69 percent of $13 trillion in assets in 2007.


Additionally, search costs in small-business lending are high for both borrowers and lenders. It is difficult for qualified borrowers to find willing lenders, and vice versa. Federal Reserve research finds that small-business borrowers can spend almost 25 hours on paperwork for bank loans, and often apply to multiple banks. Successful applicants wait weeks or, in some cases, a month or more for the funds to actually be approved and made available. Some banks are even refusing to lend to businesses within particular industries (for example, restaurants) or below revenue thresholds of $2 million.

Perhaps most important, small-business loans, often defined as business loans below $1 million, are considerably less profitable than large business loans for several reasons, including:

Small-business lending is riskier than large-business lending. Small businesses are much more sensitive to swings in the economy, have higher failure rates, and fewer assets to collateralize.

Assessing creditworthiness of small businesses can be difficult due to information asymmetry. Little, if any, public information exists about the performance of most small businesses because they rarely issue publicly traded equity or debt securities. Many small businesses also lack detailed balance sheets, use sparse tax returns, and keep inadequate income statements. Community banks have traditionally placed greater emphasis on relationships with borrowers in their underwriting processes, but these relationships are expensive and have not in the past translated well to automated methods for assessing creditworthiness, which are favored by larger banks.

Costs of underwriting small-business lending are also high due to heterogeneity of small businesses and the lack of a secondary market. Heterogeneity of small firms, together with widely varying uses of borrowed funds, have impeded development of general standards for assessing applicants for small business loans and have increased costs of evaluating such loans. Moreover, the heterogeneity of small business loans has made it difficult to securitize and sell pools of small business loans in the secondary market.

Transaction costs to process a $100,000 loan are comparable to a $1 million loan, but with less profit. As a result, banks are less likely to engage in lending at the smallest dollar level. Some banks, particularly larger banks, have significantly reduced or eliminated loans below a certain threshold, typically $100,000 or $250,000, or simply will not lend to small businesses with revenue of less than $2 million, as a way to limit time-consuming applications from small businesses. This is problematic as over half of small businesses surveyed are seeking loans of under $100,000, leaving a critical gap in the small business loan market. Often times, the biggest banks refer small businesses below such revenue thresholds or seeking such low dollar loans to their small business credit card products, which earn higher yields.

As the economy enters the final stages of the cyclical recovery from the recession, it appears unlikely that all the barriers to bank lending to small business will disappear. The structural issues of higher risk, search, and transaction costs appear to be here to stay—unless banks themselves, or more nimble new competitors, use technology to tackle these challenges.

In the next post in our series, Mills will explore efforts by the federal government to incentivize and increase small business lending during the recession and recovery.

http://hbswk.hbs.edu/item/why-small-business-lending-is-not-recovering


see, I even highlighted the regs as one of many reasons. I conceded it was a factor, just not the only factor.
 
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2nd post

And small community banks are surviving despite low interest rates.

Latest post

decades-long trend toward consolidation of banking assets into fewer institutions is eliminating a key source of capital for small firms. Community banks are being consolidated by big banks, with the number of community banks falling to less than 7,000 today, down from over 14,000 in the mid-1980s, while average bank assets continues to rise. This trend was exacerbated by the financial crisis.

You even bolded the contradiction Facepalm

Just take the L, bruh.
 
Or

2nd post

“Dodd-Frank—that term—became the poster child for every regulatory ill that’s been foisted onto community banks,” said Camden Fine, president of the Independent Community Bankers of America, which represents thousands of small banks. “There are regulatory burdens that community banks face today that are real, but had nothing to do with Dodd-Frank,”

versus latest post

Other studies have found that an elevated level of supervisory stringency during the most recent recession is likely to have a statistically significant impact on total loans and loan capacity for several years—approximately 20 quarters—after the onset of the tighter supervisory standards.
 
Not sure if it's a great proxy for total small business loans but SBA lending is up bigly over the last five years.

And yes there has been consolidation among banks but most of it is between community banks or small regionals I'd imagine. My experience is largely in NC but the healthier banks like First Bank and BNC (just purchased at a pretty strong premium iirc) continue to be pretty aggressive in the small business space.
 
2nd post



Latest post



You even bolded the contradiction Facepalm

Just take the L, bruh.

Hardly a contradiction worthy of "taking the L", bruh. Those 'contradictions' are arguments between the cited sources on details, but do not contradict my point. wtf?

Nothing I have posted contradicts the overall assertion I am making, and that is that Dodd Frank is but one of many factors contributing to the problems in small business lending. In fact, those posts highlight how complicated this issue is and isn't as simple as you and the OP are trying to make it. I still maintain that while it's not free, DF overall is needed in the industry

Maybe some tweaks are in order. But wholly rolling back banking regulations after what we have recently learned is the height of stupidity. Just real dumb shit, man. Im all for perfecting regulations, but that is not what this administration and this congress are aiming to do, which you are well aware of. There have been banking industry posters on this board over the years and this thread even who agree. The study I quoted in my last post makes it clear that the financial crisis is the overwhelming blow to the small business community, and most economists agree. Deregulation led us to that crisis. Knowing that, how the fuck do you want to do it all over again?

I know you want to get the W, but no.
 
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Correlation is not causation. You keep saying "since Dodd Frank small banks have failed etc etc etc" A lot of shit has happened in the economy since Dodd-Frank that has had an effect on Community Banks and their ability to make loans to small businesses. I put in the WSJ link to highlight that, and the quote was from a representative of Community Banks, the leader of their advocacy group IIRC.

You are heaping all the blame onto DF when, like I said, it is just one of many factors.




I agree that it is one of many factors. But DF is the factor that the government imposed and can fix. I don't follow the logic of not easing DF because its not the one and only reason small banks are at a disadvantage. Your argument sounds like more illogical anti-Trump posturing. Then again, I may be wrong on your position.
 
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I agree that it is one of many factors. But DF is the factor that the government imposed and can fix. I don't follow the logic of not easing DF because its not the one and only reason small banks are at a disadvantage. Your argument sounds like more illogical anti-Trump posturing. Then again, I may be wrong on your position.

Because of the consumer protections baked into DF to hopefully prevent another financial crisis by fault of reckless, deregulated banking.

If I own a restaurant and part of my overall expense is food safety, I am going to be less profitable than if I didn't have to worry about the consumer's safety. But should we be fighting to remove food safety regs?
 
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you can also solve another financial crisis by indicting those that were reckless, kinda like your boy Steve Bannon wants to do. Its going to happen again if the upside is make a couple hundred million and the downside is no penalty at all and you get to keep all the money and don't go to jail, but maybe lose your job.
 
you can also solve another financial crisis by indicting those that were reckless, kinda like your boy Steve Bannon wants to do. Its going to happen again if the upside is make a couple hundred million and the downside is no penalty at all and you get to keep all the money and don't go to jail, but maybe lose your job.

I not against indictments.
 
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