Banks labeled as Systemically Important Financial Institutions (SIFIs) are subject
to more intense federal regulation than other banks, per the Dodd-Frank Act of July
2010. But what factors should be used to designate a Bank Holding Company (BHC) as
a SIFI?
Jim Barth, Lowder Eminent Scholar in Finance at the Harbert College of Business, and four other industry and academic experts, offered their expertise to the Congressional
Subcommittee on Financial Institutions and Consumer Credit at a July 8 hearing on
Capitol Hill.
Barth provided written and oral testimony for the hearing, “Designation and Regulation
of Bank Holding Company SIFIs.”
“There is no evidence to support the use of a $50 billion threshold set by law to
distinguish between BHCs that are SIFIs and those that are not,” Barth wrote. “Such
a static and arbitrary threshold provides an incentive to those institutions just
below the threshold to curtail their growth to remain below $50 billion, while those
just above the threshold have an incentive to take actions to increase their size
to spread the additional costs incurred due to being subjected to enhanced potential
supervision over a bigger asset base. Surely, this was not the intent of the law.”
During the hearing, U.S. Rep. Tom Emmer (R-Minnesota) asked Barth to explain more
fully why he considers the $50 billion threshold “static” and “arbitrary.”
“As an economist, I typically turn to evidence and as I point out in my testimony,
there is ample evidence that drawing a threshold at $50 billion for bank holding companies
is inappropriate if one wishes to distinguish between systemically important financial
institutions and those which are not,” responded Barth.
Barth’s testimony reported that studies assessing systemic risk emphasize “the need
to base the designation of SIFIs on more factors than just asset size…”
“It was a terrific honor to be asked to testify before a U.S. Congressional Committee,”
Barth said. “It’s always nice when a faculty member at Auburn University is recognized
as someone with the expertise that members of Congress want to receive testimony
from at a public congressional hearing in the Nation’s Capital. It reflects well on
everyone at and associated with our university.”
Barth was joined in Washington by witnesses Harris Simmons, Chairman and CEO of Zions
Bancorporation; Paul Kupiec, Resident Fellow at the American Enterprise Institute;
Satish Kini, Partner at Debevoise & Plimpton, LLC; and Simon Johnson, Professor of
Entrepreneurship at the Massachusetts Institute of Technology.