“Rudolf Elmer has demonstrated that the ‘shadow banking system’ is not just about complex financial instruments that hide risk and the casino in which those instruments are traded. It is also about a dark corner of the banking system that hides personal and corporate wealth for a host of purposes, especially tax evasion.

As Elmer does his WikiLeaks dump in London, one issue for federal prosecutors to focus on is whether the banks and their officers filed suspicious activity reports, so-called ‘SARS’, as is required by the Bank Secrecy Act whenever an institution or its employees know or have reason to suspect illegal activity.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“Goldman’s plan to take the creation of structured financial products out of the hands of traders and give that responsibility solely to investment bankers is a positive move. The next step for Goldman, in burnishing its tarnished reputation, should be to ensure that complex products it creates are understood by their creators, by Goldman’s directors and regulators, and by its customers.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“Pure and simple, their charge should be labeled for what it is — a return of the subsidy that taxpayers bestow on the too-big-to-fail banks every day by pledging to their creditors and depositors that if the big banks go bust we collectively will pick up the tab.  Senator Brown would have a difficult time refuting this framing of the discussion.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“Its demise would have at least two significant benefits: first, it would allow the next Congress to develop a more robust bill, particularly with respect to systemic risk; and, second, it would enable global regulators to press the ‘reset button’ on international harmonization efforts, a vision apparently abandoned by this Congress and this Administration.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“Having lost the moment to make bold changes, the legislative process has become all about the November elections and very little about sound public policy.  Congress may well meet today’s deadline, but we won’t be the better for it.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“If derivatives trading is such a socially useful and profitable activity ($23 billion in revenue among the five banks that dominate the market) why can’t it exist outside of bank holding companies? The answer to the question is that it could exist in a different, nonbank setting, but, without the backing of the taxpayers, the activity would have to shed its casino-like features.”

Contact  Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“Permanently raising the federal deposit insurance ceiling from $100,000 to $250,000 when the Federal Deposit Insurance Fund is over $20 billion in the red is irresponsible. By raising taxpayer-funded deposit insurance coverage … it seems the [banking] lobbyists’ messages are getting through loud and clear.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“By lodging this casino activity in bank holding company affiliates she runs the risk of the Fed doing in the next crisis exactly what it has done in this one, namely waiving the rigid rules that are supposed to separate banks from their holding company affiliates.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“The better posture for the U.S. to strike on the international stage would be a willingness to cooperate with ongoing reform initiatives by the G-20, the Financial Stability Board, and others.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu

“If the FDIC was attempting to make the case for federal regulatory consolidation, its ill-timed proposals hit the mark.”

Contact Cornelius Hurley, 617-353-5427, ckhurley@bu.edu