Michael Held

Formerly GC, New York Fed

[Michael Held @mikeheld5]

@bank_reg Agree and not just regulatory policy.

[Michael Held @mikeheld5]

@alexbarrage1 @bank_reg If I've got a secret business plan I wouldn't want to give my competitors any ideas, regardless of whether they knew it was "my" plan. In other words, disclosure hurts the first mover advantage. - At least that's one idea - but then I'm a lawyer so I'm out over my skiis.

[Michael Held @mikeheld5]

@bank_reg Also, tactically, the release of CCI (and PII) could expose the agency to litigation risk from the "owners" of the info, thus better to redact initially and then only release pursuant to a court order, thus reducing the litigation risk to the agency.

[Michael Held @mikeheld5]

@ZaringDavid It’s an interesting question- there is always a concern that PD’s might try to “monetize” PD status (Fed “seal of approval”, confers special access to PM’s, leverage information asymmetries, etc), and managing those concerns while also have a robust and effective set of PD’s.

[Michael Held @mikeheld5]

@ZaringDavid I could see the PD’s engaging more with the SOMA manager, perhaps, bit even there it would be at the margins.

[Michael Held @mikeheld5]

@ZaringDavid Understandable but nope. In terms of non-supervised firms, the IACFM members engage with the NY Fed pres. Can’t speak to the BoG but I’d be very surprised if Citadel were to see any add’l direct access to PM’s bc they are a PD.

[Michael Held @mikeheld5]

@ZaringDavid TBC, all that market color from the PD’s is super valuable to policy makers - I’m just pushing gently back on the idea that the PD’s have a direct line to JP or other senior policy makers.

[Michael Held @mikeheld5]

@ZaringDavid FWIW, virtually all communications between the PD’s and the Fed occur through relatively low level analysts on the Desk at the NY Fed markets group, and the PD survey - which has become much more transparent to mitigate info assymetry.

[Michael Held @mikeheld5]

@NewYorkFed Thrilled for you, Anat!

[Michael Held @mikeheld5]

@Aarondklein Um, with respect to bank supervision, they are.

[Michael Held @mikeheld5]

@ProfJulieHill @GeorgeSelgin @DavidBeckworth Maybe, but I don’t think the applicant would appreciate the Fed making public the reasons for the denial.

[Michael Held @mikeheld5]

@ProfJulieHill @GeorgeSelgin @DavidBeckworth Question: if they have to explain publicly the reasons for an approval, would they also how to explain publicly the reasons for a denial?

[Michael Held @mikeheld5]

@ProfJulieHill Agree with you on the transparency point. The transparency provided wrt actions on bank applications could be a guidepost.

[Michael Held @mikeheld5]

@ProfJulieHill Although post-Reserve Trust, the calculus on that is tougher. Likely the Fed will bend over backwards to avoid an optics issue.

[Michael Held @mikeheld5]

@bank_reg Thanks!

[Michael Held @mikeheld5]

@bank_reg Is there one for Katie Cox as well?

[Michael Held @mikeheld5]

Kudos to the Federal Reserve Banks for adopting FOI policies. https://t.co/qJGvGASkKK… I’ve seen some commentary stating that these policies fall “well short” of FOIA. Completely disagree. Nice job!