In a letter sent Friday, the groups said the Fed is going too far and is proposing a set of policies on credit exposure and capital standards that go against the intent of the 2010 Dodd-Frank financial oversight law.
“We submit that an approach grounded in a ‘too big’ or ‘big is bad’ concept is not only contrary to Congress’ intent but is misguided and detrimental to a sound, strong banking system and a strong economy,” the groups wrote.
The letter precedes a meeting next week between Fed Governor Daniel Tarullo and the chief executives of large banks, including J.P. Morgan’s Jamie Dimon, according to a person familiar with the plan.
The meeting was scheduled to talk about the Fed’s annual stress tests on the banks. The banks may try to press him on other issues including their qualms with the December proposal for managing large banks.
The letter was written by the Clearing House Association, the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Securities Industry and Financial Markets Association. Comments on the December proposal are due Monday.
The Dodd-Frank law requires the Fed to write rules for overseeing bank holding companies with more than $50 billion in assets to ensure they are not engaging in risky activities that could threaten the financial system.
The groups said the Fed “has set a course,” however, to use these new powers “to achieve indirectly what it was not authorized to address directly — that is, precipitate a dramatic reduction in the size of large banks through size-based regulation.”
Collectively the lobbying groups represent the largest U.S. banks, including Citigroup, Bank of America, J.P. Morgan Chase, Goldman Sachs and Wells Fargo.
The salvo against the Fed is the latest example of tension over whether there are too many large banks whose potential failure poses a grave threat to the larger financial system.
Dallas Fed President Richard Fisher has taken a more extreme position, recently proposing breaking up the five biggest U.S. banks. Tarullo, who has been the central bank’s point man on regulation, has been more moderate.
Tarullo has never publicly called for breaking up the largest banks. But he has spooked the industry by questioning whether banks can get so big that any future growth does not provide value, through economies of scale, to the financial system or economy.
“It is possible that a firm would need to be quite large and diversified to achieve these economies, but still not as large and diversified as some of today’s firms have become,” he said in a September speech calling for more study of the issue.
In their 161-page letter, the groups argue that allowing banks of all sizes benefits the economy and that the largest institutions can provide services their smaller competitors can not.
“In the 21st century, companies served by international banks compete in a global economic system, exporting finished products, importing raw materials and components, and establishing substantial operations abroad,” the groups wrote. “They need banks that are competitive around the world and are able to meet quickly and efficiently a wide range of financial needs.”