Subject: Update: 2016 Tax Agenda on the Hill
From: Dana <[email-masked]>
To: Michael Pyle <[email-masked]>
Cc: Mike Schmidt <[email-masked]>
Date: Thu, 14 Jan 2016 19:59:50 -0500

Mike & Co.,

The hopes of even the most zealous advocate of tax reform must be modest this year, but brave talk is heard from some well-placed members.  Almost any reform would be seen as a crowning accomplishment for the new Speaker but the maw of election year politics militates against anything bipartisan and ambitious.

Below is a look at the state of play for the major tax legislation likely to see votes in 2016.  Tomorrow we look at the same issue from the campaign perspective in a pre-debate update.  

Best,

Dana

----------

Legislative Tax Prospects for 2016 

Senate Floor 

•  Customs Bill and Internet Moratorium
Early in the session, the Trade Facilitation and Trade Enforcement Act conference report, to which the House added a permanent Internet Tax Moratorium, will hit the Senate floor.   Sen. Durbin thinks he has enough votes to sustain a Budget Act point of order to knock that out, preserving slim odds of moving the Marketplace Fairness Act.  Most Senate Democrats will vote against cloture and for a Budget Act point of order against the report.   Democrats cite language discouraging the inclusion of climate change provisions in future trade agreements and weakened human trafficking language.  A permanent Internet Tax Moratorium, if enacted, would kill any chance for adding the Marketplace Fairness Act to subject Internet sales to state sales and use taxes.  

Sen. John Thune:  “I think that, in the end, if the Customs conference moves—and I think it will move soon—then the Internet-tax moratorium will be included in it as it was reported from the House.”  Regarding the Budget Act point of order against the Internet Tax Moratorium, he says:  “Right now, I think the vote count is probably fairly close on that. There are a lot of groups who are interested in that that are whipping it, and it could be a close vote, but I think in the end there will be 60 votes for keeping that in the bill.”

Senate Finance

•  Tax Extenders:  The passage of the tax extenders package through to the end of 2016 should give Senate Finance some breathing room to pursue comprehensive tax reform legislation in the coming year.  Thirty-two more expire at the end of this year, so look for another extenders bill during next December's lame duck session of Congress.

As noted last week, within Senate Finance is a series of working groups organized last year to discuss potential tax reforms in a variety of areas.  The working groups are:

•  International Tax Reform:   The working group proposes ending “the lock-out effect” on international profits by adopting a dividend exemption system.  This and minimum tax proposals are expected to help end base-erosion and tax inversion activities.  The Committee will continue to hold hearings on international tax reform in 2016, but no legislation has been introduced yet.  Chair Hatch:  “I think it’s more likely that we could work out an international tax bill because there are a number of us that want to get rid of the inversion problem ... Both Democrats and Republicans ought to want to get rid of the inversions of our larger corporations over to other lower tax jurisdictions.”

•  Business Income Tax Reform:   This group has put forward proposals to lower business income taxes.  The group’s report also catalogued recent legislative proposals, including the cash method of accounting, a pass-through entity business deduction, the research credit, publicly traded partnership rules, and corporate integration.

• Individual Tax Reform:  The working group calls for tax simplification and the adoption of incentivizing tax policies, such as those that encourage charitable giving and saving for education. 

•  Savings and Investment:  The group’s report lists three goals for policymakers to pursue: (1) increasing access to tax deferred retirement savings; (2) increasing participation and levels of savings; and (3) discouraging early withdrawals from retirement accounts.

•  Community Development and Infrastructure: The working group has proposed creating an alternative for funding the Highway Trust Fund.  Proposed solutions are meant to increase available funds to “... fix America’s roads and bridges, while also overhauling our broken tax code.”

In the House

•  International Business Tax -- Ways and Means Chair Kevin Brady seems determined to present an international business tax reform bill which addresses dividend repatriation.  Dividend repatriation is expected to pass House Ways and Means this year (more on this below).  Some Representatives have already begun pushing for such reforms; yesterday, Rep. Devin Nunes, with 26 cosponsors, introduced the American Business Competitiveness Act.  He wrote: "The ABC Act has four main components: it will allow 100 percent, same-year expensing for all businesses; lower the maximum business tax rate to 25 percent; eliminate all loopholes and special deals; and switch to a territorial international system."   Broad tax reform proposals don’t have much viability in the coming year; however, such proposals are important precursors for future tax reform efforts, possibly in 2017.

House Prospects 

Getting the top corporate and individual tax rates down to 30 percent would be difficult, and anything lower would be politically impossible because it would require wholesale elimination of major and very popular tax deductions.  If Brady tries to lower the top corporate rate below the top individual rate, pass-through business entities would oppose the bill, killing any chance for passage. 

In any event, dividend repatriation has apparently been ruled out by a Ryan aide.  George Callas, on a Pricewaterhouse Coopers webcast, said it would cost more than $100 billion over ten years, that it would only be considered as part of a broad tax reform, and that “It's not just a money generator.  It's a transition rule to deal with old earnings that were earned under the credit and worldwide system when you're moving to an exemption system.”

House Ways and Means 

Brady inherited an odd situation when he took over the Committee in November, coming in almost halfway through a Congress.  But he also replaced now- Speaker Ryan, who took key members of the Ways and Means policy team with him. Brady had to immerse himself in tax extenders negotiations pretty soon after he got the gavel.  The passage of the permanent extenders package will now give Brady a period of relief to get his bearings for a run at other policy priorities.  
He must now secure new hires for his office, which lobbyists have said could offer an indication of his intentions. During Ryan’s time on the Committee, fewer resources were committed to tax policy staff. 

Obama Overture and the EITC

Meanwhile, President Obama said at the SOTU address: "I'd welcome a serious discussion about strategies that we can all support, like expanding tax cuts for low-income workers without kids." It was an olive branch to Ryan, who has also made battling poverty one of his signature issues.  On that matter, note that both sides are interested in lowering the eligibility age for the EITC from 25 to 21 and doubling what those recipients can get, from $500 to $1,000.  

The stimulus-era expansions of the EITC just became permanent in the tax extenders deal, but GOP concerns about fraud in the program persist.  Ryan has said fraud savings could go toward offsetting the cost of an expansion. Obama proposed paying for the $60 billion 10-year cost of his proposal by changing the taxation of carried interest and eliminating a break self-employed professionals can use to avoid payroll taxes.

Both parties have come to see the EITC as a potent tool in fighting poverty.  In 2013, the EITC pulled about 6.2 million people out of poverty, according to Census data. SNAP benefits (aka food stamps) kept 4.8 million people out of poverty that year.

Wrap-up

Despite the reputation of election years being bereft of significant legislative activity, it looks as if we can expect some interesting actions over the next 12 months on the tax policy side.  Going forward, look for action from Sen. Hatch and Rep. Brady on their pet projects. Speaker Ryan’s well-deserved reputation on tax reform is also a factor in the future of this policy debate.   But there is not much to entertain the electorate in tax reform and Congress lacks for comity. 

--------

> On Jan 13, 2016, at 12:43 PM, Dana <[email-masked]> wrote:
> 
> Mike & Co. --
> 
> Just so you know:  “I’m in a primary right now.  We’re in no hurry to hold hearings.” So says Senate Banking Chair Shelby.  That explains why he won’t schedule one to fill a vacant Republican seat on the Ex-Im bank’s Board, which has only two of the five members it’s supposed to have.  That means it can’t approve loans above $10 million, a third of Ex-Im’s portfolio. 
> 
> Spoiler alert that the update below is another (requested) look at financial regulatory debate.  It might not seem like territory as friendly as, say, gun control and it's close the Vermont Senator's home turf of economic inequality but his advantage can be neutralized. 
> 
> Back to taxes tomorrow. 
> 
> Best,
> 
> Dana
> 
> -----------------
> The tangle in the Democratic primary over financial regulation ran over into a second week this week.  It is not quite a tangle on a specific issue between the two leading candidates as much as a proxy struggle between the campaigns and the commentariat, both trying to put the debate into the larger perspective of broad policy questions and themes.  
> The candidates' recent exchanges haven't grappled fully with the issues at contest while allowing Sen. Sanders to continue focusing on his so-far successful populist rhetoric.   His advantage here is bound to erode if the debate becomes any more substantive for a variety of reasons. 
> Glass-Steagall
> The US Banking Act of 1933, better known as Glass-Steagall, has been near the center of economic political discussions for decades.  The act was introduced in 1933 to separate the activities of commercial and investment banking, elemental in the New Deal effort to end one Great Depression and prevent others.    By the 1960s, the lines started blurring between commercial and investment banking activities as regulators began to allow commercial banks to undertake more securities activities.  There were so many allowances that many believe the Act was de facto dead by the time it was repealed in 1999.   I
> The substantive policy issue most in contention is the centrality of the 1999 repeal of the Act to the recession.  This is a fine place for it if you are looking for ways to trip a candidate up on the arcane business of commercial bank functions, their relatively incidental role in the recession, and the limits of Glass-Steagall (a vulnerability of his which I will happily expand upon in an update for those interested in the policy blow-by-blow).
> 
> Political Viability
> 
> The Sanders’ plan hinges on passing a new Glass-Steagall Act to permanently separate commercial and investment banking and then, importantly, breaking up the largest banks (he includes non-banks like AIG and Bear Sterns in this) within one year of taking office.  
> 
> What’s the professional commentary on Sanders’ plan to use Dodd-Frank section 121 to break up banks within one year?  One neutral analyst:  “unrealistic ... since you would probably need to replace Janet Yellen with someone who’s on board with this project, and her term won’t expire until early 2018.”  
> These considerations overshadow for the moment the practical political reality that most of the specific proposals being debated are unlikely to gain traction in the next Congress given the near certainty that the GOP will retain control of the House.
> But there is plenty at stake here and HRC has won probably the most important vote in this still muted and recondite debate. Barney Frank:  "There was this inaccurate argument out there that she's been weak on the subject... I don't know what that's based on, other than the fact she represented New York."  Getting Barney Frank's support is big and should be more ballyhooed.  But getting a small and ready stable of media savvy and intellectually able validators is not always easy. 
> The majority of rank-and-file Democratic primary voters may appreciate Sen. Sanders' obvious sincerity and passion on the issue.  He is relying on it; it is perhaps the central issue of his campaign.  But HRC's approach to regulation is no less thoughtful, certainly more detailed, and probably more systemically sound.  Moreover, it matters to voters who will have to work with at least half a Republican Congress.  And the Clinton plan is at least more viable than that of Sen. Sanders.  
> 
> Neutralizing the Advantage
> 
> Not that creating a roadmap of guaranteed legislative victories is HRC's plan.  The plan instead is to have a creditable rejoinder to Sen. Sanders' financial reform  proposals and to do so with ideas that blunt the semi-informed populist rhetoric and win the support of progressives and independents.  And to do it systemically -- HRC's dozens of proposals focus on be priorities for improvement and reach into every corner of the sector. 
> Sen. Sanders believes that the main cause of the financial crisis was the lack of Glass-Steagall, that had Glass-Steagall still been in place, the crisis would not have occurred.  This minority perspective is subject to challenge.  Few economic crises are the result of one single factor.  Even Sen. Elizabeth Warren agrees that the crisis probably could not have been avoided if Glass-Steagall had been in place.  Prevailing opinion even within the progressive commentariat agrees.  And In any event, the view disregards the large role that “shadow banking” had in causing the crisis independent of the depository banks.  
> Pressing the Advantage
> The New York Fed says that “[shadow] banking activities consist of credit, maturity, and liquidity transformation that take place without direct and explicit access to public sources" of liquidity and credit backstops -- the Federal Reserve’s discount window and the FDIC’s insurance on bank deposits.  The shadow banks take greater risks than their traditional counterparts, and they’re doing so with no public protections.  This was true during the Glass-Steagall era as well. 
> 
> Analysts of all stripes worry that that breaking up the largest banks or even passing a new Glass-Steagall Act would simply cause these activities to migrate elsewhere.  After all, shadow banking arose during the time of the first Glass-Steagall, what’s to stop it from surviving the advent of its successor?   Meanwhile, adding or tightening margin requirements on short-term “repo” lending, leverage requirements on broker-dealers, transparency on hedge funds, and revisiting the money market fund industry are the repairs to the sector's critical inter-institutional links needed to secure it. 
> Voters are legitimately concerned about the security of their jobs and future taxpayer-supported bailouts.  If the debate's focus shifts from resurrecting a long-dead Act to finding new, innovative and systemic solutions instead, and it is connected directly with anger about Wall Street bailouts or middle-class fears about being ripped off by the system, the ideas will resonate more deeply.  The new proposed provisions of Dodd-Frank work better for modern banking and the modern economy than the ideas presented in Glass-Steagall over 80 years ago. 
> 
> 
>> On Jan 8, 2016, at 6:29 PM, Dana <[email-masked]> wrote:
>> 
>> Mike & Co. --
>> 
>> 
>> The economy added 292,000 jobs last month, up from 252,000 in November. Unemployment was 5 percent, unchanged, with scant evidence of wage growth.  Labor force participation remained low, 62.6 percent, unchanged from November's 62.5 percent, close to its lowest level since the 1970s. 
>>  
>> Spring doesn't feel around the corner but at least primary politics is the season when a hundred policy flowers bloom.  This is true especially in tax policy, where all the campaigns' struggle to get a proposal noticed often ends up with novel ideas or a race to the bottom, or top, but usually away from the middle, a vulnerable place to be standing when policies are compared in the primary marketplace. 
>>  
>> We can ignore the flora and fauna since they are mostly for show and focus instead on what tax issues you can expect Congress will have, or may agree, to act on. 
>>  
>> Best,
>>  
>> Dana
>>  
>> ---
>>  
>> 
>> Almost everyone on the political landscape will have something to say about tax policy and priorities in 2016 but for now it is more about ideological positioning and image definition than how to get all the revenue we need to pay for the $3.5 trillion in total annual USG spending.  
>>  
>> Republican Tax Proposals
>>  
>> The tax theme for the GOP again in 2016 is simple: cut, cut, and cut.  Most GOP presidential candidates are touting plans which, to a varying degree, cut taxes drastically.  Of the three leaders in Iowa: Trump, Cruz, and Rubio, two promise to both simplify and lower the existing tax bracket system, while the other (Cruz) is pushing to establish a national income flat-tax.  The Republicans have all laid out their tax plans so far; the Democrats not so much yet.  
>> 
>> The tax policy debate over the next twelve months is likely to revolve around the proposals set forth by each party’s nominees.   What does that mean for tax policy debate in general?  Expect partisan lines to be drawn on any comprehensive tax reform proposals. There will be little room for sweeping bipartisan legislation.
>> 
>> It’s possible progress will be made in piecemeal fashion, with proposals and legislation focused on specific tax policies with support on both sides of the aisle.
>> 
>> A bipartisan base have waxed and waned in strength on international tax reform in recent years.  Could this be the year?
>> 
>> Senate Finance Chair Hatch: “I think it’s more likely that we could work out an international tax bill because there are a number of us that want to get rid of the inversion problem. We are working on that, to be honest with you. Both Democrats and Republicans ought to want to get rid of the inversions of our larger corporations over to other lower tax jurisdictions. . . I would have it done. We have some ideas that are pretty hard to beat.”
>> 
>> Speaker Ryan has a reputation as an ardent supporter of tax reform but both he and Ways and Means Chair Kevin Brady are saying they believe comprehensive tax reform is only possible if the GOP can take the White House.  
>>   
>> Legislative Prospects for 2016
>>  
>> Senate Finance in 2015 set up a series of working groups to discuss potential tax reforms in a variety of areas.  The working groups are listed below:
>>  
>> International tax reform:   The working group proposes ending “the lock-out effect” by adopting a dividend exemption system.  This and minimum tax proposals are expected to help end base-erosion and tax inversion activities.  The Finance Committee will continue to hold hearings on international tax reform in 2016, but no legislation has been introduced yet.
>>  
>> Business income tax reform:   This group has put forward proposals to lower business income taxes.  The group’s report also catalogued recent legislation proposals, including the cash method of accounting, a pass-through entity business deduction, the research credit, publicly traded partnership rules, and corporate integration.
>>  
>> Individual tax:  The working group calls for tax simplification and the adoption of incentivizing tax policies, such as those that encourage charitable giving and saving for education.
>>  
>> Savings and investment:  The group’s report lists three goals for policymakers to pursue: (1) increasing access to tax deferred retirement savings; (2) increasing participation and levels of savings; and (3) discouraging early withdrawals from retirement accounts.
>>  
>> Community development and infrastructure: The working group has proposed creating an alternative for funding the Highway Trust Fund.  Proposed solutions are meant to increase available funds to “... fix America’s roads and bridges, while also overhauling our broken tax code.”
>> 
>> Tax Extenders:  The passage of the tax extenders package through to the end of 2016 could give Congress some breathing room to pursue comprehensive tax reform legislation in the coming year.
>> 
>> Democratic Presidential Candidates
>>  
>> Neither of the Democratic presidential hopefuls have laid out their tax plans in full.  Each has promised to release their plan before Iowa caucuses.  Sen. Sanders has been tight-lipped about his tax plan, promising only to release his proposals “before the Iowa caucuses.”  What we do know is that he plans to raise the estate tax rate to 65% while lowering the estate tax inclusion level to $3.5 million.  He has also said he will raise the net investment income surtax by 10%.
>>  
>> Without having released a comprehensive tax plan, HRC has painted some details of the whole: tax rates on medium-term capital gains (investments held for fewer than six years) will be taxed between 24% and 39.6%.  Tax cuts to companies with profit-sharing programs, lower income taxes on “hard-working families,” and a $2,500 tax cut per student in those families.   HRC also proposes to end the “carried interest” loophole.  
>>  
>> Speaking recently, Secretary Clinton said “"As President, I'll do what it takes to make sure the super-wealthy are truly paying their fair share. The Buffett rule is one idea that would help achieve greater fairness in our tax system, and in the coming weeks, I will be laying out additional proposals that go beyond the Buffett rule.” With a promise to set out her plans sometime in the coming month, it’s a solid bet that we will have her full proposal before the Iowa Caucuses.
>>  
>> ----------------------------------------
>>  
>> A Brookings paper released in November studied potential key areas of tax reform to be addressed in 2016, laying out proposals covering five aspects of tax policy, a short description of each, along with their political potential are laid out below.
>>  
>> Raising long-term revenue
>>  
>> • Increase revenue by looking past increasing income taxes; enact a VAT tax or reduce specialized credits and deductions in the tax code.  
>>  
>> • The passage of the Protect Americans from Tax Hikes (PATH) Act of 2015 extended for two years, and in some cases indefinitely, a number of tax credits and refunds;while a VAT tax may find some support from Republicans, some Democratic lawmakers will consider such a tax to be regressive.
>>  
>> Increasing Environmental Taxes
>>  
>> • Environmental advocates, not to mention economists, have long pushed for a tax on the use of carbon, since President Obama’s “cap and trade” program’s failure there has not been a significant push for legislation of this type.  
>>  
>> • While many are in agreement that a carbon tax is an especially efficient way to make up for the externalities which arise from fossil fuels, that does not mean the idea has widespread political appeal; this is also considered a regressive tax, it would face strident opposition from the Oil & Gas sector, and it would need to be packaged with some sort of international agreement from other highly polluting countries to be seen as fair and effective.
>>  
>> Reforming the Corporate Tax
>>  
>> • Beyond lowering the corporate income tax to levels which either match or beat other developed countries, policy-makers might also consider changes to the tax structure which avoids so-called “double taxation” (taxing both corporate income and shareholder dividends) or even to change the corporate income tax to a corporate cash-flow tax.
>>  
>> • This is one area of tax reform that may be moved on in 2016, with Senate Finance Chair Orrin Hatch speaking favorably of its chances.  Don’t expect a change to a cash-flow tax, look for policies against inversion deals and which favor repatriation of profits at low tax rates.
>>  
>> Treating Low- and Middle-Income Earners Equitably
>>  
>> • This group lies in the gray area in which increased earning can trigger a reduction in government support payments; potential fixes for this problem include making more government assistance programs “work-based,” expanding eligibility for the EITC, and changing the Child and Dependent Care Credit into a refundable benefit.
>>  
>> • Republicans have long supported an increase in the Earned Income Tax Credit (EITC) and at least two presidential candidate (Sen. Rubio and HRC) have voiced support for increasing tax credit amounts for either the parents of children or families with students in college; it’s possible for these proposals to gain a footing in 2016.
>>  
>> Appropriately Tax High-Income Households
>>  
>> • The simple argument is that taxes against the wealthy are lower now than since the 1970’s, while their share of the national income has risen.  Thus, any increase in incomes will disproportionately benefit the wealthy, leading to an even greater difference in effective tax rates than now exists.
>>  
>> • This is a non-starter for Republicans, and is the least likely of any of the above categories to see any movement throughout 2016.  HRC and Sen. Sanders have hinted that their tax plans will include increases in the tax burdens faced by high-income earning Americans.
>>  
>> Keeping in mind both the current political climate and the probable environment for legislation in 2016, Brookings concludes  that “comprehensive tax reform is easy to talk about, but hard to do. The pursuit of sweeping tax simplification is a noble goal, but quixotic.”   Senate Majority Leader McConnell put the point bluntly, saying at the National Multifamily Housing Council annual luncheon this week, saying “The chances of this Congress doing tax reform with this President is zero.”
>> 
>> --------------
>>> Recent Updates:  
>>> 
>>> 2016 Tax Policy Issues  (Jan. 8)
>>> Sanders Proposals/GS & TBTF (Jan. 7)
>>> Sanders' Fin Reg Proposals  (Jan. 5)
>>> Year-End Review: Fiscal Policy (Jan. 1)  
>>> Year-End Review: Fin. Reg.  (Dec. 29)  
>>> Omnibus Review (Dec. 15)
>>> Omnibus Situation  (Dec. 14)
>>> FY 2016 Omnibus Talks (Dec. 10)
>>> Customs Bill  (Dec. 8)
>>> Tax Extender Negotiations  (Dec. 6) 
>>> Brown on HFT  (Dec. 4)
>>> Shelby 2.0 Update  (Dec. 3)
>>> HTF Conference Report  (Dec. 3)
>>> FY 2016 -- Policy Riders  (Nov. 30)
>>> Dodd-Frank and the CR  (Nov. 13)
>>> FRB Interest Rate Policy  (Nov. 9)
>>> Ryan and Tax Reform (Nov. 4)
>>> HTF/Pay-fors  (Nov. 3)
>>> FRB System Risk Rule  (Nov. 2)
>>> Ex-Im Reauthorization  (Oct. 30)
>>> Tax Extenders  (Oct. 30)
>>> Boehner Budget Deal (Oct. 27)
>>> Ex-Im Reauthorization  (Oct. 26) 
>>> Debt and Debt Limit  (Oct. 22)
>>> SEC Nominations  (Oct. 20)
>>> TPP/Currency Manipulation  (Oct. 15)
>>> Ex-Im Update  (Oct.  9)
>>> Fed Dividend  (Oct. 7)
>>> Debt/Extraordinary Measures  (Oct. 6)
>>> Jobs Report (Oct. 2)
>>> Fiduciary Rule  (Oct. 1)
>>> FY2016 Budget/CR  (Sept. 29)
>>> Trade/TPP  (Sept. 25)
>>> GSE Reform  (Sept. 25)
>>> Carried Interest  (Sept. 23)
>>> Bush Tax Cuts  (Sept. 15)
>>> Puerto Rico  (Jul. 23)
>>> Shelby 2.0  (June 24) 
>> 
>> 
>>> On Jan 7, 2016, at 8:50 AM, Dana <[email-masked]> wrote:
>>> 
>>> Mike & Co. --
>>> For better or worse, there have been few repercussions thus far among electeds or the media regarding the recent exchanges on financial regulation policy from the campaign trail this week (see photo below).  The differences in the nature of the candidates' proposals doesn't appear to be clear and sufficient to generate much momentum one way or the other. 
>>> But as relevant legislative activity on the Hill hasn't geared up quickly yet, we have time for a closer look below at the financial regulation discussion.  Tomorrow, the road ahead on tax policy on the Hill. 
>>> Best,
>>> Dana
>>> --------
>>> The proxy pas de deux this week featuring New York City Mayor De Blasio and Sen. Elizabeth Warren on financial reform has passed for now but drew some notice.  Tie goes to the front runner, for the moment.  
>>> The Mayor had not endorsed, governs in the heart of the nation's economic capital, and has street cred when it comes to progressive community and Wall Street.  So his clear preference for the HRC financial regulatory reforms plan over that of Sen. Sanders was dispositive and the comments of Gary Gensler at the outset had blunted Sanders' salvo and provided enough coverage for now.    
>>> Sen. Warren hasn’t endorsed a Democratic candidate for president yet either.  She may have had a preference for the Sander's package of reforms but did not endorse and named HRC in a tweet  praising all the Democratic presidential candidates alike on "fighting for Wall St reform."   
>>> The discussion may well move back to the wayside in short order but it is thematically significant enough to the premise of the Sanders campaign that it is likely to be revisited.  So though this round -- a muted draw -- is done, another engagement on the front can be expected before the finish line. 
>>> Where will it likely come from?   A quick look here at two leading possible policy trigger areas that have been central to the discussion, Glass-Steagall and Too Big to Fail" (aka Break up the Banks).  
>>> •   Reinstating Glass-Steagall -- 
>>> Asked to identify the biggest policy problems and industry practices that resulted in the financial crisis of 2008 and the deep recession that followed, few laymen would put the evisceration of Glass-Steagall at the top of the list.  Nothing akin to restoring Glass-Steagall came up for a vote in the immediate post-crisis years.  The Obama administration has come under occasional criticism for opposing its reinstatement in some form. 
>>> On Tuesday, Sanders embraced "a 21st Century Glass-Steagall Act, introduced by my colleague Senator Elizabeth Warren, [which] aims at the heart of the shadow banking system... In my view, Senator Warren, is right.  Dodd-Frank should have broken up Citigroup and other ‘too- big-to-fail’ banks into pieces.  And that’s exactly what we need to do.  And that’s what I commit to do as president.”
>>> 
>>> At the end of the day, Glass-Steagall is probably MEGO material to all but the most activist voters.  What does it matter if it doesn't make as a consumer better or get rid of TBTF -- which has spread much further into the lexicon than G/S while "break up the banks" is a rallying cry for some in the base.  
>>> 
>>> The more proximate causes include some other problems identified by Sanders in his speech, such as getting a grip on systemic risk, which gets attention. 
>>> 
>>> •  TBTF/Break up the Banks --
>>> A less-defined but more resonant concern is the faith of most Americans that Dodd-Frank will prevent post-2008 bailouts at their expense.  It is small solace that TARP returned a profit for taxpayers who will never see the return and whose paychecks haven't grown similarly.  No one wants to make another reverse transfer of wealth on that scale in the teeth of a recession again. 
>>> So it matters whether Dodd-Frank's Titles I and II governing systemic risk work or not.   Thankfully, they remain untested.  Opinion on their efficacy in the face of a crisis is diverse but it is admittedly a minority that believes the procedures in place should be given a chance to work in the absence of some better design.  
>>> The most popular view in almost all quarters is that maybe Dodd-Frank's operations would handle a one-off, single-firm liquidity crisis but would be overwhelmed by a full-blown simultaneous sectoral contraction.  So there is probably a policy that can address this ambient but legitimate concern without undermining the essential structure of DFA Titles I and II. 
>>> Quick postscript on the discussion that got some notice.  In his speech, Sanders said:  “Shadow banks did gamble recklessly, but where did that money come from? It came from the federally insured bank deposits of big commercial banks—something that would have been banned under the Glass-Steagall Act."
>>> 
>>> It is false that Glass-Steagall banned commercial banks from lending to investment banks.  Many academics and analysts agree with HRC that Glass-Steagall wouldn’t have prevented the crisis, because it wouldn’t have directly addressed the activities of problem firms such as insurer AIG and the investment banks Lehman Brothers and Bear Stearns.
>>> 
>>> Two additional perspectives...
>>> 
>>> Independent Community Bankers of America:    Glass-Steagall did not ban commercial banks from lending to investment banks, but I don't think that was Sander's point. The repeal of Glass-Steagall made lending to investment banks moot. The repeal of Glass-Steagall made commercial banks and investment banks one and the same. So all those relatively cheap insured deposits were there for the taking and for use in high risk and speculative trades.  Lending became unnecessary. 
>>> 
>>> Americans for Financial Reform:  Big commercial banks like Citibank and JP Morgan provided all kinds of support to shadow banking after the repeal of Glass-Steagall. They had massive exposures to 'toxic assets' and to failing investment banks through the securitization, repo, and derivatives markets, not through conventional lending. Preserving the original Glass-Steagall would have prevented some of those exposures, and the modernized 21st Century Glass-Steagall Act that Sanders has endorsed would ban almost of them. 
>>> 
>>> ---------------
>>> 
>>> Recent Updates:  
>>> 
>>> Sanders Proposals on GS & TBTF (Jan. 7)
>>> Sanders' Fin Reg Proposals  (Jan. 5)
>>> Year-End Review: Fiscal Policy (Jan. 1)  
>>> Year-End Review: Financial Regs. (Dec. 29)  
>>> !
>>> Omnibus Review (Dec. 15)
>>> Omnibus Situation  (Dec. 14)
>>> FY 2016 Omnibus Talks (Dec. 10)
>>> Customs Bill  (Dec. 8)
>>> Tax Extender Negotiations  (Dec. 6) 
>>> Brown on HFT  (Dec. 4)
>>> Shelby 2.0 Update  (Dec. 3)
>>> HTF Conference Report  (Dec. 3)
>>> FY 2016 -- Policy Riders  (Nov. 30)
>>> Dodd-Frank and the CR  (Nov. 13)
>>> FRB Interest Rate Policy  (Nov. 9)
>>> Ryan and Tax Reform (Nov. 4)
>>> HTF/Pay-fors  (Nov. 3)
>>> FRB System Risk Rule  (Nov. 2)
>>> Ex-Im Reauthorization  (Oct. 30)
>>> Tax Extenders  (Oct. 30)
>>> Boehner Budget Deal (Oct. 27)
>>> Ex-Im Reauthorization  (Oct. 26) 
>>> Debt and Debt Limit  (Oct. 22)
>>> SEC Nominations  (Oct. 20)
>>> TPP/Currency Manipulation  (Oct. 15)
>>> Ex-Im Update  (Oct.  9)
>>> Fed Dividend  (Oct. 7)
>>> Debt/Extraordinary Measures  (Oct. 6)
>>> Jobs Report (Oct. 2)
>>> Fiduciary Rule  (Oct. 1)
>>> FY2016 Budget/CR  (Sept. 29)
>>> Trade/TPP  (Sept. 25)
>>> GSE Reform  (Sept. 25)
>>> Carried Interest  (Sept. 23)
>>> Bush Tax Cuts  (Sept. 15)
>>> Puerto Rico  (Jul. 23)
>>> Shelby 2.0  (June 24) 
>>> 
>>> 
>>> On Jan 5, 2016, at 9:50 PM, Dana <[email-masked]> wrote:
>>> 
>>>> Mike & Co. --
>>>> 
>>>> Welcome back.  Seat belts buckled?  2016 opened with a multi-percent loss in capital markets across the board globally the first day and a speech by Sen. Sanders outlining his financial regulatory priorities, replete with criticisms and challenges directed at HRC's proposals the next day.   
>>>> 
>>>> For now, a quick survey here of the policy recommendations in Sen. Sanders' speech, with more analysis, etc., in an update to follow. 
>>>> 
>>>> Best,
>>>> 
>>>> Dana
>>>> 
>>>> --------
>>>>  
>>>> In a speech at the Town Hall near Wall Street this afternoon, Sen. Bernie Sanders laid out his plan to regulate some of the nation’s largest banks.  Other proposals included governance reforms at the Fed, caps on credit card interest rates and ATM fees, and allowing post offices to offer banking services.  
>>>>  
>>>> Sanders’ main proposals aim to
>>>> Identify and dismantle all breaking up banks deemed “too big to fail” by Treasury in the first year in office
>>>> Re-impose Glass-Steagall, separating commercial banking and investment banking
>>>> Cap ATM fees at $2 and credit card interest rates at 15 percent
>>>> Turn credit rating agencies into non-profit group
>>>> Enact a tax against speculative investment
>>>> A brief drill down on these proposals:
>>>> 
>>>> Too Big to Fail --  The idea, in the first 100 days, is to direct the Treasury Department to make a list of “too big to fail ... commercial banks, shadow banks, and insurance companies whose failure would pose a catastrophic risk to the United States economy without a taxpayer bailout."  Within one year, break these institutions down to size or otherwise resolve them, using Section 121 of Dodd-Frank. Section 121 allows the FSOC to direct the Fed Board to vote to resolve a financial institution deemed a systemic risk to the national economy. This requires a two-thirds majority of the Board to vote and only applies to bank holding companies with assets exceeding $50 billion, or Fed-supervised non-bank financial companies. 
>>>> 
>>>> No explanation was provided as to how to deal with inaction or  unwillingness by the Fed to force these institutions into resolution. It's a little hard to see what improvement, if any, the props makes to the resolution Title 1 and 2 process provided in Dodd-Frank except by adding an option to streamline it marginally.  Note that several pieces of legislation to break up large banks have been introduced in Congress since the crisis, but none have won much support by either Democratic or GOP majorities.
>>>> 
>>>> Reinstatement of Glass-Steagall --  This was initially proposed by Sens. Elizabeth Warren and John McCain last year. Sanders co-sponsored. Sanders today: “Shadow banks did gamble recklessly, but where did that money come from? It came from the federally-insured bank deposits of big commercial banks, something that would have been banned under the Glass-Steagall Act.”
>>>> 
>>>> HRC has repeatedly indicated wholesale support for Dodd-Frank, has proposed a robust set of systemic reforms to improve it, and has argued that restoring Glass-Steagall would not have prevented the crisis of 2008.   
>>>> 
>>>> Credit Rating Agencies --  The plan calls for turning for-profit ratings agencies (including Moody’s, Standard and Poor’s, and Fitch) into not-for-profit institutions.  
>>>>  “No longer will Wall Street be able to pick and choose which credit agency will rate their products,” said Sen. Sanders.
>>>>  
>>>> Reform the Federal Reserve --  Sanders alleges the Fed suffers from “regulatory capture,” and is now run by the same sector that it is supposed to regulate.  The plan would, "structurally reform the Federal Reserve to make it a more democratic institution responsive to the needs of ordinary Americans, not just the billionaires on Wall Street,” by reforming the practice of setting aside some Board seats for representatives of large financial institutions. The Fed would be restricted from active banking industry executives, ending what Sanders calls, “the foxes … guarding the henhouse.”
>>>>  
>>>> Reform the Federal Reserve --  The Fed suffers from “regulatory capture,” and is now run by the same sector that it is meant to be regulating.  The plan would to “structurally reform the Federal Reserve to make it a more democratic institution responsive to the needs of ordinary Americans, not just the billionaires on Wall Street” by reforming the practice of setting aside some Board seats for representatives of large financial institutions.   The Fed would be restricted from active banking industry executives, ending what Sanders calls “the foxes … guarding the henhouse.”
>>>>  
>>>> The HRC campaign had called on Sen. Sanders yesterday to endorse her plan to regulate shadow banking.  But Sanders’ piecemeal proposals on shadow banking  barely scratch the surface.  Credible reformer Mayor Bill de Blasio calls her plan “the toughest, farthest-reaching plan of anyone running for President.”  The conversation is probably too bogged down in verbiage about recondite legislation like  Glass-Steagall to resonate outside the core of the base but HRC's proposals easily stand up to scrutiny so it is welcome. 
>>>> 
>>>>  -------------
>>>> 
>>>> Recent Updates:  
>>>> 
>>>> Sanders' Fin Reg Proposals  (Jan. 5)
>>>> Year-End Review: Fiscal Policy (Jan. 1)  
>>>> Year-End Review: Financial Regs. (Dec. 29)  
>>>> Omnibus Review (Dec. 15)
>>>> Omnibus Situation  (Dec. 14)
>>>> FY 2016 Omnibus Talks (Dec. 10)
>>>> Customs Bill  (Dec. 8)
>>>> Tax Extender Negotiations  (Dec. 6) 
>>>> Brown on HFT  (Dec. 4)
>>>> Shelby 2.0 Update  (Dec. 3)
>>>> HTF Conference Report  (Dec. 3)
>>>> FY 2016 -- Policy Riders  (Nov. 30)
>>>> Dodd-Frank and the CR  (Nov. 13)
>>>> FRB Interest Rate Policy  (Nov. 9)
>>>> Ryan and Tax Reform (Nov. 4)
>>>> HTF/Pay-fors  (Nov. 3)
>>>> FRB System Risk Rule  (Nov. 2)
>>>> Ex-Im Reauthorization  (Oct. 30)
>>>> Tax Extenders  (Oct. 30)
>>>> Boehner Budget Deal (Oct. 27)
>>>> Ex-Im Reauthorization  (Oct. 26) 
>>>> Debt and Debt Limit  (Oct. 22)
>>>> SEC Nominations  (Oct. 20)
>>>> TPP/Currency Manipulation  (Oct. 15)
>>>> Ex-Im Update  (Oct.  9)
>>>> Fed Dividend  (Oct. 7)
>>>> Debt/Extraordinary Measures  (Oct. 6)
>>>> Jobs Report (Oct. 2)
>>>> Fiduciary Rule  (Oct. 1)
>>>> FY2016 Budget/CR  (Sept. 29)
>>>> Trade/TPP  (Sept. 25)
>>>> GSE Reform  (Sept. 25)
>>>> Carried Interest  (Sept. 23)
>>>> Bush Tax Cuts  (Sept. 15)
>>>> Puerto Rico  (Jul. 23)
>>>> Shelby 2.0  (June 24) 
>>>> 
>>>>> On Dec 29, 2015, at 5:40 PM, Dana <[email-masked]> wrote:
>>>>> 
>>>>> Mike & Co.  --
>>>>> 
>>>>> After the GOP captured the Senate in the midterm elections, the main question in the financial regulatory world as 2015 began was whether Congress would rollback key parts of Dodd-Frank Act (DFA) as the GOP-controlled House had been voting to do over the previous four years.  
>>>>> 
>>>>> How did the two sides fare?  What issues were at play?  What have we learned and what can be expected in 2016?  
>>>>> 
>>>>> These questions are answered below as the Shelby bill is considered both as standalone legislation and as a rider on the omnibus appropriations bill, and the other major financial regulatory legislation of 2015 is reviewed. 
>>>>> 
>>>>> (NB:  some of you may have received a draft version of the below yesterday; you can disregard that draft.)
>>>>> 
>>>>> Best,
>>>>> 
>>>>> Dana 
>>>>> 
>>>>> -------------
>>>>> 
>>>>> In the tug-of-war between the financial industry and supporters of Dodd-Frank, the gains and losses were marginal on both sides in 2015.  Once again, the struggle resulted in another stand off between the industry's efforts to ease the regulatory burden of DFA and advocates' bid to expand its protections for workers, investors and increase resources for regulators.  Republicans blame leading Democrats in Congress and in the administration.  Financial reformers who spent all year trying to block regulatory rollbacks are crediting them.   
>>>>> 
>>>>> The financial industry urged Congress to soften several DFA regulations and sought to do this first through Senate Banking Chair Richard Shelby's bill entitled The Financial Regulatory Improvement Act of 2015.  The bill, more than 200 pages and consisting of eight wide titles, addresses wide-ranging areas of reform from changes to a key DFA threshold for enhanced prudential standards to the CFPB's qualified mortgage rule. 
>>>>> 
>>>>> Sen. Sherrod Brown, the top Democrat on Senate Banking, said Shelby's bill went too far:  "Democrats are ready, willing, and able to work with Republicans to get community banks and credit unions the regulatory relief they need right now... Rather than focusing on issues that enjoy broad bipartisan support, this draft bill is a sprawling industry wish list of Dodd-Frank rollbacks.  This sweeping proposal holds Main Street financial institutions hostage to a partisan effort to dismantle Dodd-Frank's consumer protections and sensible rules for the large banks and nonbanks that played central roles in the financial crisis."
>>>>> 
>>>>> The main provisions of the Shelby bill:
>>>>> 
>>>>> •   Community Bank Reg. Relief --  Comprising 25 different measures loosening regulations on the country's smallest banks: relief from privacy disclosure requirements; permission for privately insured credit unions to become members of the Federal Home Loan Bank system; an exemption for banks under $10 billion in assets from the Volcker Rule; and a requirement that the National Credit Union Administration hold public hearings and receive comment on its budget.  
>>>>> 
>>>>> The opening title also included several provisions criticized by Democrats, such as a change to the CFPB's QM rule allowing all loans held in portfolio to be eligible for the rule's safe harbor provisions -- a controversial measure altering how certain "points and fees" are calculated under the QM rule, it removes language regarding affiliated title companies that spurred much of the earlier criticism.  It further makes changes banning certain types of loans, such as "no-doc" loans that helped spur the financial crisis.
>>>>> 
>>>>> •   SIFI Threshold -- The bill would have multiplied the DFA threshold mandating tougher capital and oversight on banks by ten times to over $500 billion in consolidated assets, though regulators would have the discretion to examine any banks over $50 billion to be considered systemic.  The Fed Board could make a recommendation to the FSOC to consider a particular bank holding company, though the FSOC would have the ability to launch its own evaluation as well.  The FSOC would be able to vote to change the list of criteria over time, and the $500 billion threshold would also be indexed for GDP growth. Shelby was willing to narrow the $50-$500 billion window for deregulation he had first proposed.  Democratic aides involved in the discussions said Shelby was willing to go as low as $250 billion.  Democrats weren't willing to go above $200 billion. 
>>>>> 
>>>>> •   FSOC Process for Non-Banks --  This title would have codified changes to the FSOC process for designating nonbanks as systemically important, to provide additional transparency to the process.  Some in Congress have criticized FSOC's designation process as being too opaque.  The FSOC would be required to give detailed explanations for why regulators are considering a designation; provide opportunities for companies to meet with council representatives; analyze a company's remedial plan for removing a SIFI designation and allow for revisions; and offer an explanation if the council moves forward with a formal designation.  Regulators would also be required to hold a hearing for designated companies at least once every five years and would have to vote to renew the decision to designate.
>>>>> 
>>>>> •   Fed Governance Reforms --  The bill would have made several changes to the Federal Reserve System.  It would require the head of the New York Fed to be nominated by the White House and confirmed by the Senate.  It would also direct the formation of an independent commission to evaluate the structure of the Fed system, including looking at the number and structure of the Fed's 12 districts.  The Fed would be required to publish a study every two years on its regulation and oversight of non-banks, a provision that would sunset after 10 years.  The GAO would be required to publish a study looking at the agency's regulation of systemically important institutions, with an eye toward issues around regulatory capture.  
>>>>> 
>>>>> •  Swaps/Emerging Growth Firms  --  This title addressed several measures related to SEC registration and regulation.  Most notably, it would remove indemnification requirements on swap data so that it can be shared with foreign regulators more easily and would establish a "grace period" for emerging growth companies working toward an initial public offering.
>>>>> 
>>>>> •   Mortgage Finance System --  The bill included several provisions related to the mortgage finance system, including Fannie Mae and Freddie Mac.  It would prohibit Congress from using guarantee fees to offset unrelated government spending and would ban the sale of Treasury-owned preferred stock in the government-sponsored enterprises without the approval of Congress.  It would also direct the FHFA to provide Congress with updates on the establishment of a common securitization platform and would transition the platform to a non-profit available to approved issuers beyond Fannie and Freddie.  Finally, it would mandate that the GSEs' risk-sharing levels be at least 150 percent of the previous year's level, with at least half of the total as front-end risk sharing.
>>>>> 
>>>>> With such a wide variety of significant proposals, the Shelby bill was an overloaded canoe.  Senate Banking reported it out favorably in May, but only on a 12-10 party-line vote, not sufficient to be certain to clear the 60-vote filibuster hurdle to passage in the Senate.  
>>>>> 
>>>>> Over the months that followed, members and staff met frequently to discuss which elements of the bill had bipartisan support Shelby's participation in these meetings was occasional at best and the discussions never really became negotiations.  
>>>>> 
>>>>> Committee Republicans Crapo, Moran and Corker did not negotiate in place of Shelby, but they tried to find common ground with a few receptive Democrats on the Banking Committee, including Sens. Warner, Donnelly, Heitkamp, and Tester. 
>>>>> 
>>>>> By the end of September, the group came up with a rough framework that covered areas where the Democrats appeared willing to move closer to some of Shelby's proposals.  The Democrats were able to find some common ground with Republicans on key areas including easing regulations for community banks, creating a new carve-out for regional banks in Dodd-Frank and making changes to the way the FSOC polices big financial firms outside the banking sector. 
>>>>> 
>>>>> The ideas were presented separately to Shelby and Senate Banking Committee ranking member Sherrod Brown.  Brown, who had floated an alternative to the Shelby bill consisting only of the Shelby bill's title on supervisory relief for community banks, was not negotiating alongside the moderate Senate Democrats but his staff was kept in the loop.
>>>>> 
>>>>> In early November, Brown arranged a meeting between all the banking committee Democrats so the four who had been working with Republicans could update the rest on the discussions.  One Some members showed interest and others showed strong opposition.  
>>>>> 
>>>>> Then on November 10, Sen. Warren gave a speech on the Senate floor warning her colleagues against going down the same road that led to a controversial Dodd-Frank rollback to weaken restrictions on derivatives trading from being tucked into last year’s spending bill.  She called out Democrats who “want to get something done around here for a change... If there's anyone in this chamber, Republican or Democrat, who thinks they can slip goodies for Wall Street into these bills without a fight, they are very wrong," she said, referring to must-pass legislation including the upcoming appropriations bill.  In addition to the pushback from Warren and other outside groups, the compromise effort faced public and private opposition from Treasury.
>>>>> 
>>>>> Warren and reform advocates were mindful that they lost a round last December in the Cromnibus bill, when JPMorgan Chase and Citigroup lobbyists secured a change to Dodd-Frank rules on complex financial instruments known as swaps. 
>>>>> 
>>>>> Back in July, Shelby, a senior member of the Appropriations Committee, had his bill attached as a rider on the Financial Services FY 2016 appropriations bill.  But he got almost nothing in the final spending agreement.   After months of laying the groundwork, banks and their allies in Congress missed their big shot at moving a wide-ranging legislative agenda in a must-pass spending bill this year before the 2016 election cycle heats up.  
>>>>> 
>>>>> Among the major financial provisions​ that didn’t make it into the spending package:
>>>>> 
>>>>> •   Fiduciary Duty --  Per DFA, the Labor Department finally put forth a fiduciary rule in April, the first update of the government’s retirement investment advice regulations in four decades.  The rule, which would take effect next year, requires brokers and financial advisers to act in the “best interest” of retirement savers—a higher standard than current regulations, which only require advice be “suitable.”  The new rule aims to eliminate the potential conflict of interests between people who offer investment advice and companies that sell financial products at a time when individuals are made responsible for building their own nest eggs through programs like IRAs and 401(k)s that have largely replaced traditional pension funds that guaranteed life-long benefits. The financial industry has said it would raise the compliance costs and drive many financial advisers out of business while making investment advice unaffordable for middle-class savers.  Efforts to delay that rule making were turned aside. 
>>>>> 
>>>>> •  Community Bank Lending Rules --  A number of regulatory changes sought by small, locally focused community lenders, such as an exemption from certain mortgage underwriting rules for mortgages held in a bank’s portfolio.  These were not adopted. 
>>>>> 
>>>>> •   CFPB Governance​ --  A provision to create a board, rather than a single director, to govern the Consumer Financial Protection Bureau, and subjecting the agency’s budget to annual appropriations did not survive. 
>>>>> 
>>>>> Some financial regulatory legislation did make the cut: 
>>>>> 
>>>>> •   Fed Dividend --  In a surprise, the banking community lost a sizable source of revenue -- the annual Fed dividend paid to member banks, totaling $25 billion.   The highway bill passed earlier this month took some of the money that banks receive in dividends from the Fed to help pay for fixing the U.S.’s deteriorating roads.   The highway bill passed earlier this month took some of the money that banks receive in dividends from the Federal Reserve to help pay for fixing the U.S.’s deteriorating roads.  Wall Street was furious over the precedent of having financial firms pay for infrastructure projects and lobbied to get a provision in the spending bill that would have given banks more flexibility to sell their shares in the Fed’s regional banks but the provision was rejected. 
>>>>> 
>>>>> •   USG's Stake in the GSEs --  A provision passed that prohibits Treasury from selling the government’s stake in mortgage-finance giants Fannie Mae and Freddie Mac until 2018 without future legislation.  The U.S. government bailed out Fannie and Freddie in 2008, and in return received warrants to acquire nearly 80 percent of the companies’ stock along with a new class of preferred shares.  Congress has tried​ unsuccessfully to pass legislation that would replace Fannie and Freddie with a new system, leading some of the companies’ proponents to push the Obama administration to take action on its own and sell the shares, now enjoined by this provision.  
>>>>> 
>>>>> An omnibus rider banning the SEC from requiring corporations to publicly disclose their political and lobbying expenditures managed to survive.  And negotiators included cybersecurity legislation designed to make it easier for the financial firms and others in the private sector to share threat information with the government.   
>>>>> 
>>>>> Five years after a crisis that shook the foundations of finance, Warren has public opinion on her side.  A Washington Post/ABC News published October finding that 72 percent of Democrats, 58 percent of Republicans, and 68 percent of independents want the next president to pursue tougher regulations on banks.
>>>>> 
>>>>> That public distrust has forced Wall Street — and financial services writ large — to make oblique arguments that don’t tackle head-on the unpopularity of the industry across the entire electorate. Republicans, trying to avoid an explicit alliance with Wall Street, regard their legislation as “reforms of the reforms” that Dodd-Frank made.
>>>>> 
>>>>> --------
>>>>> 
>>>>> Recent Updates:  
>>>>> 
>>>>> Year-End Review: Financial Regs. (Dec. 29)  
>>>>> Omnibus Review (Dec. 15)
>>>>> Omnibus Situation  (Dec. 14)
>>>>> FY 2016 Omnibus Talks (Dec. 10)
>>>>> Customs Bill  (Dec. 8)
>>>>> Tax Extender Negotiations  (Dec. 6) 
>>>>> Brown on HFT  (Dec. 4)
>>>>> Shelby 2.0 Update  (Dec. 3)
>>>>> HTF Conference Report  (Dec. 3)
>>>>> FY 2016 -- Policy Riders  (Nov. 30)
>>>>> Dodd-Frank and the CR  (Nov. 13)
>>>>> FRB Interest Rate Policy  (Nov. 9)
>>>>> Ryan and Tax Reform (Nov. 4)
>>>>> HTF/Pay-fors  (Nov. 3)
>>>>> FRB System Risk Rule  (Nov. 2)
>>>>> Ex-Im Reauthorization  (Oct. 30)
>>>>> Tax Extenders  (Oct. 30)
>>>>> Boehner Budget Deal (Oct. 27)
>>>>> Ex-Im Reauthorization  (Oct. 26) 
>>>>> Debt and Debt Limit  (Oct. 22)
>>>>> SEC Nominations  (Oct. 20)
>>>>> TPP/Currency Manipulation  (Oct. 15)
>>>>> Ex-Im Update  (Oct.  9)
>>>>> Fed Dividend  (Oct. 7)
>>>>> Debt/Extraordinary Measures  (Oct. 6)
>>>>> Jobs Report (Oct. 2)
>>>>> Fiduciary Rule  (Oct. 1)
>>>>> FY2016 Budget/CR  (Sept. 29)
>>>>> Trade/TPP  (Sept. 25)
>>>>> GSE Reform  (Sept. 25)
>>>>> Carried Interest  (Sept. 23)
>>>>> Bush Tax Cuts  (Sept. 15)
>>>>