Source: United States Senator for Colorado Michael Bennet
Denver — Colorado U.S. Senator Michael Bennet and John Hickenlooper joined a group of their Senate colleagues in expressing concerns to the Federal Reserve that federal regulators missed clear warning signs signaling Silicon Valley Bank’s (SVB) vulnerability to collapse. The letter comes as the Federal Reserve announced on Monday that it would conduct an internal investigation into its regulatory oversight and supervision of SVB.
It has been widely reported that SVB’s depositors consisted of venture investors and start-ups with close business partnerships, who were particularly vulnerable to shifts in interest rates. In their letter, the senators take issue with this financial interdependence, stressing that the Federal Reserve should investigate the role of concentration risk in the bank examination process and review the financial arrangements between Silicon Valley Bank and its customers. The letter emphasizes that it is the Federal Reserve’s duty to identify and mitigate such egregious risk in the financial system.
“It is gravely concerning that retail participants, utilizing only publicly available information, were able to identify clear and compelling examples of financial mismanagement and asset over-concentration at SVB, while the Fed, which can draw even deeper from non-public supervisory information, was unable to ascertain a similar conclusion,” wrote the senators.
“The fact that the San Francisco Fed, among other regulatory agencies, found no reason to take appropriate regulatory action or even investigate SVB further in the months, weeks, and days prior to the bank’s collapse must be addressed in a manner that restores public confidence in Fed supervision,” concluded the senators.
The text of the letter is available HERE and below.
Dear Vice Chair Barr:
We write to you today regarding the Federal Reserve (Fed)’s March 13 announcement that you are initiating a review of its supervisory and regulatory relationship with Silicon Valley Bank (“SVB”). While we understand the Fed, the Department of the Treasury, and the Federal Deposit Insurance Corporation needed to take swift action over the weekend to provide banking certainty and stability for American families and businesses, we remain deeply concerned that regulators may have missed clear warning signs in the lead up to the failure of SVB.
Safety and soundness is the cornerstone regulatory principle of the U.S. banking system and it is important we assess what went wrong at SVB to ensure future stability in the U.S. financial services sector. Specifically, we support any efforts that will provide further information on all relevant risks, actions, and inactions – taken by SVB and by regulators, supervisors, and examiners – that contributed to this failure. It is gravely concerning that retail participants, utilizing only publicly available information, were able to identify clear and compelling examples of financial mismanagement and asset over-concentration at SVB, while the Fed, which can draw even deeper from non-public supervisory information, was unable to ascertain a similar conclusion. The fact that the San Francisco Fed, among other regulatory agencies, found no reason to take appropriate regulatory action or even investigate SVB further in the months, weeks, and days prior to the bank’s collapse must be addressed in a manner that restores public confidence in Fed supervision. We look forward to evaluating the results of your review, particularly with respect to the robustness of Fed supervision and examination of SVB.
Additionally, as part of your review, we ask that you place a particular focus on the role of concentration risk in the bank examination process. Specifically, we believe the Fed must grapple with how its examiners contemplate industry concentration. As widely reported, SVB’s customer base consisted heavily of venture capital funds, venture investors, and start-ups, many of whom have or have had financial relationships or business partnerships with one another. If true, this constitutes a unique level of financial interdependency among a customer base that is also particularly prone to interest rate risk, as evidenced by news reports which point to increased outflows of personal and business deposits in the days leading up to the bank run. The Fed should review the financing arrangements between SVB and its customers to determine their impact on the bank’s collapse. Allowing such a high concentration of these rate-sensitive customers with primarily uninsured deposits at any single bank strikes us as a compelling risk to the stability of the bank, the banking system, and to taxpayers writ-large that merits further inquiry.
We appreciate your consideration and respectfully request a response by no later than Friday, March 24, 2023. Thank you for your ongoing public service and your leadership in these challenging times. If you have questions or require additional information, please contact Michael_Wong@sinema.senate.gov and Ryan_Adam@tillis.senate.gov.
Sincerely,