A statement released yesterday, entitled, "Federal Reserve and other central banks announce an extension of the existing temporary U.​S. dollar liquidity swap arrangements through August 1, 2012 says, "The Bank of Canada, the Bank of England, the European Central Bank, the Federal Reserve, and the Swiss National Bank today announced an extension of the existing temporary U.​S. dollar liquidity swap arrangements through August 1, 2012. The Bank of Japan will consider the extension at its next Monetary Policy Meeting. The swap arrangements, established in May 2010, had been authorized through August 1, 2011. Information on the actions taken by other central banks is available at the following websites: Bank of Canada, Bank of England, European Central Bank, and Swiss National Bank." The ECB'​s release says, "The Governing Council of the European Central Bank (​ECB) has taken a decision, in coordination with the Bank of Canada, the Bank of England and the Swiss National Bank, to extend the liquidity swap arrangements with the Federal Reserve up to 1 August 2012. The Bank of Japan will consider the extension at its next monetary policy meeting. The swap arrangements established in May 2010 had been authorised until 1 August 2011. The Governing Council decided to continue to conduct US dollar liquidity-​providing operations with a maturity of seven days. These operations will continue to take the form of repurchase operations against eligible collateral and will be carried out as fixed rate tenders with full allotment. The ECB will keep the necessity, frequency and maturity of its US dollar repo operations under review." See also, L.​A. Times' "​Money market funds see more outflows on Europe fears".

A Forbes Blog writes "​Fidelity Believes Its European Bank Holdings Safe". The piece, by Robert Lenzner, says, "Fidelity, the massive mutual fund management firm, headquartered in Boston, has taken the trouble to explain to me how it vetted all its holdings of European bank short term securities held in its giant money market funds." He quotes Fidelity, "Our money market mutual funds do not have any direct exposure to any banks based in Greece, Ireland, Portugal or Spain. Our money market mutual funds' European bank exposure is well diversified across a dozen countries and is concentrated with those banks that are deemed to be the "​national champions" -- the highest quality, most systemically important banks of each country. The funds invest only in very high quality U.​S. dollar-​denominated, short-​term debt instruments. We seek to provide shareholders with stability, liquidity and yield, in that order. The funds remain very well positioned in light of the continued risk and uncertainty that is unfolding in Greece and across Europe. Since February 2010, our investment approach has factored in a default by Greece on its sovereign debt and the potential for a resulting contagion across the periphery of Europe.... The French banks that Fidelity money market mutual funds are investing in are among the strongest financial institutions in the world. They are well capitalized, have strong local deposit bases and represent minimal credit risk.... [​T]​he French banks can withstand significant losses on this sovereign exposure. This is an earnings issue, not a solvency issue. We have also focused closely on the liquidity pools that these banks have built up over the past few years. These liquidity buffers are very, very large. For example, the largest banks in France each have over 100 billion Euro in immediate emergency liquidity." See also, the New York Times' "​In a Greek Default, Higher Risk for Money Market Funds" and yesterday'​s Wall Street Journal "​Is There Greek Debt in My Money-​Market Fund?".

Bloomberg writes "​Money Funds in U.​S. Unfazed by Greek Crisis Watch Out for Spain Contagion". It says, "The European debt crisis would pose a threat to U.​S. money-​market mutual funds if a rash of sovereign defaults caused big banks to fail to meet obligations within the next three months." Bloomberg quotes Vanguard CIO George '​Gus' Sauter, "It would take a very rapid decline and not just in the smaller European countries" for the debt crisis to threaten U.​S. money funds. "​You'​d probably have to see Spain and Italy get into difficult shape." The piece also quotes Alex Roever of JPMorgan Chase & Co., "It'​s not about whether Greece defaults, it'​s what happens after that, and there’​s uncertainty behind that." Bloomberg continues, "JPMorgan'​s Roever and Peter Rizzo, senior director of fund services at credit rater Standard & Poor'​s in New York, said U.​S. managers have been reducing their European bank holdings and shortening the average maturities of those remaining. That would allow them to withdraw more quickly without having to sell securities into a potentially illiquid market." They quote Federated Investors' Deborah Cunningham, "The risk is if something takes the crisis from Greece to Portugal, Ireland and beyond and it spreads like wildfire."

"​SEC'​s floating-​NAV proposal slowly sinking" writes Investment News. It says, "At a Financial Services Subcommitee hearing today, Republicans appeared to be backing away from a Securities and Exchange proposal that would force money-​market funds to adopt a floating net asset value. That'​s a proposal the mutual fund industry has fought for several months. Regulators and some members of Congress have proposed forcing money market funds to adopt a floating NAV -- as opposed to trying to keep a stable $​1 share price -- as a result of concerns about the stability of such funds stemming from the 2008 financial crisis. Last year, the President'​s Working Group on Financial Markets proposed eight reforms to provide greater stability in the money market fund industry. Among those proposed reforms was allowing money market funds to have a floating NAV. The industry has been protesting the idea, saying that it would cause money market funds to become extinct. And in opening comments during this morning'​s hearings, Rep. Scott Garrett, R-​N.​J., chairman of the Financial Services Subcommittee on Capital Markets and Government-​Sponsored Enterprises, agreed that there are concerns about the floating NAV concept." He says, "I am not convinced that replacing a stable NAV with a floating NAV solves the worry about runs in money market funds. There is compelling evidence that [​implementing a floating NAV] would lead to a loss of access to a significant source of short-​term funding. A floating NAV would also impact investors of all shapes and sizes." IN adds, "​Mr. Garrett also suggested that if the floating NAV was implemented it would have dire consequences for the money fund industry."

The LA Times writes "​Treasury bond yields dive again; some T-​bill buyers said to take less than zero". It says, "​Shorter-​term yields also slid. Heavy demand for three-​month Treasury bills -- considered the ultimate safe parking place -- drove their annualized yield to a mere 0.​008% from 0.​015% on Wednesday. Some trading services said T-​bill yields actually went negative for a time, meaning investors would in effect be paying the government to hold their money. The latest slide in T-​bill yields may reflect decisions by U.​S. money market mutual funds to cash out some of the short-​term European bank debt they own and bring the money home, as investors focus on potential risks stemming from the ongoing European government-​debt crisis." Also, ICI reports its weekly "​Money Market Mutual Fund Assets".

The Agenda has been posted for Friday'​s House Committee on Financial Services Hearing on "​Oversight of the Mutual Fund Industry: Ensuring Market Stability and Investor Confidence". The hearing will be Friday, June 24, 2011, at 9:​30 AM in 2128 Rayburn HOB on Capital Markets and Government Sponsored Enterprises. The Witness List includes: Mercer Bullard, Associate Professor, University of Mississippi School of Law, Andrew '​Buddy' Donahue, Partner, Morgan Lewis & Bockius LLP, Scott Goebel, Senior Vice President, Secretary, and General Counsel, Fidelity Management & Research Company, Heidi Stam, General Counsel, The Vanguard Group, Paul Stevens, President & CEO, Investment Company Institute, and Rene Stulz, Everett D. Reese Chair of Banking and Monetary Economics, The Ohio State University." ICI says, "We expect the hearing discussion to cover a broad range of mutual fund issues, including money market funds. Check the "​Live Webcasts" link on http://​financialservices.​house.​gov/.

Fox Business writes "​Congress Likely to Probe Money Market Funds Over Greek Exposure". The article says, "A Congressional hearing on the mutual fund industry this week will likely put money market funds under scrutiny for any holdings of Greek debt and other euro zone investments. The House Financial Services Committee announced June 3 that its capital markets subcommittee would conduct a standard oversight hearing of the industry this Friday. But the faltering $​160 billion Greek financial bailout, launched last year by the European Union and the International Monetary Fund, now threatens to put the industry on the defensive at the hearing -- especially its $​2.​7 trillion in money market funds, which are supposed to invest mainly in the safest short-​term debt securities to protect customers' cash." The piece adds, "But two weeks ago, a top Federal Reserve official warned that U.​S. money funds might be vulnerable to '​unexpected international financial problems' emanating from Europe.... The mutual fund industry and fund analysts have pushed back on arguments that money market investors are at greater risk with the unfolding events in Greece and EU countries." Also, see the Reuters blog "​Is it time to clamp down on money funds?".

The Wall Street Journal'​s Jason Zweig asks in his "​Intelligence Investor" column this weekend, "​How Much Will '​Floating Rate' Funds Really Float?" He writes, "Investors who have been loading up on "​floating rate" mutual funds this year to capitalize on rising interest rates might be in for a surprise—​even if rates rise. Floating-​rate funds are unique among fixed-​income vehicles, giving investors the potential to benefit from -- rather than be hurt by -- rising interest rates. They hold lower-​quality corporate loans whose interest payments can reset every three months or so, enabling the funds' yields to ratchet up if short-​term interest rates rise -- unlike conventional bonds, which go down in value when rates go up. With nearly everyone sensing that rates are bound to go up sooner or later, it isn'​t surprising that investors have become infatuated with floating-​rate funds.... Their assets have grown by 50% in just five months and have more than doubled over the past year to some $​70 billion. So what is the problem? Floating-​rate funds might not be quite as buoyant as investors expect. The income generated by bank loans has long been based on Libor, or the London Interbank Offered Rate, a standard measure of what banks charge one another to borrow. This week, the three-​month Libor rate was below 0.​25%, near all-​time lows. But about two years ago, bank loans began to include "​Libor floors," or minimum levels at which their income payments begin ratcheting upward if interest rates rise."

Yesterday, CNBC featured "​Why Your Money-​Market Fund Could Be Hit by Greek Default". The online article (​page down in the story for the link to the video) says, "Some of the safest, plain-​vanilla investment accounts in the U.​S. could be challenged if Greece defaults on its sovereign debt. Forty-​four percent of money-​market funds in the U.​S. are invested in the short-​term debt of European banks, according to a report from Fitch. A separate report from Moody'​s noted that 55 percent of those holdings are in the commercial paper of French banks, such as Societe Generale, BNP Paribas and Credit Agricole. French banks are some of biggest creditors to Greece, with over $​53 billion in outstanding loans to the Greek government and private sector. While fund managers have had plenty of warning of the potential of a default in Greece, many would likely still be caught off guard. Many fund managers assume that a bailout will prevent a default by Greece. The bankruptcy of Lehman Brothers similarly caught money-​market fund managers off guard, famously causing the Reserve Fund to "​break the buck.". The debt of these French banks is still very highly rated and Moody'​s says the risk of default on the short-​term debt is very low."

"​Stradley Ronon Attorney Authors 2nd Edition of The Guide to Rule 2a-​7" says a release posted last night. It explains, "Stradley Ronon attorney Joan Ohlbaum Swirsky authored the second edition of her book, The Guide to Rule 2a-​7: A Map Through the Maze for the Money Market Professional. This new and expanded edition reflects the recent amendments to Rule 2a-​7 -- a rule under the Investment Company Act of 1940, which seeks to limit the risk of money market funds. The book provides guidance to help address the complex requirements of Rule 2a-​7 and also offers direction on how to evaluate and revise products being offered for investment by money funds. For more information or to request a free copy of the book, go to http://​www.​stradley.​com/​book-​order-​form.​php. As of counsel in Stradley Ronon'​s investment management/​mutual funds practice group, Swirsky has counseled clients for more than 25 years, including more than 15 years advising investment companies on regulatory compliance and general corporate matters under the Investment Company Act of 1940." Note that Swirsky will presenting a "Regulatory Update: What'​s Next for MMFs," along with ICI'​s Jane Heinrichs at next week'​s Crane'​s Money Fund Symposium. (​Stradley has also generously agreed to provide copies of the new book to all conference attendees.)

Reuters writes "​Schwab clients slow down trading, go to cash". The article says, "Schwab'​s monthly activity report indicated investors may be heading to the sidelines. They steered $​1.​46 billion into money market funds in May while withdrawing nearly $​1 billion from U.​S. stock mutual funds. It was the third straight month of withdrawals from large-​company stock funds. Investors also pulled $​16 million out of municipal bond funds, the seventh consecutive month of net withdrawals. Rising money-​market fund balances hurt Schwab two ways: Fees earned from more lucrative stock funds are reduced, and the company, like its rivals, has been waiving fees on money-​market funds hit by ultra-​low interest rates." In other news, see The Atlantic'​s wacky "​Could a Greek Default Destroy American Money Market Funds?".

The Wall Street Journal writes "​Money Funds Trim Euro-​Zone Exposure". It says, "As worries grow about the euro zone'​s sovereign-​debt crisis, U.​S. money-​market funds have cut investments in the region'​s banks and shifted money to financial institutions in Norway, Sweden and Canada. The total dollar amount of holdings in commercial paper, certificates of deposit and asset-​backed commercial paper sold by euro-​zone banks dropped to $​361 billion at the end of May, accounting for about 40% of the $​902 billion of non-​U.​S. bank exposure of U.​S. money market funds, according to the latest data from J.​P. Morgan. U.​S. money funds' euro-​zone bank exposure was down from about 50.​9% at the end of March 2010, when the region'​s debt crisis started to brew." The Journal quotes Brian Smedley, interest-​rate strategist at Bank of America Merrill Lynch, "The critical question for money funds is whether the peripheral crisis eventually engulfs the rest of the European financial system." (​Note that subscribers to Crane Data'​s Money Fund Wisdom product suite should receive the latest set of Money Fund Portfolio Holdings (​as of May 31) Tuesday around noon.)

Dreyfus merged its Institutional Cash Advantage Plus Fund into Dreyfus Institutional Cash Advantage Fund. The recent SEC filing says, "The Board of Trustees for your fund, Dreyfus Institutional Cash Advantage Plus Fund, has approved the tax-​free reorganization of the Fund into Dreyfus Institutional Cash Advantage Fund. The Acquiring Fund, like the Fund, is a money market fund that seeks to maintain a stable share price of $​1.​00. The Dreyfus Corporation is the investment adviser to the Fund and the Acquiring Fund. The Fund and the Acquiring Fund are each a series of Dreyfus Institutional Cash Advantage Funds. The reorganization of the Fund is expected to occur on or about June 7, 2011. Upon completion of the reorganization, you will become a shareholder of the Acquiring Fund and will receive shares of the same class of the Acquiring Fund equal in value to the value of your shares of the same class you held of the Fund. Management of Dreyfus believes that the reorganization will permit Fund shareholders to pursue the same investment goals in a substantially larger fund that has the same investment objective and substantially similar investment management policies as the Fund. The Acquiring Fund has a comparable total expense ratio and a comparable performance record as the Fund. Management also believes that the reorganization should enable Fund shareholders to benefit from more efficient portfolio management and will eliminate the duplication of resources and costs associated with servicing the funds as separate entities. As a result, management recommended to the Trust'​s Board of Trustees that the Fund be merged with the Acquiring Fund."

Wells Fargo Advantage Money Market Funds' latest "​Portfolio Manager Commentary" says, "Although it'​s early to expect the Fed to exit its easing programs -- after all, we just got here! -- the steps that it might take to unwind the quantitative easing and drain bank reserves are fairly well known, having been previously discussed here and in other places in more detail. Basically, there are three specific tools in the Fed'​s toolbox that could be used. The first are the Supplementary Financing Program (​SFP) bills. In this program, the U.​S. Treasury issues Treasury bills specifically for the purpose of leaving the proceeds on deposit at the Fed, moving money from the reserve balances category to another type of liability. While the SFP bills have been popular with market participants, the current collision with the debt ceiling precludes their use right now. The second method of draining reserves is the reverse repurchase agreement (​RRP). In this arrangement, the Fed lends securities from its portfolio in exchange for cash, which comes from the RRP counterparties' bank accounts. Many money market funds, including certain Wells Fargo Advantage Funds, have already been approved to conduct RRPs with the Fed, and at the end of May it was announced that government-​sponsored enterprises (​GSEs) would be considered as counterparties. Clearly, the Fed is casting a wide net with the RRP program. The third method of draining reserves is the term deposit. Under this program, the Fed would take deposits from banks for a set period of time. This would have the effect of moving these funds from the reserve balances category to another category of liabilities. Moreover, although it has not been discussed as widely as the other alternatives, currency has a role here, too. If the demand for currency continues to increase, this would also drain excess reserve balances, which would take some pressure off these other alternatives."

"​DB Advisors acquires certain Standard Life Investments money market funds" says a press release posted Tuesday. It comments, "DB Advisors, Deutsche Bank'​s global institutional asset management business, has acquired some of Standard Life Investments (​Global Liquidity Funds) p.​l.​c.'​s money market funds. The acquisitions were completed on June 1, following a unanimous vote last month by shareholders in the funds in favour of amalgamation into DB Advisors' existing money market funds. The amalgamation adds approximately L2 billion of sterling assets, E1.​25 billion of euro-​denominated assets and a small balance of US dollar assets to DB Advisors' global liquidity management business." Reyer Kooy, Head of Liquidity Management for DB Advisors in the U.​K. & Ireland commented, "We are delighted to welcome investors in the Standard Life Investments funds as clients. We are committed to serving the needs of money market fund investors in the U.​K. and worldwide." The press release adds, "This amalgamation follows the successful conclusion of a similar initiative between DB Advisors and Henderson Global Investors. In March 2011, DB Advisors merged the Henderson Liquid Assets Fund into its Sterling-​denominated DGLS fund. Approximately L2.​5 billion of assets were transferred to DB Advisors. With approximately E85.​3 billion in money market assets under management (​as at March 31, 2011), DB Advisors is a leading provider of cash and short duration investment strategies for investors around the world." DB now ranks 7th among the 21 managers of "​offshore" money market funds tracked by Crane Data'​s Money Fund Intelligence International with $​37 billion in assets and 16th out of 78 U.​S. money fund managers tracked by our Money Fund Intelligence XLS with $​51.​5 billion in assets.

The Federal Reserve Bank of New York issued a "​Statement Regarding Reverse Repurchase Agreements" yesterday. It says, "​As noted in the October 19, 2009, Statement Regarding Reverse Repurchase Agreements, the Federal Reserve Bank of New York has been working internally and with market participants on operational aspects of triparty reverse repurchase agreements to ensure that this tool will be ready if the Federal Open Market Committee decides it should be used. Beginning tomorrow [​today], the New York Fed intends to conduct another series of small-​scale, real-​value reverse repurchase transactions using all eligible collateral types. The first set of operations will be conducted using only the expanded repo counterparties announced on May 23, 2011. The second set of operations will be open to all eligible reverse repo counterparties. Like the earlier operational readiness exercises, this work is a matter of prudent advance planning by the Federal Reserve. The operations have been designed to have no material impact on the availability of reserves or on market rates. Specifically, the aggregate amount of outstanding transactions will be very small relative to the level of excess reserves, and the transactions will be conducted at current market rates. These operations do not represent a change in the stance of monetary policy, and no inference should be drawn about the timing of any change in the stance of monetary policy in the future. The results of these operations will be posted on the public website of the Federal Reserve Bank of New York, together with the results for other temporary open market operations. The outstanding amounts of reverse repos are reported as a factor absorbing reserves in Table 1 in the Federal Reserve'​s H.​4.​1 statistical release, and as liability items in Tables 8 and 9 of that release." (​See also "​Reverse Repo Counterparties: Documents and Forms".)

Reuters' Kerber writes "​Split on money fund reforms driven by asset levels". The article says, "In a rare split, the clubby mutual funds industry is divided over how to backstop the $​2.​6 trillion kept in money market funds. It is a hot issue after one of the largest funds struggled during the financial crisis and ultimately '​broke the buck,' failing to maintain the $​1 per-​share net asset value considered sacrosanct by many investors. Regulators have already put tighter rules in place and are considering more, perhaps even doing away with the $​1 per share standard and allowing net asset values to "​float." Fund companies fear that change would be so drastic it would drive hundreds of billions of dollars away from their products and into traditional bank accounts." The piece quotes Peter Crane, "​whose Cranedata.​com site follows the industry," "The floating NAV is seen as the biggest threat to money funds as we know them." Reuters says, "​Within the industry, however, the dispute is over how much reform is needed to stave off the floating NAV. The fault lines gelled in May when three of the largest managers proposed each money market mutual fund should set aside some extra money for times of trouble, called an '​NAV buffer.' Proponents included Fidelity Investments, the largest money fund operator, plus powerhouses Charles Schwab Corp and Wells Fargo. With each fund maintaining its own buffer, the plan would avoid subsidizing smaller competitors or eroding the appeal of the largest managers as the safest. Most of the industry favors a broader approach that would spread out the risks, however, a plan rolled out in January by trade group the Investment Company Institute and backed by big players like Federated Investors and Vanguard Group Inc, as well as by smaller firms. The plan would feature a "​liquidity bank" to buy securities from troubled funds during a crisis, into which all fund families would pay." Finally, Kerber writes, "​The fate of all the proposals now lies with the Financial Stability Oversight Council, made up of top financial regulators and charged by Congress with reviewing risks to the financial system. A spokesman for the SEC, leading money fund reviews, said its next steps have not yet been determined."

Friday'​s Wall Street Journal writes "​In Stashing Cash, Look Ahead". It says, "The returns on low-​risk savings these days range from just about zilch to a little more than nothing. With interest rates at rock bottom, money-​market funds, bank accounts and ultrashort-​debt funds have been cranking out uniformly terrible returns. But investors should remember a crucial fact: Rates won'​t stay low forever. And when they rise, low-​risk vehicles may turn in very different results, since they have very different structures and investment philosophies. In looking at the various options, investors "​should think about how they will perform with certain interest-​rate changes," says Allan Roth, a financial adviser in Colorado Springs, Colo. Many economists believe in the first half of next year the Fed will start raising short-​term interest rates from its current target range of 0% to 0.​25%. And when the Fed does start raising rates, that might mean "​hikes as far as the eye can see," says Peter Crane, president of Crane Data LLC, which tracks money funds. Between June 2004 and June 2006, the Fed'​s rate-​setting committee boosted its target rate at 17 consecutive meetings. Here'​s a look at four low-​risk alternatives for savings and how they could be affected by the next increase in rates...." Friday'​s Journal also featured "​Should Investors Worry About Money Funds?", which featured the "​con" opinion piece, "​Why Investors Should Worry About Money Funds" and the "​pro," "​Why Investors Shouldn'​t Worry About Money Funds". Finally, see the press release, "Stradley Ronon Attorney to Speak at Crane'​s Money Fund Symposium."

ICI'​s Weekly Money Market Mutual Funds says, "Total money market mutual fund assets decreased by $​21.​86 billion to $​2.​726 trillion for the week ended Wednesday, June 1, the Investment Company Institute reported today. Taxable government funds decreased by $​13.​01 billion, taxable non-​government funds decreased by $​7.​25 billion, and tax-​exempt funds decreased by $​1.​60 billion. Assets of retail money market funds decreased by $​2.​34 billion to $​908.​09 billion. Taxable government money market fund assets in the retail category decreased by $​680 million to $​167.​63 billion, taxable non-​government money market fund assets decreased by $​970 million to $​544.​23 billion, and tax-​exempt fund assets decreased by $​700 million to $​196.​24 billion. Assets of institutional money market funds decreased by $​19.​52 billion to $​1.​818 trillion. Among institutional funds, taxable government money market fund assets decreased by $​12.​33 billion to $​594.​87 billion, taxable non-​government money market fund assets decreased by $​6.​28 billion to $​1.​112 trillion, and tax-​exempt fund assets decreased by $​910 million to $​111.​18 billion. See also, Treasury Today'​s "​Should you bother with US money market funds?" and The Wall Street Journal'​s "​Why Investors Should Worry About Money Funds".

The New York Times' DealBook writes "​Shadow Banking Makes a Comeback". It says, "The shadow banking industry is back -- and it could become bigger than ever, according to a new report by Standard & Poor'​s. As traditional lenders and big investment banks face a wave of new rules stemming from the Dodd-​Frank financial overhaul, their lightly-​regulated brethren -- money market funds, private investment companies and hedge funds -- see an opportunity to profit, S.&​P. said. These resurgent shadow-​banking firms are aiming to '​bolster their balance sheets to take on business that the banks discontinue,' according to the report. While the shadow industry has benefits -- like providing cheap financing to companies -- it also comes with plenty of risk to investors and the broader economy.... This flexibility, S.&​P. said, will also allow shadow firms to take on new lines of business that the banks are forced forgo."

The Boston Globe writes "​Getting out of a CD early will cost you". It says, "Savers, already enduring near record-​low interest rates on certificates of deposit, face a fresh insult: Banks are slamming customers with steeper penalties if they try to withdraw their money early. The state'​s three biggest retail banks -- Bank of America, Citizens Bank, and Sovereign Bank -- have significantly increased early-​withdrawal fees in recent months. In many cases, the penalties are so steep that they would not only wipe out accrued interest, but also eat into the principal.... Certificates of deposit often pay higher interest rates than traditional passbook savings, but require customers to leave the money in the bank for set terms, typically between a few months and five years. Some consumer advocates say higher penalties for early withdrawal are the latest effort by banks to find revenues to offset losses from bad loans and the cost of complying with new federal regulations."

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