Sky Blog
In many economic settings, gatekeepers play a central role. For example, auditors verify public firms’ financial statements, lawyers sign off on transactions by providing legal opinions, and bank regulators assess whether banks are financially sound. Gatekeepers influence the behavior of …
On September 8, 2025, the Fifth Circuit issued its opinion in Ortega v. Office of the Comptroller of the Currency, 2025 WL 2588495 (5th Cir. Sept. 8, 2025). Petitioners, former directors of a national bank, challenged the OCC’s …
We have argued that bank regulators should disclose more bank information than is now required.[1] This is because supervisory practices generally do little to promote transparency, which leads to opacity that interferes with the pricing of risk and undermines …
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and (ii) change the method for calculating the capital surcharge …
When the COVID-19 pandemic shuttered major economies in March 2020, it also wreaked havoc on financial markets. In the first few weeks of March, investment-grade corporate bonds lost roughly a fifth of their value, on par with the declines in …
As we approach the 10-year anniversary of the failure of Lehman Brothers, the news is again awash in a debate about whether policymakers could have saved the investment bank. That the issue remains so deeply contested reflects how fundamentally flawed …
The U.S. banking industry has exhibited increasing vulnerability to economic cycles since the easing of post-depression era measures designed to insulate banking from economic instability. Between 1934 and 2017 there were 2,758 commercial and savings bank failures.[1] Nearly 80 …
On March 22, 2013, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation (“FDIC”), and Office of the Comptroller of the Currency (collectively, the “agencies”) published “Interagency Guidance on Leveraged Lending (78 …