There is a fundamental inconsistency between the bank regulators believing that banks should fund themselves with the issuance of securities while not requiring banks to adjust their financials to show the mark to market value of their marketable positions. The securities markets are dependent on good disclosure. Pushing for additional securities issuances by banks that do not disclose market values of their holdings is attempting to solve on problem (failed oversight) by creating another (…

Commissioner Mersinger's advice applies to other agencies, and ought to be taken to heart by the SEC, in particular. The SEC is imposing fines with respect to recordkeeping violations that are completely out of proportion to the severity of the violations, which have not been shown to be connected to any related frauds. Some of the extravagant collections allow the regulators to portray themselves as battling ogres, when in fact they are just making bank on jay walkers and litterers.

The 2023 bank runs could be attributed in part to the bank regulators' failure to properly monitor banks exposure to interest rate risk and mismatches. (See, e.g. .) As frequently pointed out, this failure may have been in part the result of the excess amount of regulatory attention devoted to climate issues that are impossible to quantify and in any case not an imminent threat to the banking system. (See, .)  

It should also be noted that Treasury's actions to…

In theory, it sounds like a good thing for regulators to say that the list of risks that they worry about should be overinclusive and must account for the "unknown unknowns." The downside of this good thing is that it can become a justification for the government to exercise authority without any real basis, on the claim that it is protecting the system from risks that cannot be readily identified or quantified.