I wish to thank Professor Kaufman for the opportunity to speak at this conference and with the chance to catch-up with some long-time friends.

In line with this conferences theme, I will highlight some of the ways that the rules have changed but, even more so and with great disappointment, how much the underlying economic and political forces have not changed.

First, in contrast to the views expressed by a previous speaker I see no reason why stress tests and risk simulations cannot account for the boom/bust cycles of the economy and the financial systems. Moreover, both economic and financial cycles can be and are integrated in a Bayesian Vector-Auto regression model which, in fact, we do work with at Wells Fargo. This approach to stress testing is far superior to the common approach of merely changing one input, often the federal funds rate or the unemployment rate, and then producing a scenario that represents a “valuable” test to a financial institution. Such one-variable tests are unrealistic as we know very well that the real world will often experience several economic series changes moving at the same time. For example, a (lower/higher) federal funds rate is accompanied by changes in inflation, growth, exchange rates as well.

Second, one factor in the economy that has not changed is the underlying social/political bias in public policy towards housing that has been part of our society for most of the post-WWII era. America’s overinvestment in housing has been a chronic complaint with this overinvestment being assisted from federal and state tax laws, bank regulatory policy and credit/interest rate subsidies. This has not changed in recent years and, in fact, has continued this year with the increase in Federal Housing Authority (FHA) in recent months at below market rates/very low down payment requirements even as delinquency rates rise on these same FHA loans.

Third, we have witnessed change in the short-run but without resolution in the long-run of the Fed’s role as policeman in the credit markets. Increased liquidity at the short-end of the yield curve has brought down Libor and TED spreads but are these short rates too low given that current yields are below that of the often-criticized pre-Lehman period? What about long-term rates? Currently, the Fed has indicated that they will reduce their support for Treasuries by the end of October and will gradually withdraw support for mortgage-backed and asset-backed securities by March of next year. Will the Fed’s involvement in these markets really diminish in the face of relatively high unemployment and a likely upward move for interest rates in general?