Global Investment Banks Look For Ways To Boost Profitability Despite Fundamental Industry Changes

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1 Global Investment Banks Look For Ways To Boost Profitability Despite Fundamental Industry Changes Primary Credit Analyst: Richard Barnes, London (44) ; Secondary Contacts: Stuart Plesser, New York (1) ; Matthew B Albrecht, CFA, New York (1) ; Table Of Contents Changes In The Industry Have The Potential To Spur Targeted Rather Than Broad Rating Actions Unprecedented Monetary Stimulus Has Suppressed Market Volatility Weak Client Activity Has Weighed On Investment Banking Sales And Trading Revenues Banks Look To Cost Controls To Manage Short-Term Performance Structural Pressures Are Likely To Continue Investment Banks Diverge In Their Long-Term Strategies To Improve Returns Related Research SEPTEMBER 17,

2 Global Investment Banks Look For Ways To Boost Profitability Despite Fundamental Industry Changes The performance of the major global investment banks suffered in the first half of the year as structural and cyclical factors combined to stifle the sector's revenues. Stricter regulatory requirements, elevated litigation charges, and market reforms have altered investment banks' business models and depressed their balance sheets for some time, and will likely continue in the years to come. Moreover, highly accommodative monetary policies have suppressed market volatility and reduced client trading activity, contributing to a cyclical downturn in capital market revenues. By our measure, the largest global investment banks' aggregate capital market revenues were 11% lower in the first half of the year and 6% lower in the second quarter relative to the same periods last year. In our capital and earnings projections, we assume that revenues for full-year 2014 will be down 5%-10% from 2013 and remain broadly unchanged in 2015 relative to 2014, but, for certain banks, we may make adjustments to the forecast based on the make-up of their capital market businesses. Overview Our measure of aggregate capital market revenues showed an 11% drop in the first half of 2014 because accommodative monetary policies suppressed market volatility and trading activity, particularly in fixed-income businesses. This came on top of continuing structural pressures, including stricter regulatory requirements, elevated litigation charges, and market reforms. To offset weaker revenues, the priorities over the next 12 months for major investment banks are to cut costs, shrink noncore and low-return assets, and reallocate capital to businesses with stronger performance prospects. We see a divergence among banks' longer-term strategies to strengthen returns, with some fundamentally shrinking their investment banking activities, while others are maintaining a wide variety of services to clients. We do not envisage taking widespread rating actions as a result of the ongoing transition in the investment banking sector, but selective changes are possible. For banks with material capital market businesses, we believe that the main difficulty is to deliver earnings metrics consistent with shareholder expectations while maintaining balance-sheet ratios that meet evolving regulatory requirements. To boost returns, the major players are cutting costs, shrinking legacy and noncore assets, and re-allocating capital to business segments with stronger competitive positions and performance prospects. We see significant divergence among banks' longer-term strategies to strengthen performance. Some are fundamentally reducing their presence in investment banking because they have greater confidence in the earnings prospects of more capital- and leverage-efficient businesses, such as wealth management. In contrast, other banks are maintaining a wide variety of products available to customers in the hope of gaining market share as competitors withdraw. SEPTEMBER 17,

3 Changes In The Industry Have The Potential To Spur Targeted Rather Than Broad Rating Actions We do not anticipate taking widespread rating actions as a result of these changes in the investment banking industry. However, we have made selective changes to certain banks' stand-alone credit profiles (SACPs) or to our counterparty credit ratings recently based on institution-specific developments, along with broader industrywide trends, and further changes are possible if events deviate significantly from our current expectations. Recent SACP changes or counterparty rating actions and legal issues include the following: In July 2014, we lowered the SACP and affirmed the counterparty credit ratings on BNP Paribas following its $9.0 billion fine for breaching economic sanctions under U.S. law. In our view, the fine represented an additional obstacle to the strengthening of the bank's capital position. In August 2014, we affirmed our ratings on Bank of America Corp. but maintained our negative outlook because of residual legal and regulatory risks associated with the mortgage business following its recent $16.7 billion settlement (see "The Largest U.S. Banks Should Be Able To Withstand The Ramifications Of Legal Issues," published on Nov. 25, 2013, on RatingsDirect). In April 2014, we raised the SACPs and affirmed the counterparty credit ratings on Credit Suisse AG and UBS AG because they strengthened capital to meet Swiss regulatory requirements. In July 2013, we lowered the SACPs and ratings on Barclays Bank PLC, Credit Suisse AG, and Deutsche Bank AG because we believed that regulatory changes and market conditions would put pressure on their investment banking businesses. We may similarly review the business position assessments of other institutions that, in our opinion, may be unable to adapt effectively to the changed operating environment. For example, the negative outlooks on The Goldman Sachs Group Inc. and Morgan Stanley partly reflect the impact that recently-finalized regulations, particularly the Volcker rule, could have on their ability to maintain their franchise. For the main operating entities of groups with significant capital market activities, we currently have a broadly even split between stable and negative rating outlooks (see table). To reflect a potential reduction in extraordinary government support as regulators finalize resolution frameworks, we have assigned negative outlooks in several cases. At present, we typically incorporate up to two notches of support in the counterparty credit and senior unsecured issue ratings of banks that we consider to have high systemic importance. Although we believe it will likely take several more years for governments to address the "too big to fail" issue decisively, the introduction of bail-in powers (in which bondholders, instead of the government, assume the burden in case of significant losses) and similar reforms may mean that extraordinary government support will be less predictable in the future. Accordingly, we revised the outlooks on certain U.S. bank holding companies to negative in June 2013, and we took similar actions on European banks and holding companies in April 2014 following EU legislative changes. Rating Components For Selected Banks With Capital Market Businesses Country Institution Operating company long-term rating/outlook Anchor Business position Capital and earnings Risk position Funding and liquidity SACP No. of notches of sovereign support Australia Macquarie Bank Ltd. A/Stable a- Average/ SEPTEMBER 17,

4 Rating Components For Selected Banks With Capital Market Businesses (cont.) Canada France France Germany Japan Switzerland Royal Bank of Canada BNP Paribas# Société Générale Deutsche Bank AG Nomura Holdings Inc.* Credit Suisse AG^ AA-/Negative a- Strong A+/Negative bbb+ Very Strong (+2) A/Negative bbb+ Strong A/Negative a- A-/Stable a- A/Negative a- Switzerland UBS AG^ A/Negative a- U.K. U.K. U.K. U.S. U.S. U.S. U.S. U.S. Barclays Bank PLC HSBC Holdings PLC* Royal Bank of Scotland PLC (The) Bank of America Corp.* Citigroup Inc.* Goldman Sachs Group Inc. (The)* JPMorgan Chase & Co.* Morgan Stanley* A/Negative bbb+ AA-/Negative bbb+ Very Strong (+2) A-/Negative bbb+ A/Negative bbb+ Strong A/Stable bbb Strong A/Negative bbb+ Strong A+/Stable bbb+ Very Strong (+2) A/Negative bbb+ Strong Strong Strong Strong Strong Average/ Average/ Average/ Average/ Average/ Average/ Average/ Average/ Above Average/ Average/ Average/ Average/ Average/ Average/ Average/ a+ 1 a- 1 a- 1 bbb 2 a+ 1 bbb 2 a 1 Note: Sovereign support indicates that the ICR incorporates a positive assessment of the likelihood that a bank would receive "future extraordinary support" in a crisis from a sovereign government. *Holding company. The rating and outlook shown are for the main group operating company. #Rating includes a one notch positive adjustment under paragraphs of our bank rating criteria. ^Rating includes a one notch negative adjustment under paragraphs of our bank rating criteria. ICR--Issuer credit rating. SACP--Stand-alone credit profile. Data as of Sept. 11, 2014 In our view, the restructuring measures that investment banks have implemented since the global financial crisis have reined in the worst excesses of leverage, risk-taking, and dependence on short-term, wholesale funding, which is a positive to our ratings. The tightening of regulatory requirements appears to have reduced the possibility of a return to the riskier business models that pervaded in the industry in In our view, the reform process, especially in Western Europe and the U.S., favors simpler and better capitalized and funded business models that are easier to resolve and have lower embedded risk (see "How The Regulatory Reform Process Could Reshape Banks' Business Models And Affect Issuer Ratings," published on Aug. 18, 2014). Although the new rules will no doubt be arbitraged to some extent, regulators appear more determined to stand firm when banks seek to push the boundaries. Only time will tell whether regulators maintain this resolve. SEPTEMBER 17,

5 Despite this progress, segments of the capital markets, particularly trading, are likely to remain fundamentally more opaque, cyclical, and confidence-sensitive than businesses such as retail and commercial banking, in our view. In most cases, ongoing balance-sheet deleveraging and risk reduction are more likely to support the current SACPs than cause us to raise SACPs, particularly while unresolved litigation cases loom over the sector and the global economic recovery remains a work in progress. Unprecedented Monetary Stimulus Has Suppressed Market Volatility Through low interest rates, quantitative easing, and soothing forward guidance, the world's major central banks have engineered easy monetary conditions that have indirectly raised asset prices and compressed volatility (see chart 1). More recently, geopolitical surprises in the Middle East and Ukraine triggered some fluctuations, and variations in interest rate policies have led to a little more foreign exchange volatility. Still, on the whole, markets remain relatively calm. Chart 1 With global economies now recovering and some central bank policies likely to tighten--though at different paces--asset prices could move abruptly, in our view, if market sentiment changes. For example, revisions to central SEPTEMBER 17,

6 banks' interest-rate guidance could lead to sudden flows out of fixed-income investments such as exchange traded funds and mutual funds. The specter of monetary policy tightening in the U.S. led to outflows from fixed-income mutual funds in summer 2013, but that trend has since reversed. A few months back, the high-yield bond market cooled following warnings from the Federal Reserve about possible overpricing. Since then, though, it has rebounded to some extent, as interest rates have come under further pressure and these higher-yielding bonds have come back into favor. Renewed market volatility may create new opportunities for generating revenues for investment banks, but asset-price jumps could also prompt revaluations of balance sheets. We believe banks are in a good position to manage market fluctuations because trading inventory is smaller and more liquid than it was previously. In addition, transactions are generally less complex and more prudently underwritten than before the crisis, although U.S. regulators have raised warning flags over emerging risks in leveraged loans. Weak Client Activity Has Weighed On Investment Banking Sales And Trading Revenues In normal times, a long bull market would likely create fertile ground for investment banks by offering plenty of trading and transaction opportunities. Advisory and underwriting revenues are clearly benefiting from the current market environment, but the lack of volatility has subdued volumes and therefore reduced banks' sales and trading revenues. The 11% drop in our measure of global aggregate capital market revenues in the first half of 2014 was principally due to lower sales and trading in fixed income and equities (see chart 2). In fixed income, credit and securitized products performed satisfactorily, but subdued market conditions hurt rates, foreign exchange and commodities especially. Low market volatility also hit cash equity and equity derivative revenues. SEPTEMBER 17,

7 Chart 2 Prior to the global financial crisis, investment banks were able to smooth fluctuations in client activity through income from proprietary trading, carry trades, and repurchase agreements. Subsequent regulatory changes have required banks to reduce these portfolios, and we expect that revenues will increasingly fluctuate in tandem with customer transaction volumes. The reduction in banks' holdings of illiquid securities, which are particularly susceptible to market-price risk, should reduce the potential for extreme earnings volatility but will also likely dampen returns. In contrast with sales and trading, underwriting and advisory revenues were favorable in the first half of 2014 because improving economic sentiment and strong equity prices encouraged higher transaction volumes (see chart 3). On the debt side, investors' search for yield while interest rates are low has increased appetite for leveraged finance, structured products, and high-yield bonds in particular. In turn, banks' credit and securitization sales benefited from the distribution of debt underwriting positions into secondary markets. Underwriting is an attractive business line for investment banks because it is relatively capital- and leverage-efficient if the banks sell down positions quickly. It's relatively straightforward to sell these types of instruments at present because of high market liquidity and investor appetite, but history has demonstrated that conditions can change rapidly. Banks have been managing and analyzing their distribution pipelines in a much more granular way than before the global financial crisis, but they remain at the mercy of market forces to a large extent. U.S. regulators have targeted these potential vulnerabilities through the SEPTEMBER 17,

8 Volcker Rule, which limits positions arising from underwriting mandates, in addition to normal trading inventories. U.S. regulators have also intervened to curb potential risks in domestic leveraged lending, although banks have been complaining of agencies enforcing rules unevenly. Chart 3 Although renewed volatility could spark at any time, our base-case expectation is that subdued market conditions will persist at least for the remainder of this year. Client trading activity picked up in the month of June, which meant that second-quarter revenue declines were smaller than banks had initially indicated, and conditions in the third quarter appear similar to those in the same period last year. In our projections of banks' capital and earnings, we assume that revenues will be 5%-10% lower in 2014 but could vary according to the business model of each bank. This is a little less than the actual 11% drop in the first half of 2014 because the second half of 2013 was also a relatively weak period. At this early stage, we assume that 2015 revenues will be broadly flat in 2014, though market conditions can change quickly depending on certain events. For example, the Federal Reserve and the Bank of England are currently contemplating raising interest rates, while the European Central Bank recently implemented a further rate cut in response to slowing eurozone GDP growth. This policy divergence could give more direction to markets and create better conditions for sales and trading. We believe that the current cyclical lull in trading activity will ease eventually. However, the investment banking SEPTEMBER 17,

9 sector's overall revenue pool and returns will most likely be lower than the unsustainable highs leading up to 2008 because of thinner margins, lower proprietary risk taking, and lower leverage. Over the next few years, we see room for growth in specific segments of the capital markets. For example, the European corporate sector has traditionally relied on bank financing to a large extent but is slowly turning more toward the bond market as stricter regulation raises the price and availability of bank credit. Banks Look To Cost Controls To Manage Short-Term Performance Investment banks are extremely focused on cost savings to support earnings and returns over the next 12 months. We believe improvements in business-as-usual efficiency are also necessary to allow for unavoidable cost increases, particularly expansion of risk and compliance resources and investment in enhanced technology for working with clients. As revenues have fallen, banks have reduced bonuses and cut staff, focusing on business units with weaker performance prospects. Banks have more freedom to trim these variable costs than fixed expenses. We've also seen banks undertake more fundamental and innovative changes to cut costs and simplify processes by reshaping their operational infrastructure. There are significant opportunities in this area because investment banks have traditionally run business models that keep work groups separate from each other, resulting in duplicative systems and processes. For example, fixed-income and equities divisions have typically operated as separate fiefdoms, but banks are increasingly seeking to integrate these activities to offset lower revenues. Banks are also exploring external solutions such as outsourcing core processes. Banks continue to keep a firm grip on the size of capital- and leverage-intensive exposures, such as securities inventory, repurchase agreement portfolios, and long-term interest-rate trading assets, on their balance sheets. For example, The Goldman Sachs Group Inc. estimated that it reduced its balance sheet by $56 billion in the second quarter by eliminating lower return transactions such as repos that were not integral to its franchise. Institutional investors have remarked on the negative effect that banks' reduced trading inventory has had on liquidity in certain secondary credit markets, such as for corporate bonds (see chart 4). Several banks have also pulled back from commodities markets, particularly physical commodity products because of new regulation and weak revenues. SEPTEMBER 17,

10 Chart 4 Many banks have created dedicated units to reduce noncore assets that do not fit with their current return targets or risk appetites. These typically feature legacy structured credit, commercial real estate, and private-equity positions, as well as exposures to monoline bond insurers and correlation trading portfolios. Favorable monetary conditions and investors' search for yield have enabled banks to trim these assets relatively quickly, completing disposals at or above their carrying values. As a result, banks have generally reduced their holdings of Level 3 assets, which banks value using models because of the lack of an active market (see chart 5). Nevertheless, residual exposures to Level 3 assets still represent meaningful proportions of capital, and small changes in model assumptions, such as the discount rate, can have a significant impact on valuations. SEPTEMBER 17,

11 Chart 5 Banks have mostly used the capital, leverage, and liquidity capacity released by the rundown of legacy assets to improve regulatory ratios rather than to fund alternative business opportunities. This is partly because of the need to strengthen balance sheets further, but also because banks see limited potential to deploy capital profitably in current market conditions. Metrics such as value-at-risk indicate that banks have constrained risk taking at present, but we have no doubt that it will increase again once market volatility and client activity pick up. Structural Pressures Are Likely To Continue While cyclical pressures on investment banking revenues will likely ease at some point, we believe that structural factors--including regulatory change, litigation costs, and market reforms--will continue to constrain the sector. Greater clarity around regulatory hurdles enable banks to plan a path ahead The global financial crisis revealed the inadequacies of regulatory requirements for the global investment banking sector, and subsequent changes have had a profound impact on institutions' balance-sheet strength and earnings potential. For some time, a lack of clarity about future regulations has limited banks' planning. Although regulators have yet to confirm some important details, we believe that there is now sufficient information for banks to plan their strategies. Consistency among national regulatory regimes is diminishing because authorities are focusing on local SEPTEMBER 17,

12 priorities over international harmonization, and we believe that this is contributing to the different restructuring and deleveraging plans that global investment banks are implementing. In addition to stricter requirements on capital, leverage, funding, and liquidity, banks are subject to a host of other regulatory changes, including stress testing, subsidiarization (also known as ring fencing, in which an entity acts as a stand-alone enterprise rather than relying on group resources), and so-called "balkanization" (which requires subsidiaries to meet regulatory requirements on a stand-alone basis, such as U.S. rules on foreign banking organizations), explicit restrictions on certain business activities, recovery and resolution planning, and curbs on employee compensation. It is difficult to identify which regulatory measure is likely to be the single biggest constraint on banks' activities, partly because regulators intend for reforms to complement each other. For U.S. banks, stress testing, the supplemental leverage ratio, and the Volcker Rule are the principle regulatory considerations propelling decision-making at present, in our view. For European banks, some ultimate regulatory requirements have become clearer, but capital buffers and leverage ratio requirements remain uncertain. The leverage ratio is a new feature of European regulators' toolkits and, depending on its final calibration, could be a difficult target for banks to meet given the structure of the European banking system (particularly the on-balance-sheet financing of residential mortgages). The prominence major global regulators have given to leverage ratios has encouraged derivatives dealers to reduce the ratio's denominator by negotiating compression trades or tearing up outstanding trades that the banks no longer need. Depending on the stringency of Europe's upcoming asset-quality review and stress test, these exercises could also become a binding constraint on banks' strategic planning. In addition, regulators have been pushing to reduce the complexity of the banks in terms of legal entities' booking capital market business. This has already resulted, to some degree, in reassigning clients to the affiliate that has taken on the market risk of each business line. Banks may also need to retool their risk management systems to account for a more segregated booking of business in local subsidiaries. As this regulatory push gains more traction, it could increase the costs for banks to run their capital market businesses. Litigation costs weigh heavily on capital generation through earnings Regulatory fines and litigation charges have been a significant drag on investment banks' earnings for some time, with regular announcements of settlements relating to interbank offered rates, asset-backed securities, U.S. mortgage repurchases, and other matters. Recently, authorities have been taking a harder line in negotiations with banks, particularly in the U.S., which creates more challenging and less predictable conditions for the banking sector, in our view. The upturn in legal costs raises regulatory capital requirements across the industry since the magnitude of fines and settlements that competitors pay is one of the factors banks often take into account in their operational risk models. Some portray litigation settlements as a cost of doing business for investment banks, similar to operational losses. Although a certain amount of legal expense is likely unavoidable, multibillion dollar charges on legacy business activities are far too large to be a routine aspect of banks' business models, in our view. With strong encouragement from regulators, banks are strengthening compliance functions and striving for changes in internal business culture in a bid to avoid significant legal charges. We recognize that such changes are complex and time consuming to deliver in SEPTEMBER 17,

13 practice, however. Litigation charges will remain a significant factor at least this year and next, in our view, and will significantly constrain capital generation through earnings. A number of regulatory and civil matters have yet to be resolved, including the alleged manipulation of foreign exchange rates, probes of high-frequency trading in so-called equity "dark pools," and antitrust issues relating to credit default swaps. Under our criteria, we include potential litigation exposures in our assessments of each bank's capital and earnings and risk position, which are two of the four bank-specific factors on which we base our SACPs. The principles governing the recognition of provisions differ between IFRS and U.S. GAAP, but in both cases this is a late-stage consideration. Litigation settlements have consistently exceeded the contingent or "reasonably possible" legal liabilities that some banks disclose to indicate potential losses greater than existing provisions. Accordingly, we believe that banks' latest regulatory capital ratios do not fully take into account most future litigation charges, by our measures. In our risk-adjusted capital ratio projections, we typically incorporate estimated settlement costs for each bank's outstanding legal and regulatory cases. However, since these charges are increasingly difficult to quantify, we recognize that any estimates or assumptions may be wide of the mark. Therefore, another analytical approach we use is to focus on the extent of the capital cushion that each bank maintains above the threshold at which we would lower the SACP. Market reforms lead to an overhaul of trading infrastructure The infrastructure of trading markets is undergoing significant change to improve its resilience and reduce interconnections between financial institutions. Over-the-counter derivative clearing and settlement processes continue to migrate to clearinghouses, with adverse implications for banks' margins and commissions. On the positive side, however, this helps to reduce the denominator of banks' leverage ratios and may bring higher business volumes in time because of price reduction. As exchanges grow, they could arguably become "too big to fail" in their own right, which increases the importance of robust capitalization, as well as margin and default fund arrangements (see "Clearinghouses Are Raising Their Game--But They Are Not Risk-Free," published June 5, 2014). The regulatory emphasis on transparency is also leading electronic trading platforms to enter fixed-income markets such as foreign exchange. This lowers banks' transaction margins and underlines the importance of larger-scale operations. Banks must undertake significant technology investments to differentiate themselves from competitors on service and deliver to clients more seamlessly. The market reform agenda also encompasses outright limits on certain activities, such as prohibitions on proprietary trading and hedge fund investments under the Volcker Rule and other equivalent measures. The nonbank financial sector has stepped into the space left by banks in some of these market segments and is also increasingly buying portfolios of banks' noncore and legacy assets. Investment Banks Diverge In Their Long-Term Strategies To Improve Returns The structural pressures on banks' performance requires more discipline regarding the long-term allocation of capital and leverage. Gone are the days when banks could use their balance sheets to win business, or hope to produce acceptable profits from second-tier, full-service investment bank franchises. In our view, banks have split into two SEPTEMBER 17,

14 broad groups as they consider how best to adapt their business models to maximize returns. Banks in the first group seek to maintain their current scale and increase market share to earn satisfactory returns from their larger capital bases and make required investments in technology. In our view, banks such as Deutsche Bank, Goldman Sachs, and JPMorgan Chase & Co. are in this category. The second group has concluded that they have better earnings prospects in other businesses. Therefore, they are fundamentally reshaping large parts of their capital market businesses, particularly in fixed-income segments such as long-term rates, to focus on products and regions where they have competitive advantages. We include banks such as Barclays, Morgan Stanley, and UBS in this second group. We view this strategic divergence as the result of the particular circumstances and business models of banks in each group. For example, U.S. investment banks have the world's largest corporate market on their doorstep, they are relatively well-placed to achieve new regulatory requirements, and they have already captured market share because European banks and other competitors have retrenched. It is therefore not surprising that most of them see further opportunities to increase scale and win a larger slice of a smaller overall revenue pool (compared with before 2008). On the other hand, Morgan Stanley and UBS have substantial wealth management franchises that are relatively capital- and leverage-efficient and arguably offer attractive, relatively predictable risk-adjusted returns. These institutions maintain a solid presence in products and regions where they are market leaders and which the banks consider necessary to serve wealth management clients, but these banks are scaling back capital allocated to other capital market activities. In short, under the new regulatory regime, banks have learned that their balance sheets are a precious commodity and that it no longer makes financial sense to offer all products to all customers in all locations. All and all, the capital market business has been undergoing significant changes over the past two years, largely stemming from new regulation, which has hurt profitability. Recent low volatility, which has dampened trading volume, has exacerbated this. Within the capital market business, there have been pockets of positive momentum, such as advisory and underwriting, spurred on by higher equity valuations, while others segments, such as fixed-income trading, have come under pressure. Still, a presence in the capital market businesses is integral to large investment banks to meet corporate and institutional clients' demands. Some banks are making hard choices, recognizing that they may need to pull out of some businesses and attempting to deftly carve out their niche without damaging their franchise. Others are taking advantage of this, garnering market share, while trying to rein in expenses to ensure the business is profitable. In our opinion, the capital market story is still unfolding, and the last word on the winners and losers of this business has not yet been written. Related Research How The Regulatory Reform Process Could Reshape Banks' Business Models And Affect Issuer Ratings, Aug. 18, 2014 Clearinghouses Are Raising Their Game--But They Are Not Risk-Free, June 5, 2014 Delving Deeper Into Global Trading Banks' Risks And Rewards: A Study Of Public Disclosures, May 22, 2014 How Regulatory Reform Is Reshaping The Future Of Investment Banking, April 7, 2014 Basel's Proposed Overhaul Of Capital Requirement Calculations For Banks' Trading Risk Is Only A Step Toward Greater Consistency, Jan. 31, 2014 The Largest U.S. Banks Should Be Able To Withstand The Ramifications Of Legal Issues, Nov. 25, SEPTEMBER 17,

15 Today's Shrinking Investment Banks Might Leave Stronger Shares And Margins For A Few Giants, Dec. 17, 2012 The Weakness In Capital Markets Revenues Appears More Structural Than Cyclical, July 2, SEPTEMBER 17,

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