Signature Didn’t Have to Die, Either

cataloging the four days of chaos that led to the collapse of signature bank during the 2023 regional banking crisis
Nic Carter

Images: Alamy

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  • During Silicon Valley Bank’s (SVB) 2023 collapse, then-FDIC chair Martin Gruenberg rejected multiple credible offers to buy the bank and its deposits, according to people with firsthand knowledge
  • Sources say top VCs lobbied D.C. to bail SVB out for the sake of startups — to no avail, until Nancy Pelosi called the White House and asked that the bank’s uninsured depositors be made whole
  • The FDIC seized Signature bank to invoke the Systemic Risk Exception, which would allow uninsured depositors at SVB and other banks to be made whole, even though Signature was solvent and had the liquidity to handle the crisis, sources allege
  • The FDIC is currently trying to cover its tracks by investigating Signature as a possible precursor to legal action against the bank’s former executives

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The following piece of reporting proposes an alternative history of the events that led to the closure of Signature Bank in March 2023, based on conversations with sources and information in the public record. As with my reporting on Silvergate and the Operation Choke Point 2.0 scandal (which has since been validated by subsequent reporting and Congressional investigations), my sources include eight individuals with direct first-hand knowledge of the events reported herein. However, due to the highly sensitive nature of the information being shared, I am constrained in what I can share about their identities, and I can’t speak to their connection to the parties discussed here. Thus, readers would do well to approach my account with skepticism.

That said, my record speaks for itself. In early 2023, before the banking crisis kicked off, I was one of the first to report on the phenomenon that would become known as Operation Choke Point 2.0 — a coordinated crackdown led by the Biden administration against the crypto industry, operationalized through bank supervision. After my initial report, the three largest crypto-friendly banks found themselves either self-liquidated (Silvergate) or shut down by regulators (Silicon Valley Bank and Signature). The remaining few banks that offered services to crypto firms faced a variety of subsequent hostile consent orders and enforcement actions. As a result, for two years — until Trump’s election — ordinary, lawful crypto startups were largely frozen out of the traditional banking system.

My findings were initially labeled a conspiracy by the press and the administration, but they have since been validated in court documents, such as the FOIAed materials¹ released as part of Coinbase’s lawsuit against the FDIC. Regulators such as incoming FDIC Chair Travis Hill² and Fed Chair Jerome Powell³ have acknowledged that crypto firms struggled with debanking under Biden. The doctrine of reputational risk in bank assessment, which facilitated Choke Point 2.0, has since been withdrawn by both the FDIC and the OCC. And new data shows a notable spike in bank account closures that took place between March 2022 — a month after Trump-appointed FDIC Chair Jelena McWilliams resigned — and October 2024, immediately before President Trump was re-elected.

Much evidence remains hidden, but could be freed by Congressional subpoena or civil litigation — as was the case with payday lenders during Operation Choke Point 1.0. My core assertion has always been that the FDIC and Fed imposed a 15 percent limit on crypto deposits at banks following the FTX crisis, and we know this to be the case today. Of course, due to a culture of secrecy, FOIA evasion, and verbal rather than written guidance passed down by banking regulators, smoking guns have been hard to come by. As before, consider this piece an alternative interpretation of a story we’ve been officially told. I firmly believe the evidence will validate my account.

—Nic Carter

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Introduction

In March 2023, amid a regional banking crisis kicked off by the collapse of Silicon Valley Bank (SVB), the New York-based Signature Bank suffered a run on deposits and was sent into FDIC receivership by the New York Department of Financial Services (NYDFS). The FDIC (Federal Deposit Insurance Corporation), one of the top banking regulators in the U.S., then sold it to Flagstar Bank.

Much of the analysis since has focused on the high-profile failure of SVB, with Signature being considered just another casualty of the banking crisis, precipitated by rate hikes and a subsequent run on deposits. But the shutdown of Signature immediately raised questions. Was it really insolvent when it was shuttered? Was it targeted due to its crypto business? Had the government abused its authority by seizing it?

Immediately after Signature was sent into receivership, board member Barney Frank (the Frank in the Dodd-Frank Act) complained⁷ in the press that the bank was solvent and had been targeted due to its crypto-focused lines of business. At the time of its collapse, around 18 percent of its deposits were attributable to crypto firms — enough to raise eyebrows among regulators. The FDIC and Fed had begun closely scrutinizing banks serving crypto following FTX’s collapse in late 2022.

It wasn’t just Barney Frank who raised objections to the FDIC’s seizure of Signature. At a Senate hearing⁸ following the collapse, two Signature executives questioned the official version of events. The bank’s founder, Scott Shay, said under oath: “The bank was solvent — indeed, it was always solvent, with assets well in excess of liabilities even at the very end. And the bank had a well-defined and solid plan to continue in operation and withstand additional withdrawals. Although I believe the bank was in a strong position to weather its storm, regulators evidently saw things differently.” Eric Howell, Signature’s president when it was seized, testified: “I believe the bank was well-capitalized, solvent, and had sufficient borrowing capacity to withstand these and future withdrawals.”

If executive testimony and on-the-record statements from Signature leadership are to be believed, all of this is deeply unusual. The FDIC isn’t supposed to shutter solvent banks. And there were real costs involved. The agency suffered an approximate loss of $2.4 billion to its Deposit Insurance Fund (DIF) when it took Signature into receivership. NYDFS Superintendent Adrienne Harris, who delivered the bank into the hands of the FDIC, never actually admitted Signature was insolvent — citing instead⁹ a “crisis of confidence” in leadership, saying they “failed to provide reliable data.” But these are not ordinary reasons to close a bank with $110 billion in deposits and liquidate shareholders. New York Governor Kathy Hochul also alluded to the uniqueness of the situation, saying in a press conference¹⁰ on March 13th that the Fed, FDIC, and Treasury were “literally counting votes” about whether to liquidate Signature. But the closure of a large depository institution should be a straightforward technocratic process — not a political one.

So the question must be posed: why would the government close a bank with $110 billion in customer deposits, causing losses to shareholders and creditors, while imposing on other banks a special assessment (a one-time fee) to replenish the Deposit Insurance Fund, if Signature was solvent on that fateful weekend?

I believe I finally have the answer.

Based on sources with direct knowledge, my understanding is that Signature was an undeserving victim of circumstance. On Wednesday, March 8th, Silvergate announced its voluntary liquidation. (My previous reporting explores how Silvergate’s wind-down was triggered by an anti-crypto shift in FDIC policy, which left them without a business model and forced them into liquidation.) On Friday, a major run on Silicon Valley Bank caused the California Department of Financial Protection and Innovation to place it into FDIC receivership. At this point, the bank failures were localized to California, even though regional banks nationwide were starting to show signs of stress. But because the crisis was not considered “systemic,” SVB depositors — which included thousands of tech startups with uninsured deposits — were ineligible for a government bailout. Of $175 billion in pre-crisis deposits at SVB, around 94 percent were uninsured. This kicked off a furious lobbying campaign behind the scenes. Several high-profile venture capitalists made the case that SVB ought to be saved for the sake of the U.S. startup industry, but their pleas fell on deaf ears in Washington.

This changed, sources told me, when Nancy Pelosi placed a call to the White House on Friday asking for SVB depositors to be made whole.¹¹ But the FDIC couldn’t guarantee SVB’s uninsured deposits without invoking a rarely used mechanism called the “Systemic Risk Exception.”

The crisis was arguably not systemic at that point, with only one small crypto-focused bank (Silvergate) self-liquidating and SVB collapsing, so the Treasury went on the hunt for another bank on the brink.

That bank turned out to be Signature.

It fit the bill. Signature was already disliked in Washington, as it had banked some of Trump’s businesses in the past. It had a meaningful, albeit contained, crypto business, which included SigNet, a proprietary blockchain platform that facilitated the secure movement, storage, and issuance of digital assets — providing critical access for crypto companies to traditional banking rails. It had a larger share of uninsured deposits than many of its peers, as it banked a number of businesses and high-net-worth clients whose deposits far exceeded the $250k threshold. The stock was under pressure. It was experiencing a run following the closure of SVB on Friday (though executives felt the bank would weather it). And crucially, it was in New York. The collapse of an institution across the country would give the impression that the crisis had gone nationwide and was therefore “systemic.”

Contrary to what I believed in early 2023, when I labeled NYDFS Superintendent Adrienne Harris one of the architects of Operation Choke Point 2.0, it was the FDIC’s call. Per sources, Superintendent Harris was not eager to take Signature down, but she relented. Late on Friday night, the NYDFS began the process of seizing Signature, and on Sunday, the FDIC instructed New York to send the bank into receivership. Now, the FDIC had their “systemic” crisis, so the exception for Silicon Valley Bank was triggered. Pelosi got her way: uninsured depositors at SVB, Signature, and later, First Republic, would be made whole.

Signature died for the sins of SVB.

Four days of chaos

Martin Gruenberg | Alamy

To understand the full chain of events, we have to go back to early 2022, when Marty Gruenberg was reinstalled as FDIC chair. It’s widely understood that presidential candidate Biden had struck a deal with Senator Elizabeth Warren whereby she would support his candidacy in exchange for total discretion over the composition of his financial regulatory apparatus. Accordingly, she placed former staffers in the National Economic Council (NEC), the White House body that coordinates financial policy and helps vet candidates for key financial regulatory agency posts. It’s also understood that she had first refusal over financial regulators at the Securities and Exchange Commission (SEC), FDIC, Office of the Comptroller of the Currency (OCC), and the Fed.

In early 2022, FDIC Chair Jelena McWilliams was forced out of her seat, prompting a contentious fight over who would replace her. Rising star Adrienne Harris, who was running the NYDFS and had served in the Treasury Department and the White House under President Obama, was the favored candidate. The Congressional Black Caucus pushed hard for her nomination. Her ascension to the FDIC was practically fait accompli. Then–former FDIC Chair Gruenberg — aware of Harris’s status but with his eyes also set on the position — enlisted the help of his ally Elizabeth Warren, who was skeptical of Harris due to what she felt was an overly accommodating attitude toward fintech at NYDFS.

What happened next is commonly known among D.C. and financial regulator insiders: Warren’s protégés at the NEC and beyond, including Bharat Ramamurti, spread the rumor in the press that Harris had withdrawn her name from consideration, and leaked that her campaign for the FDIC role was troubled by issues that had surfaced during her background check. This was a lie: Harris’s record was squeaky clean — she had been thoroughly vetted for her role at NYDFS. But it was enough for Gruenberg to nudge ahead of Harris and regain his seat at the FDIC for a second term (which, with the benefit of hindsight, was a catastrophe).¹²

Gruenberg was in, thanks to Warren, and he would faithfully carry out her agenda. Specifically, Gruenberg executed¹³ on Warren’s desire to prohibit bank mergers, which she felt were anticompetitive.¹⁴

On Thursday, March 9th, Silicon Valley Bank was under real pressure. That day, it experienced outflows of customer funds totaling $42 billion — around a quarter of its depository base. Prompted by rapidly spreading fear on social media and an extremely online set of depositors, it was the fastest bank run in history.

Ordinarily, the run would have been seen as an opportunity for a larger bank to acquire SVB at a discount and provide the necessary liquidity to stop the crisis. And indeed, on Thursday night, there were three or four much larger parties that verbally approached the FDIC with credible offers to acquire SVB and all its deposits, according to sources familiar. One of these offers came from a Global Systemically Important Bank (G-SIB) (a “too big to fail” bank, one whose collapse would pose a serious threat to global markets). But because Gruenberg was obligated to Warren for his second chairmanship — and Warren would not have taken lightly to her de facto appointee approving a merger of that size — he nixed all the offers and allowed the situation to worsen. The CEOs who approached Gruenberg to purchase SVB would not speak publicly about their efforts, but individuals familiar with those discussions confirmed they took place.

An acquisition that included the SVB’s deposits would have ensured its uninsured deposits remained whole. Moreover, individuals familiar told me that had the acquisition of SVB been permitted on that fateful Thursday, the run would have stopped in its tracks; that day’s outflows constituted the fastest bank run in U.S. history, but the requested outflows the next day were more than twice the size.

On Friday, the situation deteriorated when SVB depositors attempted to withdraw $100 billion from the bank. Shortly before noon Eastern Time, SVB was taken into FDIC receivership. Nancy Pelosi then made calls to the White House and Treasury asking for uninsured SVB deposits to be guaranteed. Her husband, Paul Pelosi, ran a business based in San Francisco called Financial Leasing Services, which engaged in mezzanine startup lending. Sources familiar informed me that Paul Pelosi’s firm would likely have gone out of business or suffered severely adverse consequences had uninsured deposits at SVB not been guaranteed.

It’s unclear whether Paul’s business interests were Nancy’s primary concern, whether she was simply trying to salvage a major Californian financial institution, attempting to prevent even more political fallout in an already strained relationship between Democrats and tech, trying to prevent a broader crisis precipitated by the total liquidation of SVB’s uninsured depositors — or any/all of the above. Interestingly, SVB was located in Ro Khanna’s district, not Pelosi’s; in other words, this wasn’t a case of her going to bat for a business in her own district.

Signature wasn’t like SVB — a specialized bank that served startups and VCs. Signature didn’t have the same flighty depository base of early-stage tech companies. The New York bank’s clients hailed from fairly quiet sectors like law and accounting, healthcare, manufacturing, and real estate. Signature had onboarded some crypto depositors, but that only represented 18 percent of its depository base. Though Signature was experiencing a run on Friday, it was fundamentally at less risk of insolvency due to its asset portfolio and “stickier” depositors.

As of Friday morning, not only was Signature’s financial position still robust — it actually experienced a net inflow of deposits despite the run on SVB. That day, the bank had $4.5 billion in cash, $26 billion in marketable securities, and around $29 billion in borrowing capacity (lines at the Fed and collateral pledged to the Federal Home Loan Banks (FHLB)) — all of this against around $89 billion in total deposits. Between the cash and lines of credit, they had around $33.5 billion in short-term liquidity. After the SVB closure on Friday, they immediately suffered a $2 billion outflow. Between 4 and 6 p.m. Eastern Time, they were down another $16.6 billion. Still, this did not put them in a state of illiquidity.

Given the circumstances, Fedwire was kept open until 11:30 p.m. on Friday, and Signature was able to avoid a technical default. After the extended banking hours closed on Friday, the requests for outbound wires kept coming. Signature leadership was concerned but confident that they could weather the storm, especially due to the “Barney Frank factor.” Frank was on Signature’s board and had good relationships with Washington, having served 32 years in Congress. He was the Chairman of the House Financial Services Committee during the Global Financial Crisis — exactly the type of well-connected Washington insider that could get a bank out of a tough spot. Signature leadership knew on Friday that they weren’t insolvent, but they needed liquidity against their collateral assets in order to open on Monday. At this point, they still had $15 billion in combined cash and borrowing capacity — if only they were permitted to use it.

Signature’s treasurer had not put in the request to borrow from the FHLB — a network of 11 regional banks across the U.S. that provides low-cost funding to member institutions, especially in times of stress — by close of business on Friday, but bank leadership felt it could easily unlock liquidity against those assets with a bit of cooperation from the Fed. Barney Frank leapt into action, drawing on his prodigious network. At around 5:30 p.m. ET, he called Jerome Powell. Powell referred him to Michael Barr, then Vice Chair of Supervision at the Fed. The ask was for the Fed to set up a triparty agreement allowing Signature to borrow from the Fed using their collateral parked at the FHLB, and to open the discount window over the weekend. Barr said he would look into it. He never called back.

Later on Friday night, one of Signature’s cofounders called the FDIC and was taken aback at the agency’s dismissive and unhelpful tone. He asked the FDIC to impress upon the Fed the gravity of the situation and to help persuade them to facilitate the triparty agreement with the FHLB to unlock Signature’s stranded collateral. At 7:30 p.m., the FDIC reached out to the Fed but was only able to reach midlevel staffers, not senior leadership. Fed staffers initially agreed to transfer Signature’s collateral housed at the FHLB to the Fed but subsequently rejected transfers several times that night. Meanwhile, NYDFS began the process of taking possession of Signature.

Over the weekend, Signature tried to make the case to NYDFS and the FDIC that they would still be able to open on Monday even without the collateral held at the FHLB, despite only having $4.6 billion of unencumbered cash with which to settle withdrawals. NYDFS estimated that Signature was facing $7.4 to $7.9 billion in pending withdrawals for Monday, but Signature had $3 billion worth of pending inflows from Circle coming in from SVB first thing Monday morning — which would have greatly enhanced, and added that much more to, its liquidity position. But NYDFS would not give Signature credit for this pending deposit. Signature also self-assessed that it had $8.7 billion worth of securities to borrow against if the FHLB/Fed triparty agreement were consummated, but it was not able to establish this due to the Fed’s reticence.

One point of contention, Barney Frank told me, was the FDIC’s assessment of Signature’s $15 billion residential loan portfolio in New York. He felt the Department was “undervaluing Signature’s solvency” due to its unwillingness to recognize the quality of the bank’s residential loans (against largely rent-stabilized buildings) versus the bank’s comparatively more risky commercial real estate portfolio. These distinctions, it appears, were missed in the fog of war.

The NYDFS carried out its marching orders from the FDIC and sent Signature into receivership on Sunday night. The New York financial regulator later blamed¹⁵ the shutdown on leadership’s inability to “provide reliable data and a credible liquidity strategy.” The words “insolvent” or “illiquid” do not appear in Superintendent Harris’s postmortem¹⁶ of the bank. Barney Frank told me that the bank “was solvent but not liquid. We could have become liquid with temporary funds from the Fed, which others later received.”

External assessments also validate Signature’s view that the crisis was survivable. As Senator Hagerty put it in the postmortem Senate hearing:¹⁷ “If you combine [the cash position and lending capacity] with the federal liquidity programs that were put in place over the weekend of March 11th and 12th, it appears that Signature was neither insolvent nor illiquid. At the very least, it seemed that it would have had the tools at its disposal to navigate all of this.”

On Sunday evening at 6:17 p.m., 47 minutes after NYDFS delivered Signature into the hands of the FDIC, the FDIC invoked the Systemic Risk Exception. This is not a minor thing. It required two-thirds of the Fed Board, two-thirds of the FDIC Board, the Treasury Secretary, and the President to all collectively agree. Now, Washington had the air cover it needed to invoke the exception and make SVB depositors whole.

None of them had to die

Barney Frank | Alamy

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Two years after the collapse, the commonly accepted narrative is that Signature failed due to mismanagement by leadership. The GAO’s postmortem¹⁸ reads: “FDIC found that Signature Bank’s planning and control weaknesses prevented it from adequately identifying, measuring, and controlling liquidity risk. We also found that poor governance and unsatisfactory risk management practices were root causes of Signature Bank’s failure.”

Some believe Signature was a political target due to its crypto affiliation, and at the margin, this may have made it a more attractive takeout candidate. Barney Frank was adamant this was the case, telling The New York Times,¹⁹ “I think we were shot to encourage the other [banks] to stay away from crypto.” And undeniably, by forcibly shuttering Silvergate and Signature — alongside their crypto settlement networks, Silvergate Exchange Network and SigNet — regulators dealt the crypto industry a huge blow.

I asked Barney Frank whether his view had changed in the two years since Signature’s collapse. Quite the contrary, he told me. His view that it was targeted due to its crypto business had strengthened, especially given the revelations in documents released in the Coinbase lawsuit against the FDIC, which revealed a long-running campaign against banks dealing with crypto.

Though I’m sympathetic to the anti-crypto hypothesis, more evidence now points to the SVB bailout thesis as the FDIC’s primary motivation. (Though was Signature a casualty the FDIC was happy to accept, given the bank’s crypto business? Barney Frank certainly thinks that’s the case.) The main reason Signature was left high and dry — without regulatory assistance or the time to save itself — was to justify invoking the Systemic Risk Exception necessary to protect SVB depositors. Virtually everyone I spoke to with familiarity of Signature’s financials told me that the bank wasn’t insolvent — only marginally illiquid at worst. Opinions vary on whether Signature needed additional liquidity to make it through Monday or whether it would have been able to manage on its own.²⁰ Every source for this story was adamant Signature would have survived with the slightest accommodation from regulators — accommodations that were freely granted to other banks during the crisis.

Evidence today suggests that the other banks that went under during the crisis didn’t need to either. Silvergate, as I’ve reported, had survived its bank run and was growing again when the FDIC, in early 2023, effectively prohibited it from operating its core business model. Silicon Valley Bank’s case was more complex, but a case can be made that it too was doomed by government policy. It’s worth quoting former SVB CEO Gregory Becker’s comments in a May 2023 Senate hearing²¹ at length:

Ultimately, I believe that SVB’s failure was brought about by a series of unprecedented events. Between 2015 and 2019, SVB grew from about $45 billion in assets to $71 billion in assets at an annual rate of about 10 percent. This changed in 2020 due to the COVID-19 pandemic and the government’s stimulus measures. With near-zero interest rates and the largest government-sponsored economic stimulus in history, more than $5 trillion of new deposits flooded into commercial banks. By the end of 2020, SVB had grown 63 percent over the prior year, and in ’21 SVB’s assets grew another 83 percent to $212 billion. To support this growth, SVB raised more than $8 billion of new capital in 2021. Importantly, throughout 2020 and late 2021, the messaging from the Federal Reserve was that interest rates would remain low and that inflation that was starting to bubble up would only be transitory. […]
To account for changing market conditions — namely, higher interest rates for longer — on March 8th, we sold SVB’s available-for-sale securities portfolio in a planned capital raise. Unexpectedly, on the same day, Silvergate Bank announced its intent to voluntarily wind down and liquidate, and depositors triggered a bank run. Despite stark differences in our business models, news reports and investors wrongly lumped SVB and Silvergate together. Rumors and misconceptions quickly spread online, culminating on March 9 with the first-ever social media bank run, leading to $42 billion in deposits being withdrawn from SVB in 10 hours — or roughly $1 million every second. Over two days, approximately 80 percent of total deposits were requested to be removed from SVB. To put the unprecedented velocity of this bank run in context, the previous largest bank run in U.S. history was $19 billion in deposits over 16 days.

The ultimate cause of SVB’s failure was the government’s massive COVID-era stimulus, which caused a 40-year high in inflation and subsequent interest rate hikes. These hikes collapsed the value of their fixed income portfolio. The proximal cause of the failure was Silvergate’s voluntary liquidation, which, as we’ve discussed, was triggered by an abrupt regulatory shift regarding deposits from crypto firms. Still, despite a historically rapid bank run, SVB didn’t need to messily collapse. Valid bids for the bank were turned away by FDIC’s Warren-installed Gruenberg, which would most likely have stopped the crisis from spreading further and prevented uninsured deposits from being liquidated.

The daisy chain continued. Signature was hung out to dry because allowing SVB to collapse — and with it, a huge fraction of the Bay Area startup sector — was either politically unacceptable with the approaching election year, economically disastrous, intolerable to Nancy Pelosi because of her husband’s business interests, or any/all of the above. The FDIC had to justify its Systemic Risk Exception with a non-California bank, and New York’s Signature was the sacrificial lamb.

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Today, the FDIC is trying to cover its tracks by investigating Signature as a possible precursor to legal action against the bank’s former executives. The investigation will attempt to frame Signature leadership as negligent. Naturally, little mention will be made of the outside forces that led to Signature’s demise — as was the case with the post-liquidation lawsuits against Silvergate, which completely elided the adverse regulatory shift that doomed them.

This continued harassment of one of the last prominent pro-crypto banks strikes a discordant note with Washington’s new, warmer outlook on crypto. The FDIC and OCC have indicated that banks are now free to serve crypto clients, and have abolished the use of reputational risk in bank oversight — the key tool used to stifle the crypto space during Choke Point 2.0. Interim FDIC Chair Travis Hill has made laudable moves to chart a new course for the agency. He has begun a kind of glasnost campaign, releasing troves²² of crypto-related communications from Gruenberg’s tenure. He has rescinded prior FDIC guidance and informed banks that they are free to engage in crypto activities without prior approval.²³ He has criticized U.S. banking agencies under the previous administration for “effectively prohibiting” banks’ usage of public blockchains.

Yet while Interim Chair Hill is pursuing a more accommodating course for the agency as it pertains to innovative activity at banks, career FDIC staff appear to be fighting the last war — trying to justify the questionable decision to destroy a solvent bank, and one that was known for its progressive approach to crypto. Michelle Bowman, Michael Barr’s presumptive replacement as Vice Chair of Supervision at the Fed, has pledged²⁴ to undertake an independent third-party review of the regulatory failures that led to the banking crisis in 2023. Instead of trying to rationalize prior bad decisions with frivolous litigation against Signature, bank regulators should revisit the circumstances of the bank’s collapse — and determine whether it was improperly closed, and why it was denied access to adequate liquidity facilities during the crisis.

For his part, Barney Frank remains adamant that Signature was targeted by the FDIC for its crypto-focused lines of business. He told me: “Some people at the FDIC were so opposed to crypto that the fear was not that we were going to fail because of crypto, but that we were going to succeed. And they didn’t want there to exist a successful example of a bank serving crypto.”

— Nic Carter

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FOOTNOTES

¹ FDIC letters give credence to ‘Choke Point 2.0’ claims | Banking Dive

² Charting a New Course: Preliminary Thoughts on FDIC Policy Issues | Vice Chairman Travis Hill

³ Fed’s Powell Says He’s Also Worried About Debanking That Strained U.S. Crypto | Coindesk

FDIC ‘plans to eradicate’ focus on reputational risk | Banking Dive

Bank Supervision: Removing References to Reputation Risk | OCC

How big of a problem is debanking? No one knows for sure | American Banker

Barney Frank Talks More About the Surprise Shuttering of Signature Bank | NYMAG

Examining the Failures of Silicon Valley Bank and Signature Bank | Senate Hearing

Signature Bank closed by NY regulator | Banking Dive

¹⁰ Governor Hochul Updates New Yorkers on Signature Bank | Press Conference

¹¹ That day, in a highly unusual move, the FDIC separated and moved SVB’s insured deposits into a newly-created Deposit Insurance National Bank of Santa Clara (DINB) and left uninsured deposits at SVB. The far more common practice would have been to move both insured and uninsured deposits into a bridge bank. It’ is unclear why the FDIC didn’t immediately create a bridge bank but separated SVB into two banks — one insured and the other uninsured.

¹² FDIC report outlines ‘misogynistic,’ ‘patriarchal’ ‘good ol’ boys’ workplace culture | AP News

¹³ Final Statement of Policy on Bank Merger Transactions | FDIC.gov

¹⁴ Senator Warren Urges Financial Regulators to Promote Greater Competition in Banking, Strengthen Bank Merger Review Guidelines | Senator Warren’s office

¹⁵ Internal Review of the Supervision and Closure of Signature Bank | NYDFS

¹⁶ Statement of Adrienne Harris before the Standing Committee on Banks | New York State Senate

¹⁷ Examining the Failures of Silicon Valley Bank and Signature Bank | Senate Hearing

¹⁸ Preliminary Review of Agency Actions Related to March 2023 Bank Failures | Government Accountability Office

¹⁹ Barney Frank, a co-author of key banking legislation, was on the board of one of the failed banks | NY Times

²⁰ Shares in other banks with tech exposure plunge after SVB’s failure | American Banker | American Banker

Which banks are at risk after the SVB collapse? | Finextra

²¹ Examining the Failures of Silicon Valley Bank and Signature Bank | Senate Hearing

²² FDIC Releases Documents Related to Supervision of Crypto-Related Activities | Acting FDIC Chair Travis Hill

²³ FDIC Turns a New Page on Banks’ Engagement in Crypto-Related Activities | Troutman Pepper Locke

²⁴ Michelle Bowman confirmation hearing | Senate Banking Committee


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