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Federal Reserve Speeches·

Bowman, Initial Findings from Independent Review of Silicon Valley Bank

  • An independent review by the Starling Advisory Group was commissioned to examine the failure of Silicon Valley Bank (SVB) & the Federal Reserve's supervisory process.
  • The review found SVB failed due to unrealized accounting losses exceeding capital, a deposit base that was 94 percent uninsured & concentrated in venture capital firms, & a lack of operational readiness to use the discount window.
  • Supervisory staff knew or should have known about these vulnerabilities as early as March 2022 but failed to take prompt action to require SVB to reduce interest rate risk or vulnerability concentrations.
  • Delays in supervisory action were not caused by the 2018 regulatory tailoring mandate or directives from the former Vice Chair for Supervision, who had stepped down in October 2021.
  • A long-standing culture of risk aversion among staff, who believed it was safer to take no action than to risk error, significantly contributed to supervisory inaction.
  • Lack of clarity regarding decision rights compounded the culture of risk aversion, creating confusion over who held the authority to validate supervisory actions.
  • Analysis by Charles River Associates concluded that social media did not trigger or accelerate the run on SVB, noting 96 percent of related chatter occurred after the bank's failure was inevitable.
  • The Federal Reserve issued a Statement of Supervisory Operating Principles to refocus supervision on identifying threats early & taking decisive action to mitigate them.
  • New protocols will redirect examiner attention toward significant threats to financial stability rather than procedural footfaults & expand supervisory options beyond MRAs & enforcement actions.
  • Examination teams will now submit monthly reports directly to leadership to identify uncertainties, empowering staff to escalate concerns without fear & providing real-time visibility into needed guidance.