Steve Klein

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Steve counsels financial institutions about federal and state banking matters and related securities law and financing issues. Steve utilizes his background and experience as a bank regulator with the Comptroller of the Currency and as an accountant on Wall Street in advising our diverse group of banking clients throughout the Western United States.

Latest Articles

Context As many of you know, I spent six years as a bank regulator in the Securities Disclosure Division of the OCC. Since moving out to the Northwest, I have had the privilege of being involved with several hundred community banks ranging from de novos to capital raises and from enforcement actions to mergers and acquisitions. I think it is fair to say that I have seen both sides of the regulatory equation in banks throughout…
Deal Talk Well, it’s almost Spring and the flowers and deal talk are starting to bloom. We hear and see a lot of activity going on in the Western United States. Our sense is that this activity is being fueled by a confluence of factors: continuing low interest rates and skinny margins; loan concentration concerns and fears of another real estate bubble and uncertainty as to the economic recovery; undue regulatory burden; the pending Presidential…
Back to the Future As I prepare for a presentation at the WIB Annual Directors Conference, it strikes me that it has been seven years since the financial meltdown. While our economy has improved, it still has not completely recovered and the Fed and other banking agencies are fearful of an instant replay. The Fed, reminiscent of Japan, has held interest rates down at historical levels in order to jump start the economy. If and…
Introduction In connection with a presentation I was asked to make by the Federal Home Loan Bank to some of its member banks, I crafted this article on “Coping with the CAMELS.” As you know, this is an acronym for the six ratings in commercial bank exams – Capital, Asset Quality, Management, Earnings, Liquidity and Sensitivity to Interest Rate Risk. Before we address each category, I would like to present some context on today’s regulatory…
It Can Happen to You I woke up this morning to a fraud alert from Citibank on my credit card. After going through the Spanish Inquisition to secure my identity, I finally learned what had triggered the alert—a small transaction in Spain. When I attempted to verify that the Citibank people were legitimate and not the hackers, they got indignant. Upon reflection, I realized that putting down a deposit for a flat in London may…
The Changing Face of America While attending a recent presentation at the California Bank Presidents’ Seminar by Brett King, CEO and founder of Movenbank, the world’s first direct mobile-only bank, I was inspired to write another Cyber-Graham. The crossover between baby boomers, Gen Xers, and millennials is fast approaching with economic power shifting to the next generations. They are your future customer base. What they want, need, and expect will dictate your success or not.…
George Allen Still Lives On The famous football coach George Allen, when he took over the Washington Redskins back in the day, was quoted as saying, “the future is now.” At the risk of dating myself, George followed the philosophy of signing veteran free agents, many of whom had previously played for him with the then Los Angeles Rams, to win now. He surrounded the likes of QB’s Sonny Jorgenson and Billy Kilmer, who were…
Game On? On November 20, 2014, the Federal Deposit Insurance Corporation (FDIC) issued additional guidance* on its 1998 Statement of Policy on Applications for Deposit Insurance, in an effort to clarify the requirements for de novo banks and to encourage more applications. Since the financial crisis, there has been stagnant or declining growth in bank charters, with only one new bank formation since the fourth quarter of 2010. The FDIC requirements for de novo banks…
Old Friends and Places – Fresh Perspective As I return from another journey across the pond to London, I ponder this past year and what lies ahead. After visiting Windsor Castle with my old friend and colleague Jim Firn, recently retired from Russell Investments as their European counsel, I got to thinking about the past and the future. A day visit to Cambridge University sharpened that focus and provided perspective. Two of the good things…