When I was reading CNN this morning, I came across a story regarding a strongly worded report from the International Monetary Fund, the Bretton-Woods financial organization that exists to foster international trade and monetary cooperation around the world that, while it noted some positives, noted a lot of negatives in the financial system of the United States.

Most troubling was the fact that the “Big Banks” noted in the 2010 report issued by the IMF have since “gotten bigger,” by absorbing or otherwise acquiring smaller banks. Indeed, it noted two prime examples in JPMorganChase and Wells Fargo, two powerhouse banks which got even larger as it acquired smaller banks during and after the Great Recession that weren’t able to do as well, further increasing their already behemoth sizes. Said the IMF: “Large and interconnected banks dominate the system even more than before.”

Further troubling was the Student Loan market, which has exploded since the Great Recession, tripling in size since 2005 to $1.2 Trillion, per CNNMoney. When one considers students who are drowning in student loan debt may not have a healthy enough debt-to-income ratio to acquire forms of credit, such as unsecured credit, automobiles or even mortgages, the threat to the economy in the future that could be developing becomes quite clear.

Further concern was that of the “shadow banking industry,” per CNNMoney as well, which is the more investment-based banking that includes hedge funds and big-money insurance companies, now account for more than 70% of assets, per the IMF. One major danger to this is that these organizations are not banks, and therefore, are not subject to the same laws and regulation that more “Main Street Banks” or even “Wall Street Banks” are subject to; which open the gates on possible threats to Main Street consumers.

Even moreover, was the detail that even though the Dodd-Frank Act is approaching its fifth anniversary, it’s largely not implemented. Dodd-Frank, often cited as the greatest overhaul in the American financial system since the Great Depression, included many consumer protections, particularly in the mortgage and credit industries.

While not necessarily stated in the IMF report, it does bear mentioning that the Volcker Rule, named for Federal Reserve Chairman Paul Volcker, was not included in the verbiage for Dodd-Frank, which would prohibit the trading of depositor monies with the [Main Street] Bank off of the Bank’s own accounts — like those on Wall Street Banks; one of the catalysts of the 2007 Great Recession, per his own words.

Further risks cited by the IMF were that of Fannie Mae and Freddie Mac, the common names for the Federal National Mortgage Association and the Federal Home Loan Mortgage Corporation, government-sponsored entities in the housing industry. The IMF has noted that because the government still has direct control of these entities, which creates fiscal risk, it noted.

So… have we made progress overall? Or do some of the new minuses subtract against the positives we’ve made, leaving us largely where we were several years ago?

Good question. I honestly don’t know. [weighs hands] Consumers have a lot of new protections compared to a decade ago, thanks largely to the new Consumer Financial Protection Bureau; and even in the mortgage industry’s new “Closing Disclosure,” which streamlines three closing documents into one document that makes things a little easier to understand — eliminating some paperwork, and eliminating three separate pieces of paperwork in favor of one.

Further Reading:

– http://money.cnn.com/2015/07/07/investing/imf-warns-us-financial-risks/index.html

– http://www.imf.org/external/pubs/ft/gfsr/