NEW YORK ( TheStreet) -- Come March, U.S. bank investors will be praying that bailed-out lenders Bank of America (BAC - Get Report) and Citigroup (C - Get Report) can win the Federal Reserve's approval to improve on their puny dividends after years of building up capital reserves, selling divisions and posting inconsistent profits.
Struggling investment banks such as Societe Generale (SCGLY), UBS (UBS), Credit Suisse (CS) and Barclays (BCS), meanwhile, are in the process of either reinstating high-yielding payouts or forecasting big dividend increases to shareholders.
Some are even paying out special dividends.French investment bank Natixis, which needed a 35 billion-euro toxic-asset guarantee from conglomerate BPCE in 2009, said this month it would sell a 12 billion-euro stake in BCPE and deliver a 2 billion-euro special dividend. The bank now targets a 50% payout ratio. At a time when eurozone banks are gorging on emergency European Central Bank loans as a way to handle asset sales, writedowns, rising non-performing loans, messy politics in countries such as Italy and France, and an overall economy that's expected to contract in coming years, the dividend payouts of lenders across Europe are a reminder of what put banks into a state of crisis five years ago. Thankfully, in the U.S., a mix of public pitchforks and a central bank with control over the purse strings of large banks is preventing what could be a contagion of reckless management in Europe from spreading to our shores. Consider a comparable hypothetical to Banco Santander's 10%-plus dividend using AIG (AIG). In 2012, the insurer repaid government loans and the Federal Reserve's sold most of the toxic assets it bought from the company at the peak of the crisis. While AIG said in its fourth-quarter earnings that a return to profitability and its repayment of bailout loans isn't cause for a dividend or share repurchase, Santander continues to cling to billion of euros in emergency ECB loans, which help to stabilize its balance sheet, as the bank pays an industry-leading dividend. Societe Generale, which is contemplating what would equate to a 4%-plus dividend yield at current prices, is also just beginning to consider repaying ECB loans starting this year. With all megabanks in the EU holding capital ratios below U.S. peers, according to February Standard & Poor's calculations, as loan-loss provisions rise at the likes of Santander, profits evaporate at Barclays and UBS and balance sheets raise red flags, dividend payouts appear unsustainable by comparison. European banks have the widest credit default swap spreads, according to Bloomberg data, with lenders such as Santander and BBVA perceived as twice the risk of Citigroup or Bank of America. (Those spreads price risk according to market prices.) EU dividends also provide the context that's likely to best serve U.S. bank investors, who are hungry for dividend increases when the Federal Reserve releases its so-called stress test results, formally called a Comprehensive Capital Analysis and Review, or CCAR. While investors in the likes of Wells Fargo (WFC - Get Report), JPMorgan (JPM - Get Report) and Goldman Sachs (GS - Get Report) may be salivating over the prospect of improving on the mid-1% to mid-2% annual payouts of those banks, they're likely years away from meaningful increases or anything that resembles the 4%, 5% and even 10% payouts seen across the Atlantic. Bank of America and Citigroup, meanwhile, aren't likely to make meaningful dividend payouts for years, according to Christopher Mutascio, a banking analyst at Keefe, Bruyette & Woods. "Banks will have their day on capital redeployment, it's just not that time yet," Mutascio said in an interview. He expects the payout ratios of well-capitalized lenders like Wells Fargo and JPMorgan to peak at 30% of profits this year -- a ratio far below the guidance of most European banks. An expected conservative approach to dividend payouts, administered by the Federal Reserve, comes with good reason. It was the Fed, after all, that pumped over $7 trillion in emergency liquidity through banks between 2008 and 2009 to help the U.S. financial system survive the crisis. Meanwhile, allowing big dividends as the Fed continues to hold interest rates near zero and supports asset prices with up to $1 trillion in purchases would reek of hypocrisy, according to Mutascio. Left on their own, banks may simply revert to the poor judgement that led them into the crisis -- and which continues to make the eurozone a prominent risk for the global financial system. On Tuesday, EU authorities imposed a short-selling ban on the shares of Intesa Sanpaolo, as fears reemerged with a split election in Italy that puts the country's credibility with investors in jeopardy. According to Intesa Sanpaolo's most recent quarterly report, the bank paid out about $1 billion in cash dividends last year, as its ratio of total equity to assets fell. The ban should remind U.S. investors of similar restrictions in short-selling Lehman Brothers and Merrill Lynch in 2008. It wasn't short sellers of stock that led to the collapse of both banks; it was bad management of balance sheets and poor judgement when it came to dividend payouts. Consider that in 2010, Boston Fed President Eric Rosengren calculated banks currently undergoing stress tests could have retained $80 billion in capital had they slashed their dividends in 2007. That amount was roughly half of the bailout funds given by the U.S. Treasury to "too-big-to-fail" lenders during the financial crisis. A 2011 study highlights that, aside from increasing the solvency and liquidity of banks, retaining capital by minimizing dividends or share repurchases is the best way to ensure a bank doesn't fall into a state of crisis. It was published by David Greenlaw of Morgan Stanley, Anil Kashyap of the University of Chicago Booth School of Business, Kermit Schoenholtz of New York University Leonard N. Stern School of Business and Hyun Song Shin of Princeton University. The review also sharply criticizes the testing of banks by European regulators and questions the region's reliance on improving capital ratios, instead of overall capital, as a means to recover from the financial crisis. "