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 FEDERAL DEPOSIT INSURANCE CORPORATION

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 SYSTEMIC RESOLUTION ADVISORY COMMITTEE

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 MEETING

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 WEDNESDAY,

NOVEMBER 9, 2022

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 The Advisory Committee convened at 9:00 a.m.

EDT in the Federal Deposit Insurance Corporation

Board Room at 550 17th Street NW, Washington, DC,

Martin J. Gruenberg, Acting Chairman, presiding. 

PRESENT: 

SHEILA BAIR, Former Chairman, Federal Deposit

Insurance Corporation*

SHELLEY C. CHAPMAN, Senior Counsel, Willkie Farr

& Gallagher, Former United States Bankruptcy

Judge, Southern District of New York*

TIM P. CLARK, Distinguished Senior Banking

Advisor, Better Markets, Former Deputy Director

of Supervision and Regulation, Federal Reserve

Board of Governors 

JAY CLAYTON, Former Chairman, U.S. Securities and

Exchange Commission (SEC)

H. RODGIN COHEN, Senior Chairman, Sullivan &

Cromwell LLP 

GARY COHN, Former Assistant to the President

Economic Policy and Director of the National

Economic Council 

ROBERT DRAIN, United States Bankruptcy Judge,

Southern District of New York 

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D. WILSON ERVIN, Former Vice Chairman, Credit

Suisse 

RICHARD J. HERRING, Co-Director, The Wharton

Financial Institutions Center and Professor of 

Finance, The Wharton School, University of

Pennsylvania

DONALD KOHN, Former Vice Chairman, Board of 

Governors of the Federal Reserve System and, 

Senior Fellow, Economic Studies Program, 

Brookings Institution 

FRANK LA SALLA, President and Chief Executive 

Officer, DTCC, President and Chief Executive 

Officer of DTC, FICC and NCSS 

TIMOTHY J. MAYOPOULOS, President of Blend, Former 

President and Chief Executive Officer of Fannie 

Mae 

SANDIE O'CONNOR, Former Chief Regulatory Affairs 

Officer, JPMorgan Chase & Co. 

DOUGLAS L. PETERSON, President and Chief 

Executive Officer, S&P Global 

JOHN S. REED, Former Chairman and CEO of 

Citigroup and Former Chairman, Corporation of 

Massachusetts Institute of Technology 

MEG E. TAHYAR, Partner and Co-head of Financial 

Institutions, Davis Polk LLP 

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ALSO PRESENT: 

MARTIN J. GRUENBERG, Director, Federal Deposit

Insurance Corporation, Acting Chairman

ROHIT CHOPRA, Director, Consumer Financial 

Protection Bureau 

MICHAEL J. HSU, Acting Comptroller of the

Currency

ELKE KTMNIG, Chair, Single Resolution Board,

European Union

JON CUNLIFFE, Deputy Governor for Financial

Stability, Bank of England*

SUSAN BAKER, Division of Complex Institution

Supervision and Resolution

JOHN P. CONNEELY, Director, Division of Complex

Institution Supervision and Resolution

ELIZABETH FALLOON, Office of General Counsel

ANDREW FELTON, Deputy Director, Systemic Risk

JAMES (JIM) MCGRAW, Senior Deputy Director,

Division of Complex Institution Supervision and

Resolution 

ARTHUR J. MURTON, Deputy to the Chairman for

Financial Stability

ALFRED SEIVOLD, Deputy Director, Institution

Risk, CISR

R. PENFIELD STARKE, Senior Counsel. Legal

Division 

RYAN TETRICK, Deputy Director, Resolution

Readiness, Division of Complex Institution

Supervision and Resolution

JENNY TRAILLE, Division of Complex Institution

Supervision and Resolution

DAVID WALL, Deputy General Counsel (Acting),

Resolution and Receivership Branch 

*Present via video teleconference 

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 C-O-N-T-E-N-T-S 

Welcome and Introduction 

Acting Chairman Martin J. Gruenberg. . . . . . . . 5 

Session 1: Integration of Supervision 

and Resolution . . . . . . . . . . . . . . . . . .24 

Session 2: Resolution Planning Update. . . . . . .70 

Session 3: CCP Resolution Challenges . . . . . . 129 

Closing Remarks 

Acting Chairman Martin J. Gruenberg. . . . . . . 191 

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P-R-O-C-E-E-D-I-N-G-S

 9:04 a.m.

 ACTING CHAIRMAN GRUENBERG: Well, good 

morning, everybody. Welcome to the FDIC. We 

haven't seen you all for a while. So it's nice 

to be together.

 I actually checked the calendar. The 

last time this committee met virtually was in 

October of 2020. And the last thing this 

committee met in person hard to believe was 

December of 2018. So it's been four years since 

we've actually seen you all.

 And we're going to do our best not to 

let another four years pass without seeing you 

again. And we're going to try to resume annual 

meetings of this committee which really has 

enormous value to us in an area that is of vital 

importance to the FDIC. At the end of the day, 

our ability to manage the orderly failure of a 

systemic financial institution is probably --

will probably be the ultimate credibility test 

for our agency. 

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And how our agency is viewed will be 

determined by how we handle that challenge. And 

our preparations to carry out that responsibility 

are absolutely central to what we do. And our 

ability to meet with you on a regular basis to 

share with you the work we're doing and to get 

your input really has enormous value too.

 So we thank you for being here. And 

so it's a large committee. It may get larger. 

So we're a little bit cramped, but I hope you 

bear with us. We wanted to take advantage. Let 

me begin by introducing some of the new members 

who have joined up, Tim Clark who is the 

distinguished senior banking advisor of Better 

Markets. And some of you may know him as the 

former deputy director of Supervision and 

Regulation at the Federal Reserve.

 Tim was definitely a partner in crime 

with us. It was really our partnership with the 

Tim and the Fed that allowed us to make the Title 

I resolution plans into meaningful tools for us 

to use to enhance the resolvability or largest, 

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most systemic global financial institution. So 

the fact that we were able to entice Tim to join 

this committee was a big plus for us.

 And let me also introduce Frank La 

Salla, the president and CEO of the Depository 

Trust Clearing Corporation, DTCC. One of our top 

priorities at the FDIC and it's an international 

priority as well is making progress on the 

resolution of central clearing counter-parties. 

They in some ways define what systemic risk is.

 And in all the areas in post-crisis 

resolution, I think it's arguable that we've made 

the least progress in regard to CCP resolution. 

So that is a top priority for us here at the FDIC 

and domestically here in the United States. And 

it's a major priority internationally for the 

Financial Stability Board. And we're going to 

have a discussion around that later this morning.

 In addition, we've been joined by 

several other distinguished new members. This 

will be their first meeting, Jay Clayton, the 

former chairman of the Securities and Exchange 

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Commission, Margaret Tahyar, partner and co-head 

of financial institutions at Davis Polk, and 

Wilson Ervin, former vice chairman at Credit 

Suisse who played a formative role in helping 

define thinking around the issue of systemic 

resolution. And if I may introduce a special 

guest who's joining us this morning, Elke K”nig 

who many of you may know she is the chair of the 

Single Resolution Board for Europe.

 Elke is the founding chair of the 

Single Resolution Board. There was no resolution 

authority in Europe before Elke. And there is 

now a viable, robust institution, really the 

first institution of its kind in the European 

community with a capacity for resolving large 

financial institutions.

 Elke is finishing her second term as 

chair next month. And she'll be required to set 

down the limit of her service. And she's 

graciously agreed to join this committee after 

she steps down as chair of the SRB. She'll be an 

invaluable addition to us. 

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And let me recognize if I may four 

former members whose terms expired and have left 

the committee, Bill Donaldson, former chair of 

the SEC, Peter Fisher, former Undersecretary of 

the Treasury and now a senior fellow with the 

Tuck School of Business at Dartmouth, Gary Stern, 

former president and CEO with the Minneapolis 

Fed, and Michael Bodson, president and CEO of 

DTCC. And we now have the benefit of his 

successor serving on the committee. We have a 

full agenda, so I'm not going to take more time.

 But we've really broken the morning 

into three sessions that I think will be of 

interest to you. The first session is going to 

focus on our efforts to integrate our supervision 

and resolution responsibilities. I think one of 

the strengths of the FDIC is we have in one 

institution responsibility for resolution, a 

significant part of supervisory responsibility in 

the U.S. banking system as well as the deposit 

insurance responsibility.

 Tremendous synergies among those three 

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functions and the importance of close 

collaboration and integration between supervision 

and resolution is really fundamental to an 

effective resolution process. We want to talk 

about our work from that perspective. In the 

second session, we're going to focus on our two 

key resolution priorities, our ongoing work for 

systemic resolution under Title II of the DoddFrank Act and our utilization of the orderly 

liquidation authority.

 And we're going to focus in particular 

on our work around increasing transparency and 

how we think about Title II resolution and 

communicating with financial markets as well as 

the public to try to establish better 

understanding of what we do. And that is really 

not a simple task as you all probably understand 

better than most. So we want to talk about that 

issue.

 And then also what is a key priority 

for us which is enhancing our ability to manage 

the failure of large banking organizations below 

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the GSIB level. It's really a very distinct 

resolution challenge for us from the GSIBs in 

many ways as great as the GSIB challenge. And 

because we were so obsessed with developing a 

capability to manage the failure of GSIBs, that 

was not the first thing we turned to was not the 

large banks.

 And then we woke up and realized the 

failure of one of these large banking 

institutions could really be an enormous 

challenge with financial stability implications. 

So we devoted a lot of time. That's a priority I 

think for all three of the U.S. banking agencies, 

the Fed, and the OCC as well as the FDIC.

 And as you may know, the FDIC and the 

Fed issued a joint advanced notice of proposed 

rulemaking to see public comment and the 

possibility of establishing a long-term debt 

requirement for our largest banking organizations 

below the GSIB level to facilitate a capacity for 

orderly failure. So we'll talk about all of that 

work. And then finally, we're going to have a 

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session on the issue I mentioned previously, the 

challenges relating to the resolution of a 

central counter party.

 Central counter parties as you all 

well know were a systemic consequence before the 

2008 crisis. And then as a result of one of the 

key reforms after the crisis of mandating 

clearing for derivatives, it anything, we 

expanded the systemic footprint of CCPs. And 

it's not clear that the resolution capacities 

here in the United States or internationally 

really evolved to deal with the enhanced systemic 

risk that a failure of a CCP could present.

 So we've been spending a lot of time 

on that here at the FDIC. It's a big priority 

and focus of attention internationally within the 

Financial Stability Board and within other 

jurisdictions. So we're going to continue that 

discussion here, and we have a special guest 

joining us virtually who some of you may know, 

Sir Jon Cunliffe who's the Deputy Government of 

the Bank of England for financial stability. 

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And Jon is also chairing the committee 

on payments and market infrastructure of the BIS. 

He's been focused on payment issues 

internationally and in particular the supervision 

and resolution of CCPs. He's really been an 

international leader on this issue, and we 

thought we could benefit from a conversation with 

Jon.

 So that's our program for this 

morning. Thank you all for being here. We have 

the privilege of being joined by our other Board 

members, acting controller Mike Hsu and director 

of our Consumer Financial Protection Board --

Bureau -- it's still early in the morning I got 

to tell you -- Rohit Chopra. Mike, would you 

have any comments?

 DIRECTOR HSU: Just to say it's great 

to be here to see a lot of familiar faces, to 

meet some new folks. These issues are very near 

and dear to my heart. So I just look forward to 

jumping right in. Thank you.

 ACTING CHAIRMAN GRUENBERG: In his 

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previously life, Mike was also a partner in crime 

with Tim Clark over at the Fed.

 DIRECTOR CHOPRA: Partner in 

compliance.

 (Laughter.)

 DIRECTOR CHOPRA: Well, let me just 

thank all of you for being here. And I want to 

echo it's good to be with people in person again. 

The staff has prepared a lot to make sure that 

they can solicit feedback from all of you.

 I'm just going to echo a couple of 

things that the acting chairman discussed that 

are issues of concern for the Board, for me, for 

others. And as Marty mentioned, obviously the 

failure of a domestic systemically important 

financial institution would be quite challenging. 

The FDIC has some good experiences, bad 

experiences, and learning from this. And I think 

it's no surprise that a CFPB director is worried 

about the failure of an institution with an 

enormous footprint in consumer and retail 

banking, a very large number of accounts and the 

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regional impact or national impact of its 

failure.

 And I think as he mentioned, there has 

been a proposal, an ANPR by the FDIC and the Fed 

about ways to prevent that and remove from the 

play book of simply selling it to a GSIB. I'll 

also add a couple of other points of concern for 

me. One is obviously the undesignated non-bank 

systemically important financial institutions.

 The Financial Stability Oversight 

Council has not designated any in quite some 

time. And I think many experts agree they exist. 

And we do not have resolution plans for them. 

That would make resolution very challenging and 

create an enormous amount of complexity.

 And of course, the work that the 

acting chairman has mentioned about the GSIBs, 

there's no victory to be declared. There are 

still a number of complexities that of course 

U.S. law requires us to evaluate those resolution 

plans based on whether they can be credibly 

completed in a Chapter 11 bankruptcy which I 

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think many of us know is a fairytale right now. 

So there's so much work I think we need to do. 

The markets have obviously changed quite a bit 

since the last time you met together. So really 

looking forward to the discussion.

 ACTING CHAIRMAN GRUENBERG: Thank you, 

Rohit. Let me turn the program over to John 

Conneely, the Director of the FDIC's Division of 

Complex Institution Supervision and Resolution. 

John?

 MR. CONNEELY: Thank you, Chairman 

Gruenberg. Good morning and thank you all for 

joining us today. I am John Conneely, the 

Director, as Marty said, of the Division of 

Complex Institution Supervision and Resolution, 

although it's much easier to say CISR. So we'll 

stick with that.

 I'm joined at the table by the 

panelist for our first session, Senior Deputy 

Director Jim McGraw, Deputy Directors Andy Felton 

and Alfred Seivold, and our legal counsel, David 

Wall. Before we get started, I just 

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unfortunately need to take care of a couple of 

administrative matters. First, our legal staff 

has asked I provide two statements for today's 

meeting.

 The first is a statement regarding the 

Sunshine Act. So I'll read that. We have all 

members of the FDIC Board of Directors in 

attendance today as we begin the advisory 

committee meeting.

 The government in the Sunshine Act 

imposes notice and access requirements whenever a 

quorum of the FDIC's Board of Directors meets to 

conduct or determine agency business. This 

meeting is not held for such purposes and does 

not constitute a meeting under the Act. The 

Board members present will only engage in general 

or preliminary discussions that do not relate to 

specific proposals for action pending before the 

FDIC.

 Any specific issues for official Board 

resolution remain open for full consideration by 

the Board following the conclusion of the 

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meeting. The second statement -- excuse me --

regards the advanced notice of proposed 

rulemaking, or ANPR which was mentioned, 

concerning potential new resolution related 

resource requirements for large banking 

organizations which was approved by the FDIC 

Board of Directors on October 18th, 2022 and also 

approved by the Board of Governors of the Federal 

Reserve System and is currently open for comment. 

Staff will not respond substantively to any 

comments on the ANPR and generally will be in 

listening mode and not indicate the direction the 

agencies are likely to take with respect to NPR 

or Final Rule.

 In addition per our regular practice, 

the FDIC will publish a summary of this meeting 

relating to the ANPR on our public website. The 

summary will generally include a list of 

participants and a high level summary of the 

discussion. And if you have questions on either 

of those statements, we have our FDIC legal staff 

who would be happy to answer. 

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(Laughter.)

 MR. CONNEELY: Just a couple of 

technical notes, if you'd like to speak, just 

press the green lights on your microphone. Or 

for those who will be participating remotely, you 

can use the Webex raise hand function. But 

there's really no need to be so formal.

 And in the meeting, please jump into 

the discussion at any time. I'm sure people are 

not shy here. So I'd also like to remind 

participants that the meeting is public and is 

being livestreamed.

 So I appreciate the opportunity to 

provide a few introductory comments today. And 

today we'd like to provide the committee with an 

update on work being done with respect to 

systemic resolution along with some of the 

challenges that we continue to face. And we look 

forward to the committee's input to help further 

our work in these matters.

 And so let me just take a minute to 

set the stage for today, particularly for new 

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members. As you know following the 2008 

financial crisis, Congress established new 

authorities for the FDIC to manage the orderly 

resolution of large complex financial 

institutions whose failure could threaten U.S. 

financial stability, most notably Titles I and II 

of the Dodd-Frank Act. Shortly thereafter in 

June 2011, then FDIC chairman Sheila Bair 

convened the first meeting of this committee, 

noting that the knowledge and expertise brought 

to bear by members of the committee would greatly 

enhance the corporation's efforts to develop and 

implement these tools.

 In the seven meetings held since then, 

a wide range of systemic resolution issues have 

been brought to the committee in order to test 

thinking and solicit your feedback. The first 

meetings obviously focused on core aspects of the 

systemic resolution, including the establishment 

of the orderly liquidation authority and the 

development of the foundational single point of 

entry strategy. Subsequent meetings discussed 

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various structural reforms to operationalize the 

SPOE strategy such as long-term debt --

requirements for long-term debt, clean holding 

companies, orderly transfer of QFCs.

 And more recently, the committee has 

discussed their work on cross border engagement, 

bankruptcy challenges, Title I reviews, 

capabilities testing which we'll hear a little 

bit about today, broker-dealers, and other 

developments. And thanks to the input from you 

all on these issues. The FDIC has really made 

significant strides in systemic resolution 

planning.

 Yet challenges remain which brings us 

to the agenda for today. And I know Chairman 

Gruenberg went through some of the agenda. I 

just want to elaborate on a couple of points, and 

I'll just walk through. And on Slide 4, we have 

the agenda.

 The first session really will be just 

a brief update by risk staff on recent work in 

CISR to integrate supervisory and resolution 

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responsibilities. I'm sure many of you remember 

during the financial crisis the coordination 

challenges that we faced between the agencies, 

between supervision and resolution. And a lot of 

work has been done since then to bridge these 

gaps.

 And we look forward to your thoughts 

on the directions we're taking here in CISR in 

that regard. So as Jim and Andy and Alfred go 

through their presentations, we'd like you to 

think about your experiences and the challenges 

you've faced and share them and maybe identify 

ways that we could do this better. The second 

session which is really the heart of the meeting 

today, our resolution staff will discuss two 

topics, GSIB resolution planning under Title II 

and the need for public transparency and the 

challenges and options for resolving non-GSIB 

large banks.

 Here as the chairman mentioned, we'll 

introduce and discuss the topic of transparency. 

The FDIC has a long record of fostering public 

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confidence. Everybody knows if you walk into the 

bank and see that FDIC sign, your deposits are 

safe.

 And we really want to build on that 

level of confidence around the execution of our 

Title II authorities. In essence, what we're 

looking for from you is who needs to know what 

and when about our efforts to help build our 

credibility and confidence. The second topic, 

the resolution of large banks that are not GSIBs 

is new for consideration by the committee.

 In this session, we'll seek your input 

about the work we're doing and the challenges 

this work presents which are formidable, whether 

it's for the FDIC or the financial system. And 

then the third session as mentioned, we returned 

to a topic that we briefly discussed with the 

committee in 2020 which is the challenge of 

resolution of CCPs. This topic is one that is on 

a lot of policy makers' minds globally and a lot 

of work is being done and warrants continued 

consideration by the committee. 

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And we look forward to hearing from 

our guest speaker, Sir Jon Cunliffe, and from you 

all on how we should go about being prepared and 

prioritize these challenges that we have. Are 

there any questions on the agenda before I move 

on? No? Okay.

 So then as a kickoff to our first 

session, let me just -- which is on the 

integration of supervision resolution, let me 

just take a couple minutes to reintroduce CISR 

which is the division primarily responsible for 

executing the FDIC's supervision and resolution 

responsibilities for the largest and most complex 

financial institutions. You'll see on slide 3 

the mission of CISR. And it's pretty 

straightforward: to protect and maintain 

stability in the U.S. financial system by 

avoiding and if necessary managing the failure of 

a large complex financial institution.

 So this mission statement clearly sets 

out a focus on the use of both supervisory and 

resolution authorities to address financial 

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stability. And the focus and approach really has 

been driven by the evolution of the banking 

industry. The growth over the past 35 years and 

the actual and relative size and the result and 

complexity of the nations' largest banks along 

with the broadened systemic resolution powers 

that have been provided under Dodd-Frank really 

has caused the FDIC over time to adopt new and 

more sophisticated approaches to its supervision, 

resolution, and insurance functions.

 The changes were naturally 

incremental. And over time, the FDIC had 

specialized staff working on very similar issues 

throughout the organization. There were a lot of 

challenges in coordination. Supervisors don't 

like to talk a lot about failure. And resolution 

specialists like to talk about nothing but 

failure.

 (Laughter.)

 MR. CONNEELY: So we had a bridge that 

we needed to cross and bring together. So an 

important part of this evolution was the creation 

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in 2019 of CISR really to consolidate all those 

resources and adopt a more integrated approach 

that leverages both our supervisory and 

resolution responsibilities. As the need to plan 

for the resolution of these institutions starts 

long before the stresses begin.

 We have to start well into BAU. So we 

work, CISR works proactively early on to fully 

understand the firm's unique characteristics and 

activities, the degree of complexity, their 

resiliency, very important on the resiliency, the 

level of risk, and the their potential impact on 

financial stability. And to accomplish this, we 

build cross disciplinary teams that integrate 

professionals throughout the division: 

resolution, supervision, lawyers, economists, 

pretty much anything you can think of.

 And we work also closely with our 

other divisions and our sister agencies. And 

we've done a lot of work -- a lot of good work 

with the OCC and the Fed on this typic. We also 

engage in active cross border coordination 

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through our work of our supervisory colleges and 

crisis management groups which really are now 

part of our BAU activities to build and maintain 

our readiness.

 And we had both, the supervisory 

colleges and the crisis management groups, which 

are looking at the same institutions from two 

different perspectives. And we look at them with 

staff from both sides. So in taking this 

approach, we're hoping to achieve several 

overarching objectives.

 One is to improve our coordination, 

our consistency, and our accountability. 

Secondly is to foster a collaborative and 

interdisciplinary approach to these issues. And 

third and really most importantly, we want to 

insure the information, resources, and expertise 

are shared in advance and readily available in 

the event of a crisis situation. So with that, I 

will turn -- well, I'll just stop for a moment if 

anybody has any questions before I move on.

 (No audible response.) 

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MR. CONNEELY: Okay, great. So then 

I will turn it over to Jim McGraw. He will 

expand on our efforts to better integrate 

supervision and resolution. Thank you.

 MR. MCGRAW: Thanks, John. So good 

morning and welcome to the advisory committee 

members and the guests here in the room and those 

who are joining us online. My name is Jim 

McGraw. I'm the senior deputy director of the 

FDIC's Division of Complex Institution 

Supervision Resolution or as I will refer to it 

going forward, as John said, CISR.

 So this morning, I'm going to briefly 

discuss the unique organizational structure 

within CISR where we have brought together within 

one division the supervision or risk expertise 

and the resolution expertise. The communication, 

the collaboration, the cooperation, sharing of 

information, sharing of expertise between 

supervision and resolution within CISR really is 

one of the fundamental benefits of having both 

disciplines in one division. So within CISR, we 

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have three business line branches.

 We have institution risk, systemic 

risk, and resolution readiness. We also have a 

fourth branch, the operations branch which 

supports the other three business line branches. 

Institution risk provides our firm specific 

onsite supervisory work focusing in on key risk 

vulnerabilities, resiliency, the adequacy of risk 

management practices within the firm.

 Systemic risk is focused on systemic 

and emerging risks within our portfolio firms and 

looking at it more horizontally across the firms 

and then also look at those risks within the 

financial industry itself. Also systemic risk is 

responsible for supporting our supervisory 

programs, for developing and monitoring policy, 

developing our quantitative analytical tools. 

There's a lot of information that comes in, a lot 

of data from these firms and there's a lot of 

analytical tools that we build out to help us in 

both our risk and our resolution work.

 And they also oversee our 

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international coordination which I'll talk about 

in a little more detail in a few minutes. And 

then we've got the resolution readiness branch 

which formulates in the event of a failure would 

be responsible for leading the execution of a 

strategy to resolve a large complex financial 

institution, either under the FDI Act or Title II 

of the Dodd-Frank Act. The flow of information 

and analysis between these branches is critical.

 Knowing where the key risks and 

vulnerabilities and risk management weaknesses 

exist within specific business lines, material 

entities, critical services, critical operations. 

Where those are located within the firm, 

understanding the interconnectedness within the 

firm, ultimately understanding where a firm 

stands on the crisis continuum from a risk 

perspective is critical in determining where 

resolution readiness resources need to be 

focused. And also knowing the information needs 

on the resolution readiness side helps inform our 

supervision side when they're prioritizing and 

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developing their supervisory plans.

 But the risk and readiness branches, 

we have regular structured discussions. We have 

ad hoc discussions. We have information sharing 

programs.

 We have an interdivisional committee 

made up of executive managers from all three 

branches that meets to oversee and ensure that we 

have appropriate supervisory and resolution 

strategies in place that complement each other. 

Within CISR, we have an escalation protocol 

process which is a collaborative process between 

risk and readiness where firms are evaluated and 

placed into priority focus buckets based on risk 

profile perceived probability of default. And 

then that is able to serve as a guide as we 

develop steps that can be taken to better prepare 

for a potential resolution of that.

 I mentioned the international 

coordination within the systemic risk branch. 

The crisis management groups John mentioned, 

CMGs, are a significant part of that 

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coordination. They exist to facilitate cross 

border cooperation among both supervisory and 

resolution authorities, representing home and 

host jurisdictions for the systemically important 

financial institutions.

 We have firm specific information 

sharing and cooperation arrangements that support 

this cross boarder crisis planning activity. And 

then the members maintain regular dialogue. We 

have formal generally on an annual basis meetings 

where we build and maintain relationships between 

the different authorities, exchanging information 

relevant to resolution planning to ensure that we 

have a rapid resolution response in a time of 

stress.

 I'll also mention that the CMGs have 

really enhanced our internal CISR coordination 

between all the branches as over the last couple 

of years all of the disciplines, risk and 

supervision, have worked together in planning and 

preparing for these CMG meetings. And bringing 

the onsite supervisory perspective into these 

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meetings has really enhanced their effectiveness 

from a resolution planning standpoint. Cyber 

risk, I'm just going to mention this quick.

 It's just an example of a risk where 

the coordination and communication between 

supervision and resolution is key. Understanding 

where cyber risk vulnerabilities are within the 

firm, within the business lines, material 

entities how it could impact different critical 

services, critical operations is key when 

assessing and planning for resolution risk. 

Slide 7. I'll mention for Title I Planning.

 Again, the presence of our onsite 

supervisory staff monitoring the condition and 

the risk management of large complex financial 

institutions, the knowledge gained through 

examination participation and in our offsite 

analysis, it's a valuable resource that we have 

to leverage as part of the Title I plan review 

process. Onsite supervisory staff have access to 

specific information that can supplement the 

information that the firms provide in their Title 

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I plans and should be incorporated into our 

overall plan assessment. Information learned 

through supervisory programs can be critical in 

understanding a firm's Title I capabilities 

which, in turn, informs from a Title II 

perspective as well.

 Supervisory programs should be used to 

help us to test assumptions and capabilities and 

assertions that firms put within their Title I 

plans. I'll point out the drafters of original 

165(d) rule actually recognize the value of 

incorporating supervisory programs into Title I 

plan review where it states in the rule that the 

Board and the corporation will rely to the 

fullest extent possible on examinations conducted 

by or on behalf of the appropriate federal 

banking agency for the relevant company. Related 

to recovery plans, CISR staff from both 

resolution readiness and risk have been working 

closely with the other banking agencies to plan 

for and participate in in-depth reviews of 

recovery plans submitted by firms subject to the 

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OCC's recovery plan rule.

 And again, this work has considerable 

overlap with Title I and Title II. Finally, I do 

want to note and this has already been mentioned 

by Chairman Gruenberg and by John. But my 

comments up to this point have focused on banks 

and bank holding companies where we have the 

supervisory insight and the Title I work that 

we're able to use that to support a robust 

resolution preparation for those institutions.

 However, we also have responsibility 

for resolving nonbank financial companies if 

their failure threatens U.S. financial stability. 

And the work associated with the nonbank 

financial companies is more difficult given we 

don't have nearly the same resolution tools or 

resolution engagement and insight with those 

firms. A common challenge that we discussed with 

you back in 2020 was the fact that the FDIC 

didn't have access to certain data that would be 

needed in the runup to or during a resolution 

event for one of these companies. 

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Another more specific challenge which 

Jenny Traille will talk about later this morning 

is the fact that the nonbank financial companies 

are not required to submit Title I resolution 

plans. And as we've mentioned, Title I plans 

provide the FDIC with direct access to key 

information that would be useful in supporting a 

Title II resolution. So to address those 

impediments to nonbank financial company 

resolution planning, we do work closely with the 

other regulatory agencies, both domestically and 

internationally, to help sharpen our 

understanding what the FDIC might need to 

undertake a successful resolution of one of these 

firms.

 We've also put in place data sharing 

arrangements for the FDIC to receive material 

nonpublic information from the firm supervisors. 

But I will say even with the best efforts, it's 

still difficult to address the root challenges 

that we face in thinking about a Title II 

resolution of a nonbank financial company. And 

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again, we devoted a whole segment on the agenda 

to CCPs later this morning where I'm sure we'll 

have a very robust discussion on that topic. So 

with that, I'll stop and just open it up if 

anyone has any questions or comments. Yes, John.

 MEMBER REED: Jim, impressive how 

you're coordinating all of this yourselves. What 

about the interaction with the institutions 

themselves? Obviously, supervision can be pretty 

formal. Do you have informal sort of 

interactions with the targeted companies 

themselves that would allow you to flesh some of 

your work and their sort of response to it? 

Because to some extent, you're part of their 

immune system.

 MR. MCGRAW: I mean, on the 

supervisory side, we have daily --

MEMBER REED: Sure.

 MR. MCGRAW: -- contact with our 

onsite presence. Through the CMGs, we have 

access and discuss the resolution topics with the 

firms during those meetings. And then during the 

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recovery plan review work, we'll have discussions 

with the firms there. On Title I, we have 

discussions with the firms. So we are able to 

build into a lot of our interaction with the 

firms, the resolution issues and concerns that we 

might have.

 MEMBER REED: So there isn't a barrier 

that's making your job harder?

 MR. MCGRAW: I would say that the 

whole purpose behind the formation of CISR was to 

break down that barrier. And I think we've done 

a good job getting that in place. There's still 

more work to be done. But the integration of the 

supervision and resolution is much stronger now 

than prior to the formation of CISR.

 MEMBER ERVIN: A question that goes 

back to something that John mentioned. I used to 

run a credit department in a former life. And 

one of the tensions was how to deal with the 

credit officers who thought the credit was good 

and would sometimes fall in love with it as it's 

going down to a difficult path. 

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And how do you discover that dance of 

when to turn to recovery? You don't want to move 

too early. But you also don't want to be too 

late. So as you've integrated these two teams, 

how do you deal with that issue to make sure that 

people don't fall in love and think of this as a 

black mark if I turn it over to resolution, I 

failed as a supervisor?

 MR. MCGRAW: I think that's a really 

good question. And I would say and others can 

chime in too. I would say the formation of CISR, 

we've tried to -- that's been one of the purposes 

of that is to bring them together where we're not 

thinking this as, okay, this all belongs to 

supervision.

 And now -- oh, now we got to turn it 

over to resolution. We're all one team working 

on this together. And the development when I 

mentioned the escalation protocols, that's work 

that's done collaboratively between supervision 

and resolution where we're looking at firms and 

we're discussing the risk profile of the firm. 

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How well is the risk being managed? 

What is a perceived probability of default on 

that firm? And we have a lot of really honest, 

frank discussions in those committee meetings as 

far as where should firms be placed within these 

priority risk buckets.

 And so I would say our conversations 

on a daily are integrating both supervision and 

resolution. And we've hopefully done a good job 

getting rid of -- it belongs to the supervisory 

side until everything has already hit the fan and 

now we're heading it over to resolution.

 MR. CONNEELY: Yeah, I'll just add 

that really is an excellent question. And there 

is a lot of tension. And there's even tension on 

the supervisory side. You always want to make 

sure examiners are objective and independent.

 And that's a struggle sometimes if 

they're at the institution a lot. But I think 

one of the things that I see, for example, that 

is really heartening is we have supervisory staff 

onsite that will be monitoring the institution 

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and see something that they're doing. And now 

it'll trigger thoughts as to that might have 

implications in resolution.

 I should talk to my ready staff 

(phonetic). And so we're addressing those issues 

up front rather than getting to the end and then 

I didn't realize this. So I think it's a really 

great question. There is a lot of tension. But 

I think having the discussions really works.

 MR. MCGRAW: Yeah, we had -- actually, 

John and I sat through a briefing two weeks ago 

where one of the supervisory staff was on an 

examination. And there was some issues that were 

discovered that really created a lot of 

questions. This could really make a resolution 

really difficult.

 And so we sat and we talked about 

that. So somebody who's an examiner by trade but 

was thinking about the implications that these 

issues were uncovered during an exam would have 

on a resolution situation. Yeah, Richard?

 MEMBER HERRING: I was intrigued by 

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the cultural difference you noted that inspired 

the formation of this integrated group. And I 

think it does make a lot of sense. But I also 

noticed that internationally we really still have 

this strong separation between the supervisory 

colleges and the crisis management groups.

 I'm wondering how much of an overlap 

in membership there actually is and whether other 

countries actually have the ability to join the 

two approaches as you do because you have both a 

supervisory responsibility and a resolution 

responsibility. My guess is Elke doesn't have 

such easy access to supervision, but I don't 

know. But it does seem logical that those two 

entities -- and there are all sorts of privacy 

concerns and disclosure of information that would 

have to be dealt with. But I'm curious about how 

broadly you think the model can be applied.

 MR. CONNEELY: Well, I think the FDIC 

really is in a unique position in this regard. 

We have statutory supervisory in a backup role, 

authorities on the supervisory. And plus we 

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insure, so we have responsibilities and 

authorities on the insurance and deposits.

 We're also a resolution authority. So 

I don't think there's too many entities that have 

that combination of authorities. And it puts us 

in a unique position which I think we're trying 

to leverage.

 MS. KTMNIG: I think you spotted the 

right problem, and that's the problem to make 

sure that supervisor who holds onto his child 

doesn't hold on to the child far too long. And 

in Europe, we are trying to solve it in our 

institutional framework a bit similar to what you 

do. We are participating in discussion of the 

supervisor which for the banks in our realm, it 

is Frankfurt under the ECB.

 And at the same time, we have them 

participating in our discussion. But I think 

it's a topic that you always need to keep just on 

your mind because it's a bit -- it's my problem 

and the White Knight is just around the corner to 

avoid that kind of debate. Now you're in a 

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better position because you also have supervisory 

powers.

 We have formally the chance to do 

onsite inspection of the deep dives. But we 

would always be a bit in a situation are we 

doubling up to what the supervisor does because 

we are not the supervisor. But in principle, 

it's the same idea that you have between putting 

this into one group to say we need a very 

constant dialogue also with a supervisor. And 

over the eight years, we have developed out of 

the discussion on why do you need to know. We 

have now full access to their information on the 

supervisory side.

 MEMBER PETERSON: You mentioned that 

you have supervisors on site, but that's only a 

few people. Have you changed your expectations 

of the role of internal audit as well as the 

audit committee of the boards?

 MR. MCGRAW: I would say, no, we 

haven't changed our expectation. I think the 

expectation is still the same. But we do have a 

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small number of onsite given that we're backup 

supervisory. The OCC and the Federal Reserve 

numbers exponentially are higher than ours. And 

so we do work closely with them.

 And we do look at audit and where 

audit is considered to be reliable is strong. 

We'll look at that as far as thinking about have 

issues been remediated at the firm. If audit is 

credible, then that'll go a long way with us to 

see what their findings are as they look at 

different issues that the firm has addressed.

 MR. CONNEELY: I would just add -- I'm 

sorry. I would just add that it's not a shift or 

difference. But there is an extension now. 

Audits now focus on resolution issues, and we 

leverage off of that.

 And so that's a good development in 

the firms and the banks is that they're auditing 

resolution issues. They're auditing their 

calculations and their capabilities so we can 

leverage off of that. And so it's an extension, 

but it is relatively new. 

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I too was thinking about the tension 

between the supervisors and the resolvers here, 

the potential tension. Now a lot of resolutions 

are triggered by liquidity runs, right? So then 

the supervisor has no choice, right?

 But the key would be trying to get in 

before the run and the fire sale. That would be 

really a stabilizing intervention. So could you 

talk -- and the data coming in on what the actual 

capital of the institution is, is very lagged and 

incompletely and asset prices are changing very 

rapidly. Could you talk a little bit about what 

would trigger the resolution before the liquidity 

run?

 MR. MCGRAW: Yeah, I would say again 

for us it's having those conversations. We bring 

resolution as a part of the process throughout. 

So if we're starting to even notice that a firm 

is starting to experience some stress well before 

you get to an actual liquidity event, we've got 

our resolution people on board.

 Again, through that escalation 

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protocol process, we'll meet. And okay, there's 

more risk here. We're seeing some stress. We're 

going to move this firm down.

 And then that triggers resolution 

readiness starts doing more to start preparing. 

So there's not a, well, there's an event now. 

We've got to prepare. All the preparation is 

going to be done up front prior to that event 

actually taking place.

 MR. CONNEELY: One thing I will add to 

that is that one of the authorities we don't have 

is we don't charter institutions. So it would be 

the Fed or the OCC or the states. And they're 

the ones who would make the decision as to 

whether or not to pull the keys. But having 

people there, we're doing the monitoring so we're 

real time.

 MR. FELTON: If I could jump in. It 

might also be worth mentioning that one of the --

the real benefits of the Title I review work over 

the last decade really has been improved internal 

governance mechanisms, quantitative triggers, the 

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improvement. And this is also from the 

supervisory side, internal modeling, capital 

stress testing, liquidity stress testing so that 

even if the regulatory capital numbers don't come 

to us for four weeks that the firms are expected 

to have as close to a real time view of that as 

possible and that they have internal governance 

mechanisms to start engaging in actions as 

necessary.

 MEMBER KOHN: And they share that view 

with you.

 MR. FELTON: Yes.

 MEMBER TAHYAR: In the GSIB SPOEs, 

right, there's our language is liquidity 

execution need which is calculated daily. It's 

shared with the supervisors. It's never been 

tested, so we can't say it's perfect or that it 

would work in real life.

 But it's massively better and 

different from what we had in 2008. So I think 

that if a GSIB were to go into resolution, itself 

it would be pushed into the bankruptcy far before 

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the chartering authority pulls the plug. And our 

line is what is going to tell you to do that.

 MEMBER O'CONNOR: Just one other 

question to ask. To what extent or how are you 

working or integrating the evolution of markets, 

particularly the Treasury markets into your 

analysis given that the liquidation of collateral 

is so foundational to both recovery and 

resolution for banks, nonbanks, CCP in every 

structure out there?

 MR. CONNEELY: I'll start. We 

recognize that and we have started looking at 

that. And I don't know if you have anything you 

want to add to that.

 But it is an area that we don't 

naturally -- as supervisors, we don't naturally 

have insights. We're not the Federal Reserve 

here. But it is an area where we've seen time 

and again issues occur and issues that affect our 

institution. So we are looking now at building 

up our capabilities in those areas.

 MEMBER O'CONNOR: So just as part of 

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the advisory board, I would continue to encourage 

you to look at that interoperability, right? 

Because we've got shifting credential rules that 

had implications on markets, on Treasury 

particularly. And we have that reliance. And 

this is a circle. So I think those are very 

important things, and I'm glad you're looking at 

them.

 MR. MCGRAW: Yeah, Andy and I have had 

several discussions over the last several weeks 

about building that out more within the systemic 

risk range. Hi, Tim.

 MEMBER CLARK: Hi, just a quick 

question. I think the coordination is a great 

idea. I'm glad to hear it. I hope the 

interagency coordination was still functioning as 

well as it was when I was at the Federal Reserve.

 Focusing on the supervision side, the 

goal here is really for these firms to be 

prepared for resolution and frankly prepared for 

recovery action so they never get to resolution. 

Plans are great. The finding of credibility of a 

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plan is a challenging issue.

 Credibility frankly of a plan for one 

of these firms to be resolved in bankruptcy, it 

would be a huge challenge. So on the supervisory 

side, you have an opportunity to really push in 

areas that can help to make the firms better 

prepared and more thoughtful internally 

hopefully. But I wonder. I guess my -- there's 

a question coming here eventually.

 (Laughter.)

 MEMBER CLARK: There's been a lot of 

discussion about whether the agencies are 

creating rules through guidance. This has been 

very prominently raised by the bank policy 

institute. And it's interest because, of course, 

guidance has been somewhat undermined a little 

bit by statements by the agencies over the past 

few years.

 I'm wondering if you think that the 

way that everything is set up right now is the 

most effective way for you to achieve getting 

these firms to be better prepared or if you think 

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that possibly strengthening some of this guidance 

into a more rules-based approach would eliminate 

some confusion and take away some of the 

criticism that the agencies have faced for making 

up rules without actually having a rule which 

frankly I think is unfair. But it's a long 

question. Was that clear enough? I can repeat, 

but it was long.

 MR. CONNEELY: No, I think it's clear 

enough. We're the practitioners. We implement 

and try to implement the guidance, the rules, 

what have you. I leave it really to policymakers 

and others to determine whether those should be 

rules -- guidance should be rules or what have 

you. But yeah, it's a good question.

 MR. MCGRAW: We do have a lot of 

authority in Title I, for instance. And I think 

there are ways to -- again, thinking about the 

supervisory side and how that impacts Title I 

capabilities, et cetera. There's a lot of 

authority there that can be used and to push 

firms to get issues fixed that have direct 

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implications on resolution readiness.

 MEMBER CLARK: Part of my question 

was, has any of that ability to influence through 

that manner been undermined by the talk of 

guidance shouldn't be taken too strongly. I'm 

just trying to get a sense of how the dynamic has 

changed given all the discussion about making 

rules through guidance again I think has been 

unfairly aimed at you.

 MR. MCGRAW: I would --

MEMBER O'CONNOR: I'd like to hop in 

here. I think broadly speaking when guidance is 

given, forget about what the guidance is. 

Clearly, financial institutions need to take that 

extremely seriously because of the ultimate 

assessment of whether or not your plan is 

credible. And then I think there were 

discussions broadly around what would the 

implications of certain types of guidance be. So 

I think the reality is there can be guidance and, 

two, yes, it's taken extremely seriously.

 ACTING CHAIRMAN GRUENBERG: And if I 

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could just add when we implemented Title I and 

Dodd-Frank, we started with rulemaking. That's 

detailed and really lays out the framework for 

implementing the Title I authorities for 

resolution plans. And we elaborated on the rule 

as you well know through guidance documents to 

provide greater detail to the institutions for 

implementing their requirements established under 

the rule. So I think it's been actually a pretty 

functional process.

 DIRECTOR HSU: Questions for the 

committee. I think part of what the structure of 

CISR helps to do is address these twin problems. 

One is that without that integration, I think 

resolution risks becoming a paper exercise the 

way it's kind of set up.

 And part of that is the second problem 

which it's very infrequent, right? So I mean, 

knock on wood. That's the intent. But part of 

that means that memories are short and people 

forget.

 I think on a lot of these resolution 

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issues coming out of the '08 crisis, everyone was 

moving in the same direction because it was so 

present. It was omnipresent as an issue, both on 

the regulatory side and on the bank side. And as 

we get further and further from that, we've got 

folks having lived those things, part of the 

challenge is not having it just live as an ivory 

tower exercise over here and then you've got kind 

of day-to-day supervision risk management over 

here.

 And I think part of that integration 

is key. I'd be curious to hear from others. 

Like, what else needs to be done to keep that 

front and center? Because I think this gets back 

to an earlier question about boards and audit 

committees.

 That's kind of the daily muscle with 

an organization. And I think it's very easy to 

just say, well, that was a long time ago. We've 

figured this out. It's all good. We can move on 

from here.

 I think that's going to be a perineal 

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challenge, especially as we move forward and 

there's new risks that come up. And I think you 

guys were talking about that. I don't know if 

folks have thoughts on that.

 MEMBER ERVIN: Yeah, I'd share that 

view. It's one of the problems you have a 

peacetime Army that doesn't get to fight. And 

unfortunately when combat comes, you need lots of 

troops. You need to get them on board yesterday.

 And that strikes me as one of the 

fundamental problems that you have in an agency 

like this. How do you keep some of those 

memories alive? I teach some classes to kids who 

think 2008 was a million years ago, right?

 And there's a generation of people who 

lived it, and that generation is slowly moving 

on. So I do wonder if there are training 

exercises, ways you can kind of throw in. There 

have been some war games.

 I remember actually Jay Powell ran one 

of those things a long time ago which was quite 

useful. They had a former FDIC chairman 

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pretending to be an FDIC chairman on the panel. 

But throwing in curve balls and throwing in 

multiple actions into the market and trying to at 

least get people to think about that as more of a 

real time exercise.

 I think different types of training 

might be one way that you could preserve that a 

little longer. It's a tough problem. But I do 

think your point is very well taken because these 

things probably don't come in ones and twos when 

they come. You look at some of the FDIC history, 

there's some pretty big waves. So I do wonder if 

there are ways you can use some of those tools to 

help with that.

 MEMBER O'CONNOR: I would encourage 

also the cycle. Keeping the cycle reasonably 

short, two years, three years for the 

institutions because systems and approach can 

atrophy otherwise. So I think that's important.

 The second important point back to 

what Wilson was just saying is also on the crisis 

management groups, really doing play book 

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exercises because again within five to ten years, 

everybody turns over. So many of us in this room 

who lived through all of it will not be sitting 

around those tables. So I think that's equally 

important because those two things need to come 

together.

 ACTING CHAIRMAN GRUENBERG: If I can 

just add, and it's an important question on the 

standing Army issue. How do we mobilize in the 

event of a stress environment? And we perhaps 

should've had the table -- in addition to these 

folks who spend their time on the supervision of 

the largest institution and resolution planning 

for the largest institution, we have an 

additional division dedicated to resolving banks 

on the smaller end of the spectrum but with very 

significant operational capabilities and frankly 

large human resources to draw up which also 

collaborate closely with these complex 

institution groups.

 So we actually can bring a lot of 

resources to the table in the event of a stress 

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scenario. And a large part of the planning of 

those groups are if we had to mobilize additional 

resources. You actually have standing contracts 

with third parties if we need to as well as 

capabilities to call back retired annuitants. I 

mean, there are in place a whole set of plans 

that we --

PARTICIPANT: Reservists.

 ACTING CHAIRMAN GRUENBERG: Yeah, to 

draw upon. And particularly even now, for 

example, where we may be facing -- we are facing 

a change in the economic environment and 

uncertain outlook of what the next 6, 12, 18, 24 

months may present. And that triggers a lot of 

thinking on both the supervisory and on the 

resolution in terms of additional human resource 

needs and how we might address them as events 

unfold.

 MS. KTMNIG: Perhaps to add and not to 

get so militant like Army. But we are 

firefighters.

 (Laughter.) 

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MS. KTMNIG: We hope there's no fire. 

But we need to be trained for all kind of fire 

and not just to believe it's the old chimney that 

will burn and this is where you know the answer. 

But what I find incredibly important I think the 

way you're setting it up, it addresses this is 

the cooperation then also between the various 

institutions.

 Now I come with a European mindset. 

We have 21 national authorities. So you never 

know which country will be the one you have to 

deal with. But I find it incredibly important 

for any cross border institution that we also 

train together, have deep dives, have a kind of 

tabletop so that we all speak the same language 

and that we all know what we want to do and how 

would we work together, be it a European 

institution with a U.S. arm to it or be it a U.S. 

institution with in our case simply be across 

European institution. So testing and fire drills 

are probably the only way I would think of to do 

so. 

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MEMBER COHN: You're probably going to 

say the same thing. So look, we're all creatures 

of our past. So when we go through all this 

resolution, even though we may be forgetting '08, 

it still heavily influences everything that we 

do, that we think.

 I think one of the things that we 

should be really careful about is the next crisis 

won't be '08. I don't know a lot. I just know 

that. I know that for sure. I know that for 

sure.

 So if I was thinking -- if I was 

sitting in your chair, I would think what is the 

seismic or systemic crisis that's not '08? What 

happens if we get a major cyber event? What 

happens if we get a major cloud event?

 We could just go through these. And 

how do we deal with those events. And '08, 

whether we like it or not, there was a sign, 

there was a windup, there was a pitch, there was 

a swing, there was a ball flying out. There were 

a lot of balls that went out of the stadium. We 

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sat there and watched them.

 The next event, there might not be a 

sign, a windup, a pitch, and a ball. It just 

might happen. And so in many of these things, I 

think we've got to accelerate our thinking 

because we live in a highly accelerated world. 

We also live in binary outcome events. And the 

event mostly likely will affect multiple 

institutions simultaneously.

 MEMBER CLAYTON: Yeah, look, I agree 

with what Gary said. And a question related to 

that, I think March 2020, it was sort of all 

hands on deck for a little bit with a little bit 

of -- but not the same as '08. I'm curious. 

When was the last time it was sort of all hands 

on deck for a resolution even as an exercise? 

And I think that's -- if it's been a long time, 

it's a good reason to give it a try.

 MR. CONNEELY: Well, I think 2020 was 

all hands on deck. I think the market events 

that we've had was all hands on deck. The 

geopolitical events we've had all hands on deck. 

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Some of the instances that we're going 

to share with you today any one of these -- to 

your point before, any one of these could cause a 

crisis amongst our banks. We need to be ready 

all the time, and we really don't know when it's 

going to come. And it could come very fast.

 So we do maintain a heightened state 

of readiness. We do exercises both internally 

and with other agencies and globally. We have 

protocols and committees set up to constantly 

work through some of these things.

 We can't predict it, and we try to 

build our resolution tools so that they're 

functional and they'll work in any sort of 

environment. But we really don't know what's 

going to happen. But we try to maintain a 

heightened state of readiness.

 MEMBER CLAYTON: And just to follow up 

on what Gary was saying, unfortunate experiences, 

every time we go through one of those, you're 

like there's something I wished that I had. And 

it would be interesting to get updates on what 

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those things you identify that we didn't have 

this going in but we could use it the next time.

 MEMBER O'CONNOR: Yeah, just to 

amplify those comments as well, I think you have 

two things here to add. Big picture, how do we 

horizon scan in a more effective way? And how do 

we contemplate an economy that is substantially 

more open, right?

 You don't have the banking industry 

writ large as a choke point for the bulk of 

financial services delivery anymore. You've got 

open technology architecture. You've got open 

nonbanks. You mentioned that a little bit. So 

as you think about continuing to shore up this 

section which is super important, it's sort of 

like a balloon.

 And the answer may or may not be 

regulate more, expand powers. But how do you 

think about -- how can we think about under the 

powers that you all have in collaboration with 

the other agencies to identify and address these 

types of risks as they emerge? Because in the 

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end, people are going to care about was the 

economy impacted by financial instability 

regardless of where it came from.

 MEMBER COHEN: John, you had mentioned 

right in your introductory remarks that the last 

time we met, we did not have -- you did not have 

the data which you needed for nonbank financial 

institutions. This is what the chairman 

generally mentioned about nonbank financial 

institutions. In the beginning, I gather you 

don't -- you still don't have -- I got to believe 

that this creates a problem not only for the -- I 

mean, you have no ability with the nonbanks. I 

would think it adversely affects your ability to 

really supervise and plan for the regulated 

sector. So if all of that is still correct and 

to go to what Jay said, we've got a gaping hole 

and the nonbank sector grows.

 Now I want to take a radical 

approach, suggestion, and go back to something 

the director mentioned again in his opening 

remarks and that is FSOC. There are huge 

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problems with designated and regulating nonbank 

institutions under FSOC. Why could not FSOC 

designate just for the purpose of providing data, 

requiring data to come to you to give you a 

better overview of what's going on?

 ACTING CHAIRMAN GRUENBERG: I think 

these guys are going to find that question over 

their head.

 (Laughter.)

 ACTING CHAIRMAN GRUENBERG: But I 

think you raise an important question, Rodgin. 

And I think this is a subject obviously I think 

all three of us are concerned with as members of 

the FSOC. I think it's been a focus of attention 

if I may say for the Secretary as well. And it's 

a subject we're hoping to address.

 DIRECTOR CHOPRA: So of course, the 

tools to get firm specific data to the extent 

there is a -- I don't think this will be that 

helpful but some state regulators that have some 

insight. But there's also the Office of 

Financial Research which has certain authorities 

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to compel and collect data that has been used in 

a fairly limited fashion.

 But it's also important to underscore 

the legal mechanics of using -- of invoking Title 

II. For a nonbank, it requires, I believe, super 

majorities of the Fed Board, the FDIC Board, and 

sometimes maybe even the SEC has to be involved, 

consent of the Treasury Secretary, maybe even 

consultation with the President and with no real 

insight as to what is happening other than market 

signals. And to be able to go in again without a 

supervisory relationship, without a plan. And 

yeah, tough.

 But I don't know what we've -- what 

Jim, John, and others, if you want to share the 

thinking you have put into that scenario of how 

to navigate something like that. Obviously, it's 

like what Gary said. You don't even know. What 

are you even going into?

 MR. CONNEELY: Yeah, it's a difficult 

question. I mean, we do try -- it's difficult. 

Honestly, it's so vast, both the authorities. 

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They're very broad authorities, and we don't know 

where the boundary is fully drawn yet.

 I mean, there is some parameters that 

companies would have to meet. But we're in a 

dynamic environment. And then as far as what the 

decisions are going to be made at the time, 

there's going to be several parties involved and 

they're always going to have their own 

perspective.

 And we'll have to deal with those 

facts and circumstances at that time. It's hard 

to plan for that. We do hold conversations, 

though, with all the key turners to make sure 

everybody understands their roles and talk about 

issues. But it's difficult.

 DIRECTOR HSU: I want to maybe try to 

tie together Gary, Jay, and Sandie's comment 

because I do believe that this challenge of how 

to prep for the next and not fight last year's 

war, right? It's kind of a perpetual challenge. 

The exercises that we're talking about earlier 

are really valuable. They're extremely time 

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intensive.

 And you have to pick wisely. And I 

think this is one of the challenges is, like, 

where do you drill? And if you pick that spot, 

then if you miss, then you expended a huge amount 

of resources.

 So I think that does argue for 

something a bit more modular, smaller, faster, 

more nimble. What exactly that is, I think we 

really need to put some thought into how to do 

that because I think that is a newer -- because I 

think the environment requires it. Because 

change is happening much more quickly and things 

are not contained within the four walls of the 

bank anymore.

 And so that does require kind of a bit 

more creative thinking on that front. It would 

be interesting to know what other industries do, 

kind of what's best practice out there. That's 

something that, I think, kind of the collective 

knowledge of folks at this table and your friends 

have probably some insight into. So that may be 

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something to kind of think about and pursue in 

the future. Thanks.

 ACTING CHAIRMAN GRUENBERG: May I just 

observe, this is really a pretty engaged group 

here. And I'm looking at the clock and our 

agenda this morning. And I'll maybe perhaps move 

to our second agenda item.

 And I think all of these issues 

continue into the next. So it's not as if we're 

leaving them behind. But I actually think these 

next topics will engender further conversation 

around these issues. John, if that's reasonable.

 MR. CONNEELY: No, I think you're 

absolutely right. We're actually naturally 

leading into the next panel. Thank you. And our 

next panel which is going to be the resolution 

planning update as we noted, Title II and public 

transparency and large bank resolution planning. 

And we'll have Deputy Director for Resolution 

Readiness Ryan Tetrick, advisors Betsy Falloon 

and Susan Baker, and our legal counsel Pen 

Starke. 

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MS. FALLOON: Thank you and good 

morning. I'm Betsy Falloon. I'm a senior 

advisory in the resolution readiness branch. And 

I'm here to introduce our Title II topic for 

today.

 And chairman and John have mention 

that what we're interested in here is to talk 

about transparency and ways that we can tell the 

story of the way we are planning and the way we 

intend to approach a Title II resolution in a way 

that enhances everybody's understanding of it and 

improves confidence in the process and the 

outcome. At this point, there's a pretty broad 

awareness of the single point of entry strategy. 

I think that people are aware of that approach to 

resolution which is the one that we think is the 

most effective.

 And a lot of steps have been taken to 

make that approach more actionable, more 

available in a wider range of scenarios, both in 

Title II planning area but in Title I as well. 

The firms have taken steps and the agencies as 

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well to improve the firm's structures or 

capabilities. And the single point of entry 

strategy is now a credible option in a much wider 

range of scenarios.

 The planning work in Title I has 

certainly had a lot of benefits and our Title II 

readiness as well. And sort of the talk about 

the firehouse or the standing Army, that routine 

of the resolution planning also helps us because 

there's always new information and new plans. 

And we are building upon our planning as the 

firms build upon their planning.

 So over the course of my career, I 

have seen where resolution planning has become a 

truly full time year round job which is way 

different than in the early years where we came 

in and out in good time to do deals and a bad 

time to do resolution. But we recognize that 

this is hard. And comments have been made about 

how it's hard to know exactly what to be ready 

for.

 And we certainly know that being ready 

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for the last crisis is not the answer. Although 

certainly also we need to have learned from the 

last crisis and remember those lessons and keep 

that muscle memory but at the same time not be 

trapped by the expectations of the past. As I 

mentioned, we use the Title I plans as a 

foundation for our resolution analysis in Title 

II.

 And in Title I reviews, we are now 

using capabilities testing more so that as part 

of our Title I review. So to validate the 

capabilities that the firms have described in 

their plans and the capabilities that we rely on 

in Title II for our readiness. Arlen (phonetic) 

was mentioned, and that's certainly a capability 

that we think about a lot in Title II readiness 

as well as in understanding the risks associated 

with the Title I plans.

 We have a systemic resolution 

framework that we have built out which is sort of 

our road map for how we think about Title II 

execution. And we've been working -- at this 

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point, we're building in details. We're building 

in templates.

 We're trying to make this framework an 

actionable set of steps. And an important part 

of that is internal tabletops and exercises. We 

try to do a lot of that, both the high 

investment, high yield ones where if we get it 

right, it's really good. And we've had a few of 

those.

 And also, we try to look for 

opportunities where we have low cost exercises. 

We call them Pop Exes, but just a quick, not a 

lot of buildup, how would you do it if this 

happened. Take this firm. Take this scenario. 

Send some staff and go.

 And those are ways that we can -- I 

don't want to say build muscle memory because 

it's not quite true. But create the teams, 

create the expectation. Keep the knowledge 

fresh, and also identify where we have gaps and 

where we need to do additional work.

 Certainly coordination among all the 

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financial regulatory agencies is critical to our 

readiness. And I think John mentioned the 

ongoing work that we do with key turning 

authorities which is really important. And we 

also coordinate on a staff level with staff at 

Treasury to make sure that the liquidation fund 

which is funded ex post and is a different 

approach than what we use with the deposit 

insurance fund that we have a staff level 

understanding of what it takes to make sure that 

we're ready to move that money timely and that 

everybody knows what their job is to accomplish 

that.

 And of course, there's been a lot of 

talk about our cross border engagement. And in 

CMGs and outside of CMGs, we have a lot of 

engagement with supervisory and resolution 

authorities around the world to make sure that we 

have as much as possible shared understanding of 

the steps that we might take, the steps that they 

might take. And that we talk about the work that 

we've done to keep those issues fresh and to keep 

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those relationships fresh.

 And all of this really supports 

readiness and keeps us busy while we're in the 

firehouse. Next slide, please. So the topic 

here is transparency. And we are very mindful 

that confidence is critical to the success of a 

resolution in any case and in every case but 

particularly in this case where we would be 

exercising authorities for the first time.

 And the key to confidence always is 

setting expectations. Do stakeholders understand 

the process? And is it being executed consistent 

with those expectations?

 So we have taken steps to build 

awareness and understanding and are sort of 

looking for ways to continue to do so. So for 

instance, we've been very transparent about our 

Title I resolution planning work. The guidance 

is published. Q&As are published.

 Public portions of the plans are made 

available to the public on the agency's websites. 

Our feedback letters are open to the public and 

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are also posted on websites. So it's an open 

process.

 And I think that there's a lot of 

information available there. Certainly I've 

mentioned that we work with other regulators and 

regulatory authorities to have a shared 

understanding with those stakeholders. And in 

2013, we published a notice in the Federal 

Register about the Single Point of Entry approach 

to resolution and to make that strategy that we 

had developed available so the public and other 

stakeholders would understand and be aware of 

that approach to resolution.

 We continue to talk about Title II 

resolution. There's been speeches about it. We 

talk about it in a lot of different venues, some 

of them are in small group venues and some like 

this one are open to the public and are a way for 

us to tell our story. But what we want to do and 

what we want to ask you about is what do we need 

to do to better set expectations to power our 

communications and improve confidence when the 

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time comes. And with that, I'll turn it over to 

my colleague, Susan Baker.

 MS. BAKER: Hi. As Betsy conveyed, 

we've done a lot about transparency in terms of 

resolution planning. It's all out there on the 

website. What we want to think about and what 

we're starting to work on now is how to improve 

transparency about our execution plans for Title 

II resolution.

 We've been working on these for ten 

years now. And we should probably be starting to 

say more things publicly. So what we want to 

think about today is what should we be 

transparent about now that would help improve 

confidence in the event that we're called to use 

our Title II authority?

 So we've been thinking about this 

across many dimensions. First, we look at who we 

need to be transparent for. And we have a large 

number, a list on this slide that you can see.

 We've done a lot of work with 

policymakers and regulators around the world as 

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has been said and a lot of engagement with 

certain parts of the firm. So the sides on the 

right, we've probably done more on. But what do 

we need to be thinking about for the stakeholders 

on the general public, customers, counterparties, other people like that?

 We think about what message do these 

stakeholders need to hear. And it might not all 

be the same. And then we think about when we 

need to be transparent.

 And I know that there's going to be a 

temptation for us to say -- for people to say 

FDIC should just lay it all out there. Say what 

you're going to do every step along the way. And 

that pre-commitment will help improve confidence.

 But we also need to be mindful of the 

need for FDIC to have operational flexibility to 

adjust to the specific facts and circumstances on 

the ground. Next slide, please. So the is slide 

is some topics that we're considering, the what 

of what we need to be more transparent about. 

And so what we would like to hear from you is 

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which of these topics or others that might not be 

on here, thinking about contracting authority 

which I took off the slide and now maybe I 

shouldn't have.

 (Laughter.)

 MS. BAKER: What are the things that 

would be helpful to get out in the public domain 

to improve confidence now? So some of the things 

we've heard about obviously are what are the key 

decisions that the FDIC has to make, when would 

you decide the framework? Is Title I bankruptcy 

going to work or do we need to turn keys for 

Title II which basically hinges on the need for 

liquidity through the OLF I think?

 How do we decide the resolution 

strategy? Does the firm have enough capital to 

make an SPOE work? Or do we need to be thinking 

about an NPOE?

 Do we need to be more transparent 

about how we coordinate cross border? How it 

would differ if we're a home or a host, for 

example? We get questions about planning for the 

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bridge as well.

 Who's going to run this bridge? What 

assets and liabilities will go into it? And how 

will the FDIC oversee what's happening at the 

bridge and maintain that for public confidence 

perspective as well?

 We're thinking about creditors. How 

do you communicate with claimants, including 

about their claims determination? How will the 

losses be allocated on the Dodd-Frank hierarchy 

which is different than under FDI Act and under 

bankruptcy?

 And then how with the claimants be 

compensated? How does securities for claims 

process work? We mentioned that in the 2013 

thing that Betsy mentioned earlier.

 We're also wondering if we need to be 

more transparent about some of the accountability 

mechanisms that we have as well for the general 

public audience. We are required to remove 

culpable management. How would we go about doing 

that? 

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Do we need to reemphasize that in the 

Dodd-Frank hierarchy, that compensation claims 

are subordinated to general creditors and that 

prior compensation could even be clawed back if 

needed. And then finally, there's the funding 

mechanism. What part of that would be most 

helpful to provide confidence.

 I do think that the OLF in using it as 

the big gift -- it's not a gift, but the big tool 

that we need in Title II to help provide 

confidence. But what do people need to know to 

really get that? How important is it to explain 

the rules and the mechanics for the OLF, how 

money will get from point A to point B.

 How would we use targeted guarantees 

to allay concerns about excess cash use? There's 

a lot of questions here. And so there are a lot 

of things we've been thinking about.

 And what we want to hear from you 

today is what you think the priorities would be 

in order to go about setting expectations 

appropriately in public about how we would 

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execute Title II so that if an when we do have to 

have that announcement on Friday -- ideally, 

Friday night that people are in a position to 

receive it, understand it, and say, yeah, that 

works. And we can see how this will happen. Of 

course, there will be doubters. But there's a 

lot of things going on. So with that.

 MEMBER HERRING: First of all, I'd 

like to praise the FDIC for its unrelenting 

pressure to have more disclosure under the actual 

public reports. I think they have been very 

helpful. Second, I guess I am a bit pessimistic 

about your ability to communicate with the people 

who really need to know in terms of a crisis. 

And this is partly from my experience of teaching 

this stuff.

 (Laughter.)

 MEMBER HERRING: There was a lot of 

interest just after the crisis. It's dwindled 

over time. And so people are sort of less and 

less interested in getting into the nitty gritty 

and some of the really interesting developments. 

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So I would think your strategy ought 

to be to disclose as much as possible to people 

who professionally need to know about it. And 

that would certainly including the ratings 

agencies, the people within the banks who are 

responsible for these judgments. And simply 

publicly available, a place where people can go 

if they need to know more because we're dealing 

with a society where people are getting their 

information in tweets.

 There's just no patience, I think, for 

going through the elaborate and careful planning 

that has gone on. It should be there. It should 

be accessible when people need to know. But I 

don't think you have much hope of reaching a 

public that doesn't have a professional need to 

know.

 MEMBER COHN: I completely agree with 

that. I almost think you'd scare the public if 

you put this out. Like, why are they telling me 

this? Should I be concerned about my bank?

 Like, my insurance company doesn't 

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tell me what they're doing with my assets if they 

just assume they're going to pay my claim, right? 

I think you've got to think of the unintended 

consequences of taking a public that has more 

full faith and confidence in the banking system 

than maybe people in this room do that we want 

them to have full faith and confidence in the 

banking system. They know the FDIC insurance is 

there. They know it works.

 They put their money in. They're 

going to get their money out. So there's a 

select crowd of people that are in the 

institutional side. And if they won't understand 

this, they're going to find a way to understand 

this.

 There's a bunch of law firms 

represented in this room. There's a bunch of 

people that'll change them by the hour a lot of 

money to explain this all to them. And I don't 

have a problem with that, and they all have huge 

staffs. But I would be careful about the 

unintended consequences starting to blast too 

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much of this out in the general public.

 MEMBER TAHYAR: So I'd like to take a 

slightly different view that may be a middle 

ground in the center. First of all, I think 

Susan and Betsy, what you've done and the 

thoughtfulness here is extraordinary. And I want 

to give you respect for it.

 I do think there's more that could be 

put out in the public, perhaps not just on Title 

II but also in Title I in a way that isn't scary 

to folks. I mean, Gary, there's a timing 

question, right? We're at a delicate moment now.

 So if it goes out tomorrow, it might 

have a different impact than if Susan and Betsy 

do their work and it goes out as we're moving out 

of the recession. But I'm very big on 

transparency. I think transparency leads to 

accountability.

 The FDIC has to have flexibility. So 

there are some ways that you could get out some 

basics which say, we could do this, we could do 

that. We will be holding these folks 

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accountable. We have these powers. We have 

these authorities.

 Without putting too much out there, I 

get that we live in a tweet world. But you know 

that 1994 book that the FDIC did on this, I mean, 

that's a bible, right? And so folks who want to 

know about it want to know about it.

 One final thing is I think there's an 

additional group of stakeholders that exist today 

that need to know more about resolution planning 

that didn't exist when we started on this journey 

and that is the kind of fintech nonbank lenders, 

money transmitters, digital assets, crypto 

exchanges, whatever we want to call them. I know 

you've listed domestic authorities. And I think 

there are states that are starting to think, 

should we have a resolution plan?

 And there's so much learning here that 

could be of benefit to those who are thinking 

about different kinds of resolution plans. And 

they would be very difficult if you could put a 

little bit out more in public. So I'd go for 

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more, maybe not the whole hog.

 MS. KTMNIG: Perhaps to build on those 

comments, I can share we were -- when I go to 

Parliament, the first question is, when will you 

become more transparent? The second question is, 

when are you giving us more information? And 

then when we published in summer, or first 

assessment of resolvability, I could count on 

Germany's paper at least commenting that we 

published something.

 Then our gossip magazine, political 

had a short article and that's it. When I went 

to Parliament the next time, they said, when will 

you be more transparent? When I refer to the is, 

I knew no one had read it.

 (Laughter.)

 MS. KTMNIG: But I think the simple 

argument is -- and I would I full heartedly build 

on your comment -- you need to probably have on 

your website and I know you have already a lot on 

this. How does Title II work? What can you 

expect from the institutions to do in case of, a 

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bit stylized.

 And this can go out on a normal sunny 

day. You need to be mindful that it doesn't go 

out and everyone is quite sad. Why are they 

doing it now? But I think a number of the other 

topics are probably topics for what we would call 

it guidance paper where you give more detail to 

those that have either an academic or an 

institutional desire to know.

 But they are not really top of 

priority for the public. Now the one difference 

between us I have always envied for that is that 

you have the summaries of Title I plans. We are 

not talking about any individual banks, so you 

will find from us a comment on GSIBs. On 

average, everything is fine. You will find a 

comment on midsize and the like. But you will 

never find any detailed bank specific comment, a 

topic that all Parliament is talking about.

 MEMBER O'CONNOR: So just to sort of 

again looping these three together. From my 

perspective I think when you're going to make --

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I believe in transparency. But it has to have a 

meaning.

 So if the people that are getting the 

transparency need to be able to do something with 

it. So for example, when we have a terrorist 

alert and we give it a color but we don't know 

where it is, how we respond, that's transparent 

but not particularly productive except that we 

should worry. So I think here we've got to do 

this sort of same sort of thinking.

 How and what should be used by the 

general public. And that's sort of minimal and 

sort of basic framework. And two, what 

transparency can you provide that will lend 

stability in a negative outcome?

 And that's more about not publishing 

claimant communication. That's going to be more 

about you're going to come out and say we've got 

this. We've got a strategy for this. We are 

confident we can work through it.

 So that's sort of I think the way that 

you should be thinking about the communication. 

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And with regard to accountability, yes, that's at 

some point. That's sort of a stage two.

 I think you definitely need to do it. 

But that's not your first order communication. 

You're first order communication is we've changed 

managements, right? So those would be sort of 

the framework that I would offer up to think 

about which I think you sort of have here.

 MEMBER ERVIN: I'd like to go back to 

some of Dick's earlier comments. I do think it 

is hard to get a lot of demand for transparency 

right now in the is sort of period of peacetime. 

But that is going to flip, and it's going to flip 

probably even faster than we saw in 2008 where 

the need for communications really quickly in the 

social media world to avoid disinformation and 

have some holding patterns for things like I 

remember in the early days of bailing people 

saying they're coming for my deposits, right?

 So just holding communications that 

you can pull out that are helpful to deal with 

disinformation, some very simple things, and how 

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quickly you'll be able to deal with different 

constituencies. For example, liabilities are 

further up and closer to harm's way. When are 

you going to be able to give them some comfort, 

if any?

 How do you deal with foreign 

operations? How do you communicate to some of 

those different groups? I think ex ante 

preparation for the speed of scaling up and the 

ability to get information out to avoid rumors 

taking over the narrative strikes me as probably 

the place that feels like it's got the most 

benefit in a world where I think you've done a 

pretty good job of getting out the basics of 

Title II and some of the basic resources that are 

available now.

 MEMBER LA SALLA: Can I just make a 

general comment which will be totally unhelpful 

and unproductive because I don't know the answer 

to it. But it never stopped me from saying 

anything like that before, so I'll do it again. 

Transparence is only helpful and effective if 

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it's accurate.

 And that sounds obvious. But in my 

experience with resolution issues, and in this 

world in interoperability between institutions, 

it seems to me more times than not the regulators 

are sort of the quarterback in this. And they're 

getting bilateral information. But the normal 

network of institutions that really should be 

talking to each other to help aren't doing it.

 And so information becomes 

disinformation because everybody is waiting for 

each other to clarify. So my point is to have 

accurate transparency, it needs to be underpinned 

by a foundation of a solid normal network within 

the industry among the institutions who are 

involved in this. And that's not easy. But I 

think it's something that we need to really think 

about and work on because if we don't it's just 

going to spin.

 MEMBER CLAYTON: Can I follow up on 

that? I think -- look, I think this is an 

incredibly important point. And any statement 

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that's made whether it's made by a regulatory or 

an institution is going to be tested by the 

market.

 And we have to understand that. And 

I think that just putting the two points 

together, what you want to have out there today 

is something that when you make a statement in a 

time of stress, it provides that underpinning for 

the statement. And I think that's the way to 

think about the body of work that you have out 

there, and it's kind of a dynamic relationship 

for when you have to make a stabilizing 

statement.

 MEMBER KOHN: I wondered whether there 

are some market tests of whether you're being 

heard. And I think about TLAC. So TLAC should 

spread, should respond to good and bad news about 

the institutions. And it's really important. I 

mean, it's a little bit conflicted, right? I 

mean, it's important that people understand they 

can be bailed in.

 But you don't want a huge run on the 

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institution. But they're going to be, and it 

could be an early warning signal to the FDIC and 

the primary regulators when these things happen. 

And there may be some other prices -- this is 

similar to what Jay was saying -- in the market 

that you can tell whether people understand who's 

going to be protected, who isn't going to be 

protected. It would be, I think, an interesting 

study to look at the evolution of market prices 

in the situation like March of 2020, for example, 

and see whether people understood what might 

happen.

 DIRECTOR HSU: I might go further than 

that, Don, because I think that you look at the 

evolution. I think we have to sit down and talk 

to long-term debt investors and make sure that 

they as a stakeholder group fully understand bank 

debt today is not what it was before. It is not 

principle protected by design. And I think that 

expectation, I like how you started off.

 It's all about expectation setting. 

And I think that is absolutely critical. If that 

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doesn't hold, this whole thing doesn't hold. So 

I think it's one area to focus on.

 I do want to go back to something Jay 

said about stabilizing statements. In my 

experience, they're not stabilizing. If you have 

to make a stabilizing statement, you're in real 

trouble. And I think that part of that means 

there's a lot of pre-work that needs to be done 

such that those statements aren't seen as a 

reach.

 Because if they're seen as a reach, 

the market sniffs that out in two seconds and 

actually has the opposite impact. And this is 

one of the big challenges. Like, what can be 

done ahead of time so that it's all going as 

planned, hands off the wheel, this is part of 

what we've been prepared for? Because that's 

what builds confidence.

 MEMBER CLAYTON: You just said very 

well what I was trying to say.

 (Laughter.)

 MEMBER PETERSON: So I think the most 

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stabilizing comments have not been coming from 

the FDIC. They've been coming after the CCAR 

tests. And so there's been a consistent approach 

now for over ten years of pronouncements coming 

out about the banks, about how much capital 

they're able to return, how much stock they can 

buy back, what kind of dividends they can pay.

 And that consistency, the market 

understands that. Even the common public will 

understand that. They know how to read those 

headlines.

 I think what we've talked about here 

with the FDIC's role of having this available for 

institutions, have it available somewhere. The 

professional markets understand it. But I think 

right now the more stabilizing factor is that 

we've had ten-plus years of reports on stress 

testing, on capital levels, on dividend levels, 

et cetera.

 And maybe we should think more about 

is there a way to make that more transparent or 

eliminate some of the jargon, et cetera. But 

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what you're doing I think is excellent work. But 

maybe it should be more for professional 

investors and available to anybody.

 MEMBER ERVIN: Just a quick comment 

back to Mike and Mike's comments about TLAC 

spreads and Don's as well. I still kick myself 

for not buying some during the COVID crisis. 

They went --

(Laughter.)

 MEMBER ERVIN: I feel stupid about 

that. There have been some events in Europe over 

the last decade. And TLAC and CoCo spreads have 

spiked out and come back in on idiosyncratic 

stuff. So I think the market has generally been 

behaving as we would hope it to behave. Some of 

the academic studies I've seen, I know Darryl 

Duffy (phonetic) and a few people did a big study 

on some of the too big to fail premium. And it 

seems to be working okay.

 Again, we haven't really run the thing 

through a proper test. I hope we don't have to 

in the near future. But at least all the ex ante 

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signals about credit market spreads and whether 

it's systemic or idiosyncratic seem to be sending 

decent signals from what I can tell.

 MEMBER HERRING: Following up on that 

very quickly. In the very early days of the 

committee, we used to measure sort of how well we 

were doing with whether the kind of debt we were 

looking at, at the bank or at the holding 

company, differed. And it was really a couple of 

years before the markets got the message that 

there really is a different credit risk here, 

that there are different priorities in play. So 

I very much would support Wilson's view, and 

that's a healthy thing. Somebody understands the 

rules which is good.

 MR. CONNEELY: Well, this is a 

fantastic discussion, and thank you for all your 

input. And I think it confirms a lot of what 

we're thinking and it gave us a lot of new things 

to think about. We're running well behind on the 

agenda here which is not a bad thing. But I'd 

like to turn it over to Ryan Tetrick to talk 

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about the resolution of non-GSIB large banks.

 MR. TETRICK: Thanks, John. And part 

of the lesson of resolution planning needs to be 

prepare to execute on a compressed timeframe. 

See how this goes.

 (Laughter.)

 MR. TETRICK: So if we can turn to --

so we're on slide 14. So I should just start by 

acknowledging that this is the first time that 

we're discussing a large bank resolution in the 

SRAC and explain why we think it's the right time 

to do so. The policy response to the great 

financial crisis understandably focused on the 

largest and most systemic institutions.

 At the same time, we at the FDIC have 

taken a number of meaningful steps to improve 

large bank resolvability and have long been 

attentive to the significant challenges that are 

posed by what are sometimes referred to as 

regional banks or DSIBs. But I'll simply call 

them large banks for this discussion. While 

compared to GSIBs, the failure of a large bank 

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might be relatively less threatening to financial 

stability.

 It still may be highly costly and 

result in significant disruption to local 

communities and potentially to the wider 

financial system, especially if it occurs in the 

context of a wider economic downturn. Our goal 

for this presentation is really simply just to 

introduce some of the challenges that we see with 

resolving these institutions and discuss some of 

the strategic options that might be available to 

us. During the global financial crisis, the FDIC 

handled the failure of the largest IDIs with 

creative and dynamic responses.

 But the options that were available to 

us where limited and undesirable, a costly 

conservatorship in the case of IndyMac and the 

sale of Washington Mutual to a GSIB which was 

really only possible because it had a large 

preexisting stock of long-term debt to absorb 

losses and because it had already been marketing 

itself in the route to its failure. And so 

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JPMorgan had conducted significant due diligence 

by the time the institution failed. So it's fair 

to say that the challenges and tricky issues here 

are underexplored publicly and not fully 

resolved.

 I promise we won't resolve them in 

this discussion. We'll just get started here. 

So really on slide 14, just a quick flyover of 

the FDI authority under which these institutions 

would be resolved.

 The FDIA is the only regime available 

for resolving insured depository institutions. 

And importantly the depositor class is senior to 

unsecured creditors. And the uninsured 

depositors would share losses pari-passu with the 

deposit insurance fund which covers insured 

depositors. Every resolution must pass the 

least-cost test which means that the FDIC must 

execute the resolution that is least costly or a 

resolution that is least costly to the deposit 

insurance fund.

 So that really comes into play only 

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when there are losses into the depositor class 

and therefore costs to the DIF in paying insured 

depositors. We have bridge authority which would 

work a lot like the type of bridge authority that 

we've talked about in Title II except that 

furniture depository institution, it's a new 

deposit taking entity charted by the OCC rather 

than a company formed by the FDIC. And it's well 

understood that the deposit insurance fund is 

available to fund the cost of the resolution in 

terms of the administrative expenses during the 

course of the resolution, the payment of 

insurance.

 But really importantly for the 

resolution of large banks which will almost 

certainly fail due to liquidity. The DIF is a 

source of temporary liquidity as well. It's 

large, pre-funded, but also backstopped by 

significant borrowing authority ultimately by 

U.S. Treasury.

 And the scale of the liquidity that we 

have in the DIF is actually in some ways greater 

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than relative to the institutions that would be 

resolved or the liquidation that we're entitled 

to. So there's significant liquidity that we can 

use to facilitate one of these resolutions. So 

moving to slide 15.

 Just quickly which institutions do we 

have in mind here? So generally in this 

discussion, we're talking about IDIs with over 

100 billion dollars in assets that are not 

subsidiaries of U.S. GSIBs. But from a 

resolution strategy perspective, there's nothing 

magic that happens at that 100 billion dollar 

line.

 There's nothing magic that happens at 

the 250 billion dollar line. The issues are 

really similar. They just become more pronounced 

as the institutions get larger.

 Also, I think we find that large banks 

tend to be generalized as having a very simple 

structure. A holding company with 95 percent of 

all assets and activity in the IDI subsidiary 

conducting traditional banking activity. And 

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part of the objective of this slide is just to 

break down that mental model just a little bit.

 That holds for many institutions. But 

there's a little bit more complexity here than 

might first be apparent. Some of these 

institutions, they obviously have more 

diversified businesses than smaller banks.

 And some of them even have Title I 

designated critical operations. In the first 

couple rows here, you're focusing on the impact 

of size on strategy. And again, there's not much 

difference between over 250 and under 250.

 It's really a matter of degree. And 

looking at how salable are these institutions and 

a resolution, very limited possible acquirers for 

any of the institutions in these categories. And 

I really want to touch on the model line 

institutions if you think about it from a 

resolution strategy perspective.

 If they're failing, they have some 

specialized business that they're involved in. 

And it's almost certain that's part of what's 

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impaired. And that makes preserving franchise 

value through the course of the resolution 

significantly more difficult.

 And then it's just something that we 

tend to see with the institutions in that 

category. They have more operations outside the 

bank chain making operational continuity more of 

a challenge for us in resolution. And then IDI 

subsidiaries of FBOs similarly operational 

continuity challenges.

 They have relationships with foreign 

affiliates, with the parent in terms of shared 

services, shared data, shared personnel, those 

sorts of things. All right. So slide 16, these 

are some of the unique challenges that we see 

from a resolution perspective when considering 

large banks. And I would be interested to hear 

from the committee if these are the right 

considerations or if there's others that we 

should be focused on.

 I'll quickly step through them. Here 

we're distinguishing large bank resolution both 

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from GSIB resolution under Title II but also from 

the resolution of ordinary community banks. And 

in a way, they combine a lot of the toughest 

challenges of each plus the burden of high 

expectations.

 I think everybody is going to remember 

the challenges of failing SIFIs from the global 

financial crisis. But for large banks, the 

expectations are probably closer to the failure 

of an ordinary bank that the FDIC tends to handle 

routinely and swiftly. So starting the 

challenges box, the first few here generally 

speaking relate to strategic options and the 

latter given to operational challenges just in 

carrying out the resolution.

 But obviously it's touched on already. 

Just from the standpoint of capacity, the capital 

and operational resources that would be needed, 

there are very few institutions that could 

acquire a large bank. And it'll be especially 

difficult at the time of failure on a compressed 

timeline. 

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There's no minimum loss absorbency 

requirement for these institutions. Some of them 

do have long-term debt that could absorb losses, 

but there's no requirement. And that means that 

there could be increased costs and it could limit 

the strategic options available to the FDIC 

particularly if the depositor class is impaired.

 Franchise value be destroyed and it 

might make it harder for bridge and sale 

strategies to past the least cost test. They 

don't have a debt structure that supports a 

single point of entry type of resolution. That's 

sometimes contemplated for these institutions.

 But without that structure there, that 

means entry at the IDI which for these 

institutions is a very complex operating company 

for using a bridge. That means that over the 

weekend, it'll involve the transfer of thousands 

of employees and a wide array of services, 

assets, and contracts to that bridge institution 

over the weekend. I've noted the challenges with 

operational continuity in addition to some 

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services being outside the bank itself.

 They also just haven't fully addressed 

the impediments to maintaining operational 

continuity and resolution that some of the larger 

firms have and to the same degree. So next 

handful of challenges here, I know there are a 

lot of challenges which was just part of the 

message. Getting to the receivership entity 

itself, so there's a large number of deposit 

accounts that we would need to handle at the time 

of resolution for the largest banks, 10, 20, up 

to 40 million deposit accounts and more complex 

account types then for smaller banks.

 So past the relationships and things 

like that, that would be hard to work through. 

And then, of course, large portions of the 

deposit balances are uninsured, ranging from 40 

to 50 percent for these institutions on average. 

And then just other challenges around 

receivership management, the receivership entity 

that the FDIC would be responsible for.

 It'll depend largely on the complexity 

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and scale of the assets that left behind in the 

receivership. It could be significantly 

simplified if we're selling the institution or 

using a bridge and much is moving to that. I 

should just note that in the event that we have 

to undertake a liquidation where everything stays 

in the receivership, the operational challenges 

are quite daunting in that circumstance.

 The last two challenges here kind of 

touch on the path to failure and the point of 

failure. They obviously -- they have more 

complex business lines and the fact that we're 

going to need to make projections about 

valuations through the course of a bridge period 

makes our assessment of the potential cost to 

resolution at the time of failure more difficult. 

And then combine that with the fact that they're 

almost certainly going to fail due to a run on 

liquidity.

 There'll be an abbreviated runway 

which will further reduce the time that we have 

to conduct valuations and to market the 

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institution. So those are the challenges. There 

are a few advantages.

 Importantly as was touched on the 

first panel, we maintain a dedicated and onsite 

presence at these institutions. It's hugely 

valuable in understanding these companies day to 

day. And then also in the runway to resolution 

when one of these banks fails, we'll have ready 

access to the source of technical information 

that we need to be prepared to resolve one of 

them.

 We maintain two resolution-specific 

record keeping requirements that relate to large 

bank resolution. One requires these banks to be 

able to calculate deposit insurance within 24 

hours notice from the FDIC and provide that to us 

within 24 hours. Another requires certain of 

these institutions to provide us with position 

level QFC data so that we can assess their 

derivatives portfolio, make decisions in a timely 

way over a resolution weekend.

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specific resolution planning requirement which 

increasingly involves not just the plant 

submission but engagement around the planning 

process with the institutions on an ongoing 

basis. So that's a lot. I'll stop there and 

interested for any reaction before we move on.

 MEMBER MAYOPOULOS: I'm curious as to 

-- it seems to me that at this scale of failure, 

the likely cause is probably a macro event that's 

likely to affect multiple institutions at once. 

And I'm curious as to how you feel about your 

ability to collectively coordinate all of that 

and how you think about the scenario planning 

about what you do with one institution may impact 

what happens at another institution and kind of 

the knock-on effect of that.

 MR. TETRICK: Yeah, so that could be 

the case, right? There could be something 

particular that a particular bank is doing in its 

idiosyncratic failure. But it could be a larger 

downturn and there's multiple institutions under 

stress at the same time. 

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Part of the -- and we'll get into this 

in the next part of this discussion. Part of the 

challenge here is that there isn't a built-in 

strategy the way that there is for GSIB 

resolution. And the GSIB model really relies on 

the resources of the institution, single point of 

entry.

 And we're relying on sort of 

maintaining operations that limits the resource 

need on the FDIC. Now bridge strategies for a 

large bank can look a lot like that. The 

challenge is there's not a built-in exit.

 So we try to focus on strategies that 

reduce the resource need of the FDIC. We can't 

control the timeline. But there is decision 

making with the other authorities about which 

weekend institutions fail on. So we would hope 

to not be resolving multiple institutions at the 

same time. But there's significant challenges 

and multiple failing at once.

 And then just to the latter part of 

your question about the impacts on other 

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institutions, this is one of the reasons why 

we're really focused on the impact, particularly 

on uninsured depositors. Because if there's a 

resolution that's impacting uninsured depositors 

and they're similarly situated banks, I think 

we'd be concerned about what the knock-on effects 

would be to those uninsured depositors. At other 

banks, we're seeing haircuts occur at the bank 

that's being put into resolution.

 MEMBER ERVIN: You probably don't need 

any extra challenges, but I want to throw two 

more in. One is for acquirers. As you get 

bigger, a lot of regulatory tasks escalate.

 So it's not just the cost of the 

institution. It's the cost across your whole 

institution where everything would be held at the 

higher capital and CCAR standards, et cetera. 

That's similarly true for foreign banks.

 Foreign banks find it more expensive 

to operate cross border than they used to. So I 

think your pool of cross border buyers also is 

difficult. So I think in terms of what happens 

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to buyers in this group I think is important. 

The second one is a legal tale. I remember a few 

years ago I think it was Jamie Dimon said if I 

tried to do this again, my board would ask me to 

have a psychological examination that I picked up 

a lot of lawsuits with acquisitions.

 Those are very difficult to due 

diligence on in the kind of time frame you're 

looking at and the costs are huge. So I don't 

know if there's any ways you can mitigate some of 

those risk for an acquirer, if there any tools 

you have in terms of making it a cleaner 

institution to purchase. But that strikes me as 

another thing that in this kind of compressed 

time frame for these scales of institution could 

be quite difficult.

 MR. TETRICK: To quickly respond, 

because there may be limited acquirers just in 

terms of capacity, our planning, we know we can't 

depend on an acquirer being available. So sort 

of looking at solutions that allow us to market 

an institution over time out of a bridge rather 

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than compressed over a weekend. But we are 

looking at things we can do to at least expand 

the range of scenarios when an acquirer could 

pick up one of these institutions quickly. Legal 

risk is a good thing to look into. But there are 

regulatory barriers particularly for the largest 

institutions that would need to be overcome.

 MEMBER CLAYTON: But also Ryan, I 

think as far as the legal risk, as we said, WaMu 

came on us very quickly. And everything was 

transferred over. We had the option to retain 

certain liabilities in the receivership and pay 

them pursuant to the priority scheme. So it's 

possible that we could offer Jamie Dime and a 

different option next time.

 (Laughter.)

 MEMBER O'CONNOR: I won't comment on 

that one. Just a couple things spring to mind. 

One, these large institutions -- and by the way, 

I should start with I completely appreciate you 

want to have a more prescriptive approach to 

getting information and creating a playbook. 

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But the starting point I would say is, 

one, you have liquidity and capital stress 

testing which obviously improves the shock 

absorbency. When I think about the Title I, 

Title II resolution plans for GSIBs, they were 

driven by, one, making sure that critical 

operations would continue. There would 

opportunity for recapitalization and to make 

those institutions internalize the costs of 

externalities they create because they created 

such systemic risk.

 I didn't hear those components here. 

And I'm not saying you don't go on this path. 

But maybe you talk about it a little bit 

differently because these -- size was the other 

thing that jumped out, size not necessarily 

equaling risk.

 So something big and simple, right? 

As long as you have the right information, you're 

going to be able to resolve in a very traditional 

sense to the way you would draw smaller scale 

banking institutions. So I would posit size, be 

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careful on.

 You can be a lot smaller and create a 

lot more complexity and be a lot more 

destabilizing. And then the question also I 

would push on, I love the recognition of model 

line being a problem because I think it sort of 

can be. But I would also say when you look at 

some of these small banks and the 40 to 50 

percent uninsured depositors, we also have to 

make sure and I think you were leading down this 

path that if it's not systemic, those components 

can fail.

 That's a terrible thing to say. But 

the reality is I think also collectively want to 

be careful of bailouts and moral hazards that 

would be potentially embedded. So I think we're 

on the right path of thinking about it.

 Part of the wording we might want to 

use a little bit differently because you're not 

necessarily dealing with systemic institutions 

and forcing them to bear the externalities which 

is why you drove Title I, Title II for the GSIBs. 

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And you also have this good cushion of liquidity 

and capital stresses. And I would just offer up 

that as you think through how you present it.

 MEMBER TAHYAR: I think this is very 

thoughtful, and I think it's good that the FDIC 

and the Fed are thinking about this right now. 

One thing to be -- we need to be crystal clear on 

is that the imposition of a long-term debt 

requirement on banks that don't have a lot of 

long-term debt right now in a rising interest 

rate environment means that you would be imposing 

enhanced increased today costs to solve a 

contingent problem. And that has to be very, 

very carefully balanced.

 And so as you're doing your analysis 

on the APNR, I would hope that's a place where 

you would be doing a very, very deep dive. 

Another deep dive, thinking about the uninsured 

deposits which some of them might be hot money 

and some of them might be sticky in the sense 

that if it's brokered deposits, it's hot. But if 

it's Joe's Auto Body Shop making payroll, it's 

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sticky. And so I would hope as you're doing the 

good and careful thinking around this APNR that 

there could be some data driven analysis around 

that because there's a lot of challenges to think 

through here.

 MS. KTMNIG: I have to add -- not to 

add challenges. I think one thing to be seen, we 

can see it on our side. But I think also 

Washington Mutual was already mentioned.

 The first guaranteed to successful 

resolution is that it comes early enough at a 

point whether it's still franchise left which 

gets us back to the discussion we had in the 

first round. The second part gets us back 

probably to supervisory presence and realistic 

assessment. The second one is clearly something 

we are contemplating is you might not be able to 

find a qualified buyer for the whole thing.

 But you might be able as part of your 

resolution planning to say there are buckets to 

be prepared. Now it's very simple to say they 

need to be prepared. If it takes two years, 

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that's far too long.

 So really in resolution planning 

already to think about whether there are chances 

to produce buckets which increase your 

optionality if need be without really 

jeopardizing the firm. And I won't comment on 

the question, what to do with a bank which has a 

balance sheet. Here is equity, there are 

deposits, and nothing is in between which is the 

challenge in this topic.

 MEMBER ERVIN: But I think, for 

example, in Europe, you generally force MREL on 

banks that are smaller than GSIBs, a lot smaller, 

and same thing in the UK. So from an 

international competitiveness issue, we're in a 

pretty different place from other jurisdictions 

that have wrestled with this. I agree with Meg 

that this needs to be done in a calibrated way. 

We have a different market.

 On the other hand, if we're going to 

internalize an externality, it is going to be a 

cost of dealing with a contingency. And it's a 

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question of does that cost go to the DIF and get 

spread around everybody else, including the 

people who are behaving virtuously? Or is it 

internalized to the institution? That would be 

difficult to resolve. I would think as a matter 

of economics, you generally want to lean towards 

the latter.

 MEMBER TAHYAR: And it's interesting. 

One of the tools we don't have here is contingent 

capital which is what MREL has, right? And 

there's been a tax blocker on that. And that may 

well be something that as you're going through 

the process of thinking through this is to 

rethink whether that tax blocker is appropriate.

 MEMBER HERRING: I think that's a very 

important point because that extra layer of 

liability really gives you a lot more option and 

time in dealing with it. I'm reminded of 

something that the OFC did -- the Office of 

Financial Research did, I probably put an extra C 

in it -- sometime ago where they looked at the 

GSIB scores of all of the major U.S. banks. And 

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I can say from the point of view of a 

professional who grades, it was very nice to see 

a huge break point between the GSIBs and 

everybody else.

 I haven't seen that updated now that 

we've had several mergers. And I'm wondering if 

you using those -- I'm not sure -- they're not 

perfect metrics but they are well recognized. If 

they look closer together than they once did.

 But in the original cut, there was 

just a really comforting break between the GSIBs 

and everybody else. Could've been reverse 

engineered. I wouldn't say it wasn't.

 But nonetheless, it did indicate they 

were quite different. If they become more alike, 

then I think it's a much easier sell to say we 

know there's a problem. We know how to deal with 

it, and these things should be extended.

 MR. TETRICK: So as I respond to that, 

maybe we can turn to the next slide. If you 

look, there's still pretty significant grade 

distribution on those scores. They may have 

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tightened some.

 But I guess part of the way that we 

think about systemic risk is it's not necessarily 

binary. It depends on the scenario. And when 

one of these institutions is failing, if it's in 

the context of a wider stress, a regional bank 

could be disruptive.

 So we've touched on a lot of this 

here. But just quickly and how do we think about 

what's the right strategy. There's not a single 

answer. These are the broad three approaches 

that we think about.

 But we really focus on the middle 

option here, the use of a bridge bank. We've 

talked about why a sale to a third party acquirer 

would be a significant challenge. A liquidation 

would be extremely costly.

 For a bridge bank, one thing that 

we're looking very, very closely at is that 

there's a big difference between a bridge in 

which we can pass all deposits in a bridge in 

which we can only pass insured deposits. And if 

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there are losses incurred by the depositor class, 

then that makes it harder to pass the cost tests 

and pass all deposits. It also means that the 

franchise is probably significantly destroyed at 

that point.

 And then importantly a bridge 

strategy, that's not an exit. That's only half a 

strategy. You need an exit to have a full 

strategy.

 And so what we focus on making the 

bridge itself feasible and we think about some of 

the ways that we could exit from a bridge. And 

certainly being able to more readily break up 

parts of these institutions by lines of business, 

regional franchises, sales of portfolios and 

looking at that in advance, that's very helpful 

and it could help with a multiple quire type 

exit. We think about whole bank type exits.

 Maybe over time if there's time to 

market out of a bridge, you can have a single 

acquirer. You could have an IPO type exit. And 

if there's significant long-term debt, you could 

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contemplate a bailout type exit for these 

institutions too where you're turning the 

institution over to its creditors.

 The problem is that the FDIC is not 

going to want to be in a bridge for an extended 

period of time. And these institutions are very 

large. And so executing any of those options 

could take a long time, and there's not a builtin exit strategy like there is for GSIBs.

 And maybe I'll just turn to the last 

slide here. Just acknowledge there's in addition 

to building up our own operational capabilities 

to operate a large bridge, these are some of the 

things that we're doing to enhance large bank 

resolvability. Obviously, we have the IDI 

resolution planning process.

 We're strengthening that starting with 

a number of submissions that are coming in this 

year. We've committed with the Federal Reserve 

to provide guidance to Category 2 and 3 

institutions, so some of the largest banks that 

file Title I resolution plans. And then we've 

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noted the ANPR on long-term debt.

 And we look forward to seeing the 

comments. And those come in towards the end of 

the year. I think that's it on this topic.

 ACTING CHAIRMAN GRUENBERG: Thank you, 

Ryan.

 MEMBER ERVIN: Could I just make one 

comment? It goes back to something that Dick 

brought up which is, is there a dividing line in 

terms of the systemic risk scores? One of the 

things I do worry about is sort of the continuity 

to the U.S. banking system.

 We've had our GSIBs since they got 

designated. They stuck there. None of them have 

de-GSIB'ed. And in terms of the other banks, 

they tend to try to stay within their buckets. 

And I worry that we've created some of these 

discontinuities, that there's no sort of ramp up 

that you cross a line also and you go into full 

Title I, planning full TLAC, et cetera.

 It would seem to me that there is no 

bright line that really just magically separates 

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that bank that's a millimeter over the line from 

one that's not quite so much over the line and 

that if I was thinking about a system that would 

work smoother, that'd be more future proof 

because banks want to grow and scale becomes 

important. That having some ramp into some of 

those capabilities would give you options whether 

to bail in on its own resources or help with a 

merger. That some sort of phasing in would feel 

like saying that both solves an industrial 

structure problem as well as a resolution 

problem.

 MEMBER PETERSON: And I want to add to 

that that I don't think that's just based on 

size. It's activity based. It's broker dealers. 

It's international activity. It's asset 

management, et cetera.

 MR. TETRICK: I think that's right. 

To Sandie's point earlier, I mean, if you just 

look at the GSIB scores and the sizes, there are 

many regional banks that are larger than some of 

the GSIBs. And that's because a lot of what's 

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scoring there is the complexity of the 

activities, the cross border activity.

 And breaking into that type of 

activity isn't something that the regional banks 

can readily ramp up into. So I think that might 

be part of why you don't see as much movement 

there. But it's definitely not just size. Size 

is important to us in terms of just who can 

acquire if you just look at it from a strategy 

perspective.

 MEMBER PETERSON: Size is only onefifth of the G6.

 ACTING CHAIRMAN GRUENBERG: I'd like 

to give you all a brief break if we could. Let's 

take five to seven minutes. And maybe if we can 

come back by around 11:20 or so, we could start 

our last session.

 (Whereupon, the above-entitled matter 

went off the record at 11:14 a.m. and resumed at 

11:26 a.m.)

 MR. CONNEELY: Okay, great. Almost 

everybody came back, so that's a positive. Ready 

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to get -- okay, great. So we're on our last 

session of the day. We're going to be talking 

about CCP resolution challenges.

 And there are a lot of challenges in 

that regard as the chairman noted up front. 

First we'll hear from Associate Director Jenny 

Traille on Title II resolution for CCPs. And 

then we have our guest speaker, Sir Jon Cunliffe, 

Deputy Governor for Financial Stability and CPMI 

chair. And he will over some remarks as well. 

So with that, I will turn it over to Jenny.

 MS. TRAILLE: Thank you, John. So as 

mentioned a few times today, we wanted to revisit 

the topic of CCP resolution under Title II that 

we started to discuss in the last SRAC meeting in 

2020. And in particular, I'd like to focus on 

some of the key challenges we face domestically 

as we think about resolving one of these 

institutions and highlights on the ongoing work 

that the FDIC is involved in internationally to 

address what are some common challenges across 

authorities and jurisdictions. 

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So in this session, we would like your 

thoughts of the prioritization of efforts to 

tackle these challenges that I'll describe along 

with any other insights that you may have and 

that you can share in addressing this complex but 

critical area of systemic risk. So many of you 

may recall that when we last met in 2020, we 

discussed the FDIC's objectives with respect to 

resolution, specifically to maintain the 

provision of the critical clearing functions in 

order to protect adverse effects on U.S. 

financial stability. We also gave a very high 

level overview of some of those challenges, and 

we would like to spend our time today going into 

some more detail.

 So the first challenge that we face is 

a lack of resources that are available 

exclusively to support resolution. CCPs 

themselves have robust loss management waterfalls 

as part of their rule books, particularly with 

respect to managing member defaults. But we need 

to plan for it and be prepared for a situation in 

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which these resources are significantly depleted 

or even exhausted by the time the FDIC is 

appointed as receiver.

 We wouldn't want a scenario where if 

recovery failed, resolution would also fail. So 

another aspect to this issue of resources is the 

potential for these end of waterfall tools to 

have some tradeoff such as potentially precyclical impacts to markets and participants that 

are already under stress in that type of tale 

event. So while the FDIC would have the 

authority to use the tools and resources within 

the CCP's rule book in Title II to the extent 

that they are still available, their application 

or the availability that we would think about in 

that context would be weighed against the 

financial stability consequences.

 And unlike SPOE for GSIBs which we've 

talked about many times already today where we 

have financial resources available to absorb 

losses and recapitalize a firm with the purpose 

of allowing it to continue to perform those 

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critical functions for the market while the 

resolution process is ongoing, we don't have 

dedicated losses absorbing resources reserve for 

resolution in the CCP context. Such tools have 

been proposed and publicly debated by legislative 

bodies, by regulators, academics, and 

practitioners. And certain jurisdictions have 

considered or even adopted some of these tools 

such as resolution cash calls that are reserved 

for resolution.

 The second challenge we wanted to 

highlight which we've mentioned earlier in Jim's 

remarks in the first session is the lack of 

requirement for CCPs to file resolution plans 

with the FDIC. So this is again an important 

contrast to the bank space where GSIBs are 

required to file resolution plans under Title I. 

And in addition to providing for the resolution 

of GSIBs under bankruptcy without systemic 

implications, the Title I planning and review 

process as we've talked about greatly informs the 

FDIC's resolution planning under Title II. 

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So the Title I process includes firm 

engagement and capabilities testing which then 

leads to refined guidance over time and builds 

our understanding of the individual firm's 

operational options and challenges and 

resolution. And this has facilitated ongoing 

improvements in the FDIC's resolution readiness 

over time. And along with the benefit to the 

FDIC, we touched on this a bit in the last SRAC 

as well.

 The process has also been beneficial 

to the firms, in particular the capabilities that 

they have developed as part of the resolution 

planning efforts have proven useful both in 

business as usual and in stress. The third 

challenge area that we want to go over today is 

that the FDIC does not benefit from a direct 

resolution engagement with these institutions. 

And rather we rely on the supervisory authorities 

of our regulatory counterparts, the CFTC, the 

SEC, the Federal Reserve.

 And that informs our understanding of 

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resolvability. So this dynamic combined with a 

lack of Title I authority means that the FDIC 

doesn't have the ability to directly remove 

barriers to resolution or proactively enhance the 

resolvability of the CCPs such as requiring 

changes to rules, structures, capabilities, or 

operations. So these challenges add to the 

complexity of CCP resolution which I think is 

acknowledged as already a difficult problem.

 And so we work with our U.S. 

counterparts and within our existing authorities 

to make progress. Over the last several years, 

we've invested a significant amount of resources 

together across a number of fronts. We have 

worked to understand how we might improve 

resolvability within our existing authorities to 

increase our shared understanding of the 

processes involved in a Title II resolution, 

including how we would make a determination for 

entry into resolution for a CCP and how to 

address the FDIC's information needs.

 We've also worked to better understand 

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the supervisory monitoring and actions during BAU 

and to develop ex ante frameworks and legal 

documents to support resolution planning. And 

yet more work remains. So I do want to spend a 

few minutes talking about some of the work that 

we're doing on an international front where we're 

very active to further progress.

 So if I could ask for the next slide. 

So the FDIC is very involved in international 

standard setting bodies such as the Financial 

Stability Board or FSB. We also directly engage 

with foreign, supervisory, and resolution 

authorities through bilateral and multilateral 

work streams.

 This work helps us develop a mutual 

understanding of our respective resolution 

frameworks, address challenges across 

jurisdictions, and learn from one another's best 

practices. When we last met, we described our 

involvement in FSB's work on FMI resolution, 

financial market infrastructure resolution, which 

focuses on CCPs. The FDIC has played a key 

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leadership role in that work since 2015, and we 

continue to be deeply engaged.

 Currently, Acting Chairman Gruenberg 

chairs the FSB's resolution steering group. And 

Art Murton, the chairman's deputy for financial 

stability, co-chairs the working group on FMI 

cross border crisis management. And this work 

has continued over these years in a number of 

forms.

 Over the course of late 2020 and 2021, 

the FSB led a series of joint workshops with the 

Committee on Payments and Market Infrastructure, 

CPMI, and International Organization of 

Securities Commissions, IOSCO, and Basel 

Committee, BCBS. And these workshops focused on 

the systemic risk posed by CCPs as well as the 

possible systemwide impacts that could occur from 

CCP recovery and resolution. Then in November of 

2020, the FSB published guidance that laid out a 

framework for authorities to assess the adequacy 

of their financial resources to support an 

orderly resolution. 

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And this guidance is meant to help 

jurisdictions analyze and identify potential gaps 

in resources, and then consider means for 

addressing those gaps. That guidance then led to 

the chairs of the FSB, CPMI, and IOSCO committing 

to conduct further work on financial resources 

for both recovery and resolution. And in March 

of this year, there was a report that was 

published that was part of an effort to determine 

whether and what future policy work might be 

needed on the use, composition, and amount of 

resources.

 When that was published, the FSB 

agreed to review the sufficiency of the existing 

tool kit for resolutions specifically. And 

considering the need for resources reserved 

specifically for resolution, including their 

associated costs and benefits, the tradeoffs that 

would come with those potential policy choices. 

And this work is currently a major focus that's 

led by our acting chairman as the chair of that 

working group with RSG (phonetic). 

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And then I also want to highlight that 

we work directly with foreign counterparts across 

several venues. The first that I'll mention 

connects nicely to our guest speaker that will 

come up next. And that's engagement on CCP 

resolution among principles from the Bank of 

England, the Fed, the SEC, the CFTC, and the 

FDIC.

 This group of five agencies has met 

several times since 2018, including in the summer 

of last year and February of this year. These 

meetings serve as a venue for high level 

engagement on these unique challenges. And they 

serve to guide the plans for staff level work 

that are ongoing among the five agencies across 

several work streams.

 We also host crisis management groups 

for CCPs. We talked about them a little bit 

earlier today on the bank space. We do this 

jointly with the CFTC and the SEC. And these CMG 

meetings or groups meet annually.

 And we've had two of them since 2017. 

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We added a third in 20210. And we also 

participate in these meetings for foreign CCPs 

which are hosted by the resolution authorities in 

those jurisdictions. These meetings are valuable 

meetings to understand our shared challenges, 

share approaches and progress, and try to 

identify improved resolution options. So with 

that backdrop, I want to turn to our chairman to 

introduce our guest speak who has graciously 

agreed to speak today and address questions.

 ACTING CHAIRMAN GRUENBERG: Thank you, 

Jenny. That was very helpful. We wanted Jenny 

to sort of lay out that background and context 

before we turn to our guest speaker, Sir Jon 

Cunliffe.

 I suspect some of you may know Jon. 

He serves as the Deputy Governor of the Bank of 

England for financial stability. He's also 

chairing as Jenny mentioned the Committee on 

Payments and Market Infrastructure for the BIS. 

He's really been an international leader on 

payment system issues and has particularly 

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focused international attention for several years 

now around the risks related to both the 

supervision and the resolution of central 

counter-parties.

 I think of all the issues relating to 

the resolution of systemic financial institutions 

since the 2008 crisis, this is the one that 

really stands out as clearly a profound system of 

consequence in which we've arguably made at least 

progress. There are a lot of reasons for that. 

Perhaps Jon will talk about that.

 But I couldn't think of anybody better 

to at least give us a broader perspective on what 

I do think is a fundamental systemic resolution 

risk for the FDIC and for this committee to 

engage in. I would note that prior to taking 

over his payment system responsibilities, Jon had 

also been responsible for the resolution work at 

the Bank of England. So Jon and Elke and I 

collaborated very closely on the cross border 

working relationship on the traditional GSIB 

resolution issues. 

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And in some sense, we're now 

continuing that on the CCP work in Jon's current 

capacity. And I would note Jenny mentioned the 

US/UK working group on CCP resolution. I always 

envied Jon at those meetings because on the U.S. 

side we had the Fed, the FDIC, the SEC, and the 

CFTC and on the other side was Jon --

(Laughter.)

 ACTING CHAIRMAN GRUENBERG: --

basically embodying all these authorities and 

thinking to myself, boy, his life may not be easy 

but it's at least a little simpler than ours. So 

with that, I think Jon is on the line. And we 

can ask him to offer his remarks. Jon, thank you 

so much for joining us today.

 MR. CUNLIFFE: No problem. Thanks, 

Martin. First just to check whether I'm audible 

and visible.

 ACTING CHAIRMAN GRUENBERG: Yes, both 

are true.

 MR. CUNLIFFE: Okay, thanks. And 

secondly, apologies. It's a privilege to get a 

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chance to address this group. And I would've 

liked to have been there in person, but I have a 

meeting tomorrow morning in Basel which we'll 

among other things talk about the work planned 

for CCPs and non-default losses and the like.

 And it made it just impossible to be 

with you and to get back in time. And as it's 

nighttime in Switzerland, I'm afraid I may look a 

little -- the lighting may look a little strange. 

So I apologize for that as well.

 Just a quick word about what I do. So 

I'm Deputy Governor for Financial Stability. But 

I also have responsibilities for CCPs, settlement 

systems, and payment systems for the supervision 

and regulation.

 So I'm both kind of micro-prudential 

and macro-prudential in this area. And up to a 

few years ago, I also had responsibility for 

resolution. One of the reasons I gave that up to 

another deputy governor actually was because we 

thought it was bad practice to have the same 

person responsible for supervisor and for 

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resolution. I think it's good practice for those 

things generally to be split.

 So for today's perspective, I guess 

I'm speaking from the perspective of the FSOC 

from a financial stability perspective and the 

CFTC and the SEC and CCP regulator perspective. 

And I'm not speaking from the perspective of the 

FDIC. But I can still remember resolution --

(Laughter.)

 MR. CUNLIFFE: -- work. As Marty 

said, I also chair the BIS Committee on Payment 

Systems and Market Infrastructure. And more 

importantly, the joint committee with have with 

IOSCO which functions as the standard setter --

the international standard setter for CCPs and 

issues the PFMI which are our version of the 

Basel standards for CCPs and settlement systems. 

So I thought I'd start today with all my hats on 

and then speak from different perspectives.

 But I'll identify when I'm talking 

from a UK perspective. And I apologize again in 

advance. I don't know how much of these issues 

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you covered in previous discussions, so some of 

what I say may seem blatantly obvious in which 

case talk amongst yourselves or something.

 (Laughter.)

 MR. CUNLIFFE: If I lose people, I'm 

happy to pick things up in questions. I'll set 

out briefly why we need effective regimes to deal 

with CCP failure, why CCPs are different than 

banks, and the risks they take and how they 

manage them, and what the UK regime will do. And 

we have proposals for a new regime which are now 

in front of Parliament which I hope we'll get 

Parliamentary approval and we can start to 

implement early next year.

 And in doing so, I'll touch on some of 

the suggestions that have been made for CCP 

resolution. So first, what does it matter? 

Well, as we know, CCP's role as central nodes in 

the financial system have made them if they're 

large enough naturally systemic and they protect 

key markets from counter-party credit risk.

 And we saw what a failure in that area 

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can do during the great financial crisis. And by 

mandating use of CCPs for some key financial 

derivatives after the GFC, we've made some of 

them even more systemic globally. For example, 

60 percent of credit derivatives are now -- swaps 

are now cleared centrally as opposed to 10 

percent before the great financial crisis.

 Eighty-five percent of interest rate 

contracts are cleared by CCPs. It was about 40 

percent before the financial crisis. And of 

course, that's just the proportions.

 The actual quantum has grown as these 

markets have expanded pretty significantly. And 

just as important as financial markets, we've 

seen the role of CCPs in commodity markets and in 

terms of the recent stress and the role they play 

in enabling hedging and forward contracts. So 

CCPs represent a concentration of risk.

 I always say this. That is not some 

unintended consequence after the great financial 

crisis. I mean, the assessment at the time is 

the benefits from centralization in terms of 

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consistent and prudent margining, transparency, 

netting, and the mutualization of losses made 

central counterparts clearing preferable to a 

complex and what would be a peak wave (phonetic) 

of bilateral contracts with much larger gross 

margin flows.

 That was the decision we took back in 

2009. I think it still holds, but we can't 

ignore the concentration of risk and the failure 

of a CCP and the effects that would have. And it 

would transmit stress quite widely throughout the 

financial system.

 And it would remove the protection 

against counter-party credit risk which I think 

is essential for markets to operate. So we do 

need to find effective ways to manage a CCP 

failure. And because the concentration effects 

exist, it means actually there are returns to 

concentration in being a CCP which means many of 

these businesses are global and they meet 

international standards in the same way as we 

need international standards -- strong 

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international standards for the resolution of 

globally systemic banks.

 However, and it's an important point, 

CCPs are not banks. And the design of any 

resolution framework I think needs to reflect 

some of the essential differences. The first and 

most obvious, the risks they run are very 

different.

 They don't do maturity or liquidity 

transformation. They don't have complex balance 

sheets with asset and liability structures or 

mismatches that need to be resolved. The two 

risks they face essentially are counter-party 

credit risk, and we'll talk about that, and 

operational risk of some sort of operational 

failure.

 On counter-party credit risk, I mean, 

this stems from the default of one or more of 

their members. As their function is to be the 

central counterpart, in other words, to stand 

between the two parties to a trade, they really 

have to ensure at all times that they have 

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exactly offsetting contracts with the buyer and 

the seller. In other words, they have to 

maintain matchbook at all times.

 And if one of the counter-parties 

defaults, they need to be able to absorb the 

losses that will probably be necessary to restore 

that matchbook by finding contracts to offset the 

contracts that have been lost. Now unlike banks, 

they don't hold capital really to absorb loss 

absorbing capital. Rather under their rule 

books, they can effectively pass losses with 

limit back to their clearing members.

 First they do that and I think the 

previous speech I mentioned the waterfall of 

allocation of losses. First they do that by 

using the pre-positioned resources of the 

defaulting member. And then they fail to 

neutralize the losses by using the pre-funded 

default fund to which all members contribute.

 And then when the pre-funded resources 

run out, they have the ability to make cash calls 

on the remaining members. And then after that, 

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they can start to haircut the margin they owe to 

some of their members. And finally, they can 

tear up some or if necessary all of the contracts 

they have with their members.

 So actually, unlike banks, when it 

comes to default losses, CCPs can't go bankrupt. 

At the end of the waterfall of recovery actions, 

they just tear up all the contracts and 

effectively the clearing service disappears. And 

I should say that if you follow the rule book, 

the equity of the others is untouched in that 

process.

 But of course, from a financial 

stability point of view, those clearing services 

are important. And tearing up of contracts 

removes the hedges that counter-parties will be 

depending upon in stress. So the CCP service 

needs to be kept operating and the transmission 

of stress needs to be kept to a minimum.

 So a quick word about non-default 

losses. The other main risk is operational 

losses not caused by default, fraud. It could be 

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cyber. It could be investment losses.

 Here CCPs generally have no powers to 

pass those losses on to their members. Nondefault losses have to be absorbed by CCP 

capital. And CCP capital is generally pretty 

small relative to the size of their operations.

 For one of our big CCPs, their capital 

is 500 million euro. Their default fund is ten 

times that. The open interest passing through 

the CCP is many, many times greater.

 So non-default losses could therefore 

wipe out the capital of the CCP and lead it to 

insolvency. And the result again would be the 

loss of the clearing service. So how should 

resolution address those risks?

 Well, the first point to make is that 

even though for default losses, the CCP rule book 

means it can effectively wind itself up without 

bankruptcy. The latter stages of that waterfall 

process could be systemically very damaging in 

the allocation of losses across the wider 

financial system, particularly when one comes to 

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the tearing up of contracts. And clearly as I 

said earlier, poor financial markets could 

disappear if we lose effective clearing services.

 And in following through those 

recovery actions, CCP managements have choices 

they can make in how they carry out those 

actions. And there are some actions they can't 

do under their rule books. And to some extent, 

they're tied to the secrets of actions that the 

rule book sets out.

 And the last point to make that as 

they carry out those actions, it's very likely 

that there'll be disagreements between CCP 

management owners on the one hand and clearing 

members on the other. And we've seen cases of 

that with defaulting members in some instances in 

CCPs in the past. So my first point is it is 

imperative that the resolution authority can step 

in and take control before CCP recovery actions 

are exhausted.

 I think the earlier speaker made the 

point that you want to ensure that when you get 

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to resolution the resources or the options that 

are available have effectively been exhausted. 

So for us, one key issue is the resolution 

authority needs to be able to step in on failure 

or the likelihood of failure before recovery 

actions have been taken too far. And the 

resolution authority needs to be able to use the 

CCP recovery tools flexibly.

 But where those are sufficient, it 

needs to have extra tools that it can use outside 

the rule book. And of course, it needs to 

understand to do this and to step in that way, it 

needs to understand the business of the CCP. And 

there needs to be a resolution plan that has 

agreed in advance.

 And resolution authorities I think can 

then take actions, most of which will be in the 

CCP rule book. But they can take them with the 

view to the avocation of losses across the system 

in taking into account financial stability 

considerations. And then, of course, resolution 

authorities will operate within a public law 

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framework.

 And I think one of the points has been 

made to us by the private sector is that would 

reduce once a resolution authority steps in. 

That reduces these tensions between CCP 

management and owners on the one hand and members 

on the other. And of course, in all of this, 

it's important as with other forms of resolution 

that there is a robust no creditor worse off 

provision.

 And the counterfactual in this case is 

I think should be what would happen if the rule 

book had been followed all the way to the end of 

the waterfall? So the current UK regime -- we 

have a regime, we have one in place since 2013 --

has many of those features. But it doesn't have 

them all.

 And the legislation that's now going 

through Parliament I think will give us all of 

those powers to operate ex ante, to require 

resolution plans, to remove obstacles to 

resolution, to step in when we need to step in. 

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And then it will give us in some areas some extra 

powers that don't exist in some of the CCP rule 

books. And it will ensure that no credit worse 

off provision in the way that I described it.

 This raises the question, though, for 

default losses is do we need extra pre-funded 

resources either in recovery or resolution to 

supplement what already exists. And I think, 

Marty, this is really where your resolution group 

is now focusing. So seen from our perspective, 

there are two reasons why you might want to 

increase the pre-funded resources in the CCP 

waterfall.

 The first and this is a key issue for 

us is the question of incentives because our CCP 

equity is not going to be written down. In the 

case of default losses, do CCPs really have the 

right incentives to risk manage properly, 

particularly when they're in competition as many 

are internationally with other CCPs? And a point 

that's raised by the private sector is whether 

the allocation of losses between members on the 

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one hand and CCP owners on the other is unfair 

because it's very little CCP skin in the game 

when the losses are mutualized.

 So it's for that reason that some 

jurisdictions like the UK already require CCP 

owners to have skin in the game. It's not 

equity, but it's pre-funded resources that can be 

called upon as mutualization takes place --

mutualization of losses takes place in the 

waterfall. And the issue is how large that skin 

in the game should be.

 Kind of what stages of the waterfall 

should be exposed to loss? The UK regime that's 

now being legislated will give us the power to 

call for a second skin in the game tranche which 

we could insert at a later point in the 

waterfall. But the key point here, I think --

and the size of that is something we have yet to 

determine.

 But the key point here to be clear, 

the objective is to ensure that the incentives 

are sufficient and rightly placed to avoid 

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resolution by incentivizing CCP management. It's 

not really a question of ensuring the pre-funded 

resources are available in resolution. So that's 

the second reason you might want to increase prefunded resources to ensure that you have enough 

in resolution and that you don't want to rely on 

cash calls, haircutting the variation margin, or 

in the later stages tear up once the resolution 

authority comes in.

 So one option which has been much 

discussed, pages written about this, would be for 

CCP to raise extra resources by issuing bailout 

bonds in the way the banks do. And then those 

bonds could be written down in resolution and the 

funds used to absorb losses. So a number of 

reasons have been given as to why that might be 

preferable to depending on the cash calls and 

cutting of margin and other tools.

 One is whether cash calls will be too 

procyclical in the event of CCP stress. And it 

would be better to have the resources prepositioned. And the other is whether cash calls 

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will actually be effective because clearing 

members might want under stress resist further 

cash calls.

 And this is a kind of complex debate. 

And I think it's going to be where Chairman 

Gruenberg's international group go next. But I 

thought I'd offer a few thoughts on this. And 

it's informed, in part, by the first stage of the 

international work which looked at the 

sufficiency of pre-funded and non-prefunded 

resources in a number of systemic CCP's ability 

to absorb losses and recovery and resolution. 

And I think that work was published earlier in 

the year.

 And the work suggested that these 

systemic CCPs could absorb failure of up to four 

of their largest clearing members. And the 

international standard is two large clearing. 

But they can absorb failure up to the four 

largest clearing members, although some would 

exhaust pre-funded resources and need to go into 

cash calls at that point. 

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But the cash calls that will be 

necessary would be within the capacity of the 

remaining clearing members which tend to be the 

larger financial institutions. And on the 

question of whether firms would be able to resist 

cash calls, I'd only observe that if you resist a 

cash call you're effectively in default. And 

that triggers other default cross causes.

 So I think it's unlikely that clearing 

members would try to resist contributing to cash 

calls. But there's a big caveat in all of this 

which is in a (phonetic) in which, say, three to 

four of the biggest clearing members fail, we may 

find that actually those liquidity resources 

aren't available for the other clearing members. 

And this could make the stress more stressful.

 And the only points I'd make, though, 

is if we're in a stress in which three to four of 

the big clearing members fail, remember that's 

not just in one CCP. That's across the board and 

across the financial system. And if the 

resolutions that we're talking about potentially 

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the failure of, say, two to four GSIBs.

 And then the resolution arrangement 

for those GSIBs has also failed, the resolution 

would enable them to continue to meet their 

obligations to a CCP without default. I think 

we're going to be in a pretty heavy systemic 

crisis and bailout bonds and the resources that 

they might offer, even if it's a full reload of 

the default fund may help. But they're likely to 

be able to resolve the systemic issues that we 

face.

 And those considerations I think need 

to be balanced quite carefully. In the end, it's 

a question of how far into the tale of the risk 

distribution you want to go with protection. And 

does the extra bang that you get by, say, bailout 

bonds, is it proportional and do the costs 

outweigh the benefits?

 And I'd say that there are costs which 

we need to recognize. Just a simple thought 

experiment back of the envelope. If a CCP issued 

bonds equal to the default bonds, so it would 

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have a full reload in resolution.

 The annual coupon of that could be 

equal to or greater than CCP capital. And those 

costs, of course, are likely to get passed back 

to users raising the cost and reducing the 

incentives to clear. So one needs to think about 

benefitting that sort of systemic stress you will 

get from this against the costs and the 

disincentives to clear in business as usual.

 Of course, jurisdictions are different 

and there could be jurisdictional reasons why one 

might want to go at least some distance down that 

route. And in a world where the resolution 

authority either doesn't have the line of sight 

or can't effectively or quickly step in before 

the resources that are available in recovery are 

exhausted or whether the resolution authority is 

not able to plan for CCP resolution and for the 

comes in and has to deal with a very complex 

situation without there being a plan or 

sufficient advance knowledge or where CCP rule 

books are either -- they don't provide sufficient 

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options or actually there are obstacles to 

resolution there which can't be cleared away. In 

those circumstances, one might argue, well, a 

reservoir of pre-funded resources that can be 

accessed only in resolution might be necessary to 

enable CCP clearing service to continue to 

operate.

 The next stage of the FSP work will 

look at these issues and maybe tease them apart 

and give us better line of sight. And finally, 

and I'll stop here shortly, just I should say a 

word about non-default losses because in a way 

these are equally if not more worrying because 

the position is very different. And the CCP 

recovery actions are very limited.

 And the capital to absorb these losses 

is pretty limited as well. So the resolution 

authority in that case will not be able to depend 

on the waterfall. It will need to have access to 

some other resources.

 So in the UK, the new powers that we 

hope will be approved by Parliament will give us 

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the power to make a cash call. We're thinking of 

something proposed to be put out there. It's 

three times the default fund to cope or to absorb 

the losses of -- non-default losses and to 

recapitalize the CCP.

 And of course, if those circumstances, 

there is no credit or worse option, well, 

protection that protects the equity. And so the 

equity of the CCP will be wiped out. We need to 

think about what then happened to ownership and 

whether the CCP was passed back to the members.

 But we feel it very important in the 

UK there is a resolution authority. We have 

access to resources, the deal with non-default 

losses. Now bailout bonds could be a reason to 

do that as well.

 But as I say, the cost of holding them 

is high. And of course, if it's an idiosyncratic 

failure of the CCP because of fraud or cyber, 

then we won't be in a systemic crisis. And those 

cash calls wouldn't have that procyclical effect. 

But again, that's how you deal with non-default 

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losses as a resolution authority needs to be 

worked out.

 And I think it's very important a 

resolution authority has access to some resources 

to meet that and to be able to keep the clearing 

service in operation. And the last point I'd 

make and this is something that will come up in 

our meetings tomorrow, of course the CPMI-IOSCO 

standards are for the operation of CCPs. They 

don't include resolution. We deal with life and 

the resolution authorities deal with that 

(phonetic).

 (Laughter.)

 MR. CUNLIFFE: But I think we need to 

think about in recovery should CCPs have better 

options to deal with non-default losses. And 

that's work that I hope we'll be starting in the 

future. I'll stop there, Marty. Thank you.

 ACTING CHAIRMAN GRUENBERG: Jon, thank 

you very much for that. I must say exceptionally 

lucid presentation on a pretty complicated 

subject. And Jon's agreed to take a few 

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questions from the committee if there any members 

that would like to follow up with him. Yes, Dick 

Herring from the University of Pennsylvania for 

Jon's benefit.

 MEMBER HERRING: Thank you. That was 

a terrific overview. You didn't mention one of 

the differences from a bank resolution that 

strikes me as very important in this case. In a 

bank resolution, we can hope at least to have a 

resolution weekend. It strikes me that with a 

CCP, you have almost no time to intervene and try 

to take control of the situation, keep it from 

deteriorating quickly. How do you deal with that 

much shorter time for action?

 ACTING CHAIRMAN GRUENBERG: Jon, I 

think you may be on mute.

 MR. CUNLIFFE: I'd been on mute. I'm 

sorry. Look, that's a real challenge. And in 

the circumstances which this is happening and say 

two clearing members have defaulted, prices will 

be moving very fast in markets. And so you'll be 

in a situation of general stress. 

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We've -- I mean, to my mind, it makes 

the case for the resolution authority to be 

closely involved with the business of the CCP for 

there to be close cooperation between the CCP 

supervisors and the CCP resolution authority. 

It's easy for me to say that because in the Bank 

of England we look at these things in an 

integrated way. But also the resolution plan has 

got to have stabilization.

 That said, some of the defaults we've 

seen in the past, CCPs have been able to go 

through that default waterfall quite quickly. 

I'm thinking of Lehman Brothers. So the Lehman 

Brothers default. There were large positions 

held certainly at the London Clearinghouse.

 And those positions were closed. They 

were auctioned off, the losses absorbed in the 

middle of a global stress if you remember. The 

losses absorbed and people paid out very quickly 

whereas the nonessential clear contracts took 

years to work out in a bankruptcy.

 But it is a challenge. I think what 

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we'll do in the UK also is we will do some dry 

runs and some kind of resolution testing. I 

think that once the resolution authority steps 

in, we haven't had to do a big resolution in the 

UK I'm pleased to say.

 But once the resolution authority 

steps in and says, look, we are now in charge. 

We're taking over control of the rule book and 

the actions, I think that might also have a 

stabilizing effect. But ex ante planning, 

wargaming, knowing where your tools are and the 

risks I think will be essential. But it will be 

quite a stress period.

 MEMBER HERRING: Thank you.

 ACTING CHAIRMAN GRUENBERG: Wilson 

Ervin?

 MEMBER ERVIN: Thanks, John. I agree. 

This is a terrific presentation on a tough 

subject. We recently gone through a period in a 

few markets where interest rates were quite 

shocked and went outside some of the initial 

margins that people had been thinking about. 

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I am wondering if we're thinking about 

different types of events where we might want to 

protect, could minimum initial margins, some sort 

of constraints on that be another solution if 

we're thinking about different types of 

waterfalls that could internalize more of these 

to the stressed members and take some of the 

pressure out of this. A second question I had is 

if you're not wiping out equity in some of these 

cases, how do you align the incentives of the CCP 

towards systemically positive events? If it's 

really not coming out of their pockets, how do 

you improve that alignment going forward?

 MR. CUNLIFFE: So on the first, I 

think, I'm doing work with IOSCO co-chairing a 

group with Ros Behnam of the CFTC on what we saw 

in the dash for cash in 2020 and actually what 

we've seen in the commodity markets. I should 

say, by the way, if that was a polite reference 

to the little local difficulty we had in long 

gilts in the UK a couple weeks ago, those are all 

bilaterally margined. So we didn't actually --

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there was no CCP impact.

 The impact was taken by the banks that 

were providing the repo basically and margining 

bilaterally. But more generally, I think we do 

need to look at the responsiveness of CCP margin 

to shocks. And I mean, this goes down to the 

unlovely name, do you need mechanisms for antiprocyclicality.

 So in other words, should we be 

calling margin more prudently in good times or 

normal times so that the jump to stress margin is 

not so great in their terms. And we will be 

looking at that work. We published a report in 

that group.

 We just looked for the dash for cash, 

and I'm hoping we can look at that 

internationally, at least some interest to look 

at the responsiveness of CCP margin models 

because ideally as we've been, so more than 

ideally, you don't want to be in a resolution 

situation to begin with. And the protection 

against default losses is the initial margin that 

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the defaulter has to pay in advance and then the 

sizing of the reporting. And I hope out of that 

will come some views on how to measure 

procyclicality of margin and stress which is what 

will cause the default.

 The margin would go up. You will see 

the clearing member will not be able to pay. And 

do we need to -- I think you called it minimum 

margin. But do we need to be calling a bit more 

margin in normal times a bit overprudently in 

order to avoid a big jump under stress?

 Some jurisdictions already in the UK 

and Europe have, I'll use the word, antiprocyclicality measures. We learned some lessons 

in the dash for cash about how effective they 

are. But I think that is an issue. It's one 

answer. The other answer to avoid you getting to 

resolution is exactly as you said, making sure 

the incentives are aligned.

 The problem with equity, this is 

something I think the FSB wrestled with when it 

put out its first set of guidance some years ago 

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is if you have a no creditor worse off protection 

and if the rule book basically says the CCP can 

call of them to make unlimited calls on its 

members and then wind itself up and still 

preserve the equity. You can't square that with 

writing down the equity and resolution with a no 

creditor worse off guarantee. I think that's 

something that needs to be looked at again 

actually. And we need to think about whether the 

no creditor worse off guarantee should offer that 

level of protection to shareholders in terms of 

incentives.

 But skin in the game, so resources 

which are not equity don't go to the ownership 

but which belong to the CCP owners and which are 

exposed either initially when mutualization 

happens or initially and then as you dig deeper 

into the waterfall, that's one way of if you like 

creating the incentives that writing down the 

equity would give you without having to wrestle 

with this no creditor worse off protection which 

is important in resolution because we are 

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disturbing people's legal property rights and 

they do need to be protected. But I think 

incentives will be part of it. And certainly in 

my jurisdiction we're going to be looking at skin 

in the game and whether that is in the right 

place.

 ACTING CHAIRMAN GRUENBERG: Yes, 

Sandie?

 MEMBER O'CONNOR: Jon, thanks so much. 

A few just sort of follow-ons. You talked a 

little bit about the non-default losses and 

having the resolution authority have the ability 

to cash call. Again, just how are you thinking 

through because you clearly know that's the risks 

that are occurring are solely brought on board by 

the CCP management itself.

 And I should say we're talking about 

deneutralize, not neutralize CCPs. But they make 

the choices on where to place their investments, 

where to place that collateral, and how much they 

spend on their cyber resilience. So having the 

backstop of doing a cash call of the clearing 

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members which have no engagement in that risk 

management but provide a pocket.

 Well, I understand that can stabilize. 

That's just such a disconnect. How can that be a 

good long-term approach? And maybe you're saying 

that's why we want to look for better tools to 

really aligning incentives to appropriate risk 

management. That would be the first question I 

have. And I have another one if I could, 

Chairman.

 MR. CUNLIFFE: Let me do that one. 

Should I do that one because I'll --

MEMBER O'CONNOR: Please.

 MR. CUNLIFFE: -- forget.

 (Laughter.)

 MEMBER O'CONNOR: Me too. It's all 

good.

 MR. CUNLIFFE: Yeah, so look, I mean, 

before losses start, there is a really big 

problem, we already have actually in the UK that 

you can mutualize the investment losses where 

they put their money, where they put their 

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margin, where they lose that. So we already have 

that in the UK regime, but we'll extend it. I 

think you're in the world of second best here.

 Bear in mind that however you fund 

that, whether it's pre-funded resources or 

whether it's a cash call, have a clearing 

obligation, clearing mandate on many of these 

services. Those costs are going to be passed 

back to users. So it's not a question that there 

is some way that users can avoid the costs.

 If you say we -- and of course, with 

non-default losses, it's very difficult to size 

them, particularly something like a cyber attack. 

But if we said, like -- the idea I think has been 

talked about in the UK that it's a multiple of 

the default fund. The carry cost of that is 

pretty large, and it's passed back to the 

members.

 Now of course, these resources, 

they're not doing anything because they're just 

sitting there kind of waiting to be used which is 

a difference I think with banks (phonetic). So 

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in that world of second best, I think you wanted 

two things. Non-default losses would wipe out 

CCP equity.

 There's no, no creditor worse off 

protection there because in the current rule 

books that's what would happen. So the incentive 

has to come from the wipe out of the equity which 

you think would have some incentive effect. And 

then I think members will be -- members need the 

clearing service, and we need the clearing 

service to continue.

 And the choice then is because these 

are multilateral. You go back to the members or 

whether the public sector steps in. And I think 

public sector support, but CCPs are something we 

all want to avoid for the obvious reasons.

 And so one last thing which is as we 

back resolution in the situation where CCP's 

capital is wiped out by the members. And then 

the losses are absorbed by the cash call, and the 

CCP is re-capitalized by the cash call. Then in 

those situations, the members would then owe the 

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clearing services.

 I mean, they might not want to, but 

that's pretty much the same as in bank 

resolution. But I don't think there's an easy 

answer to this. One better answer to this I 

think might be for CCPs to have better recovery 

options and also to think about how would their 

members, they manage these risks.

 As a general view, think the more you 

put members -- expose members to these risks, the 

more they will demand, I think, more involvement 

in risk management and to understand what is to 

be expected on CCPs. And maybe that comes to 

something around the governance of CCPs and the 

governance of risk management machinery. Just 

one last point on that which -- I'll get told off 

for saying it, but I'll say it anyway.

 When you talk to the CCPs, they tell 

us that the pressure they get from their members 

is to charge less margin, to reduce the cost of 

failing all the time. When you talk to the 

clearing members at very senior levels, they say 

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they're worried about the risk in CCPs and the 

fact that they are exposed to these risks, both 

the neutralized default and the non-default. And 

they don't have kind of enough influence on the 

CCPs.

 I think some of the answers to this 

lie in the clearing members. And actually 

whether the risk controlled impulse in the 

clearing member outweighs the can I do this trade 

as cheaply as possible impulse in the clearing 

member. So there are some issues there, I think, 

for clearing members as well.

 MEMBER O'CONNOR: Yeah.

 MR. CUNLIFFE: So you had a second 

question.

 MEMBER O'CONNOR: Yeah, let's -- so 

well, I think just a couple things. I think on 

the governance, I think you nailed it there. And 

I think if you see many of the writings and the 

acting chairman mentioned them by both buy side 

and sell side, I think there's just a very clear 

drive by global industry -- and I'm no longer in 

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it anymore -- to actually build up front 

resources because you want them to be 

predictable, manageable, and understood. Yet it 

seems really hard to get there. And I'm just 

curious as to your viewpoint because it seems 

like our regulators are aligned. Our academics 

are aligned.

 The industry wants something yet we 

are not there yet. And I think up front is the 

way to go and inclusive of bail-inable debt 

except I would just offer rather than shock 

absorbency, that's really your recapitalization 

mechanism, right? Because then it moves from a 

demutualized to a mutualized model which is 

probably a more appropriate model.

 But that's just not where we are at 

the moment. So I guess my question is why are we 

collectively having a hard time if everyone says 

they want more pre-funded, they want TLAC, they 

want better collateral, they want more 

appropriate through the cycle margins. So I'd 

love your view because I certainly can't figure 

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it out.

 MR. CUNLIFFE: So first of all, I 

think to the extent the CCPs complete a margin 

that they shouldn't. So I don't know if they do 

or not.

 MEMBER O'CONNOR: They do.

 MR. CUNLIFFE: But to the extent they 

do, that's because they're under commercial 

pressure from their clearinghouse. And when you 

talk to them, particularly for clearing services, 

there's a contest between different CCPs. We 

certainly get an awful lot of reports that they 

are basically under pressure because they're 

clearing members will go to the cheapest auction 

and of course pre-funded resources cost money.

 But there are other things that cost 

money in terms of margin as well. So I'm not 

sure it's quite as one sided as one things. And 

of course, the cost of bailout bonds as I say, so 

I think the report from London Clearinghouse is 

around 10 billion.

 I don't know what it will be on the 

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bailout bond. But that cost particularly where 

there's a clearing mandate and they're legally 

obliged to use the CCP. And they just want to 

get into the economic regulation of CCPs. Maybe 

we'll have to go there one day.

 Those costs are going to come back to 

members as well. So I don't see this as such a 

one side set of issues to be honest. I think 

there's a really big issue about transparency. 

And this comes down to margin models.

 One of the recommendations of the 

CPMI-IOSCO group as I mentioned was that there 

should be much more transparency around margin 

models and their procyclicality, how they will 

react in stress so that clearing members can see 

that and plan for it. But also metrics so that 

clearing members can have a view on whether they 

want to use CCPs with more procyclical models or 

less procyclical models. Some of it will depend 

on the nature of the clearing services.

 Clearly a great difference between 

clearing agricultural futures on the one hand and 

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interest rates on the other. But I think 

transparency is a big issue here. But I think 

also we need to think -- individual regulators 

needs to think about whether I called it prefunded or whether I call it just the way those 

margin models attune between pre-stress and 

stress.

 I think there's a conversation to 

happen as well. But I mean, I guess my point is 

at the end some of the pressures on CCPs come 

from the members. I think it would help if 

members looked to the seniority and the 

background of the people they appoint to those 

committees.

 MEMBER O'CONNOR: Yeah, I think you're 

right about that. And I would suggest to that 

where members -- clearing members raise certain 

issues that are related to risk, whether it's 

margin or collateral or things of that nature. 

There's a way that those that oversee the CCPs 

have insight into that because I think there's a 

gap between what the clearing members may weigh 

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as a viewpoint and whether or not that gets taken 

on board.

 Reference, Don and I wrote a little 

bit about this in the Task Force on Financial 

Stability in December 2017 when Bitcoin went on 

to CME, for example, and got part of the 

waterfall in the default fund. That's 

interesting, not standardized, et cetera. So I 

just think we need to create some transparency 

there so that the regulators can be actually 

helpful in understanding the risks that are 

coming on board.

 MR. CUNLIFFE: I think that's right. 

But I think the regulators also need the power to 

be able to take those decisions. And different 

jurisdictions have regulators who have different 

powers for the approval or not of new clearing 

products.

 But some of this goes, I think, to 

regulator and supervisible powers (phonetic). 

And it's not just new products. And there's also 

actually part of the legislation I was talking 

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about. We'll give the Bank of England rulemaking 

power in this area which we haven't had in the 

past because it was all done in euros. We have 

to have more options, I think, in the future.

 ACTING CHAIRMAN GRUENBERG: Good. Are 

there any other questions for Jon?

 (No audible response.)

 ACTING CHAIRMAN GRUENBERG: Jon, thank 

you. This has been a superb overview of an 

important issue. And we want to elevate 

attention to it, so this will be an ongoing issue 

and matter of attention for the FDIC. And we'll 

bring it back to this committee as well. So 

thanks a lot.

 MR. CUNLIFFE: Okay, thanks. Thank 

you for the invitation, Marty. Also, thank you 

for taking on the international work. These are 

basically global infrastructures and we need to 

manage this.

 ACTING CHAIRMAN GRUENBERG: Thank you. 

We'll see you. All right. Well -- yeah, John.

 MEMBER REED: It was interesting, the 

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contrast between the Bank of England. I got the 

sense from our earlier discussion that most of 

the progress we've making here is procedural. 

We've got a lot of people talking together and 

building understanding that we didn't have 

before. But substantively, where do we stand 

here in the United States if one of these units 

were to get into serious trouble. Do we have the 

capability to deal in a timely way?

 ACTING CHAIRMAN GRUENBERG: I'll be 

glad to respond, but I'll give Jenny first crack.

 MS. TRAILLE: Sure. So I mean, we've 

highlighted a number of the challenges today, 

including the runways likely to be short. So I 

think that we look at the existing planning that 

we have, our existing authorities and tools. We 

talked a lot about the procedure, the way we work 

with the supervisors and the other authorities 

because that's how we build our understanding and 

our information.

 And so we do look at individual firms 

and we do build on that planning. But we 

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acknowledge that there are challenges and there's 

more work to be done there, data. I mean, 

there's a lot of things that we've highlighted.

 I think ultimately the strategy for 

CCP resolution isn't that much different than 

what we would attempt to achieve in further 

institutions in that you're trying to preserve 

those critical operations for the market. And so 

if there was a -- we would look to move those 

critical operations into a bridge institution. 

And so the work then goes into how do you 

operationalize that. But the strategy isn't so 

much different. It's just all sort of the 

unknowns and the information that we need.

 ACTING CHAIRMAN GRUENBERG: If I can 

comment, and it really goes to the broader issue 

that was raised earlier about the gap on the 

resolution side relating to non-bank financial 

companies of which CCPs are in some sense the 

ultimate example of a systemic nonbank financial 

company. And the fact is this is my perspective 

on it that the Dodd-Frank Act really put in place 

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a coherent framework of authorities for the 

agencies to deal with the resolution of a global 

systemic banking organization. We really have 

the Title II authorities with the orderly 

liquidation fund backstop complemented by the 

Title I resolution plans which gives us both a 

line of sight into the companies and authorities 

to get the firms to make organizational and 

operational changes to enhance their 

resolvability.

 And we got domestically and 

internationally an agreement on a requirement for 

TLAC additional loss absorbing resources to 

facilitate the resolution of the firm. So that 

we really have a -- and we've made enormous 

progress if I may say in terms of cross border 

cooperation with the key jurisdictions 

represented by Elke's presence here and Jon's 

participation in this meeting. So that we've 

really built what I would consider to be a fairly 

credible framework which hasn't been tested yet 

in practice. 

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We have not yet executed it. So I 

have that caveat that until we do it, I'd be a 

little cautious about what representations we 

make. But I think we have a set of authorities, 

capabilities, resources that did not exist across 

international relationships that simply didn't 

exist prior to 2008 that puts us, I believe, in a 

very different place.

 And then I happen to believe we could 

execute if it were required of us. I think in 

the nonbank financial company sector and the CCPs 

are the prime illustration of this. We don't 

have that coherent framework.

 And I should mention the supervision 

authority that we talked about earlier where we 

as the banking agency have a supervisory role and 

line of sight into these firms. On the nonbank 

side and CCPs are a good illustration, we have by 

default Title II would be the public authority 

for a systemic firm failure, whether it's a bank 

or nonbank. And we can bring those authorities 

to bear. 

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But the supervision responsibilities 

are in the market regulators. And we do not have 

a resolution planning requirement. And we've 

just been -- we're talking about internationally 

additional resources, loss observing resources, 

and resolution but don't have something in place.

 So we don't have the framework on the 

nonbank side including the CCPs that we've built 

on the banking side. We have the benefit of now 

having a framework and an example to learn from 

and apply. But frankly, we have a lot of work to 

do in the United States with our counterpart 

agencies to try to as best we can the Fed, the 

SEC, the CFTC to try to collaborate in the 

absence of additional statutory authority as well 

as on the international side to try to build 

stronger cross border relationships.

 But the question is a fair one. We 

don't have the framework, the infrastructure in 

place on the nonbank side. And that's why this 

is on the agenda for today's meeting because I 

think looking at the post-crisis world, this is 

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probably where our attention and priority needs 

to be.

 MEMBER CLAYTON: Yeah, all I can say 

is I agree with you. Back in my old seat, both 

of these conversations that we've had today are 

related. Who are the members of the CCPs?

 They're the entities that we're 

looking at. And I knew that if it's a brokerdealer, you would be calling me, telling me make 

sure they make good on their obligations to the 

CCP because they have to be related, right? They 

can't look at CCP resolution in isolation from 

resolution of financial institutions because 

they're going to happen at the same time.

 MEMBER O'CONNOR: And the great news 

is in most of the financial institution -- I 

think in all of the financial institution 

resolution recovery plans, their exposures to the 

CCP are in there, right? And their largest 

counter-party exposures are in there. Where I 

think the model becomes less stable from the 

centralized approach is these uncapped cash 

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calls, these potential contract tear ups which is 

basically taking the CCP out of the space of 

being a CCP and opening up exposures that people 

can't manage.

 And just to follow that thought 

through, if you're a clearing member, you're not 

allowed to operate out of a CCP. If you're an 

end user, you can go. But who are you going to 

trade with because there's no market debt?

 So these are -- again, if they're 

predictable, manageable, it can be done. Those 

pieces need to be closed down. And the last bit 

I think we should carry on thinking about is, who 

has some of these extraordinary tools?

 Who can enact them, like, variation 

margin haircutting? And for those who may not be 

as familiar with it and I'm sorry to say I am as 

familiar with it as I am. That would be the 

equivalent of in a bank resolution plan saying we 

are just going to haircut your deposit in order 

to survive.

 That wouldn't exist anywhere else. So 

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11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

if we're going to think like that, who does that 

and for how much? Because that might be 

perfectly good in recovery for a recovery and 

resolution authority to do.

 But I would question that in the hands 

of the management of the CCP that has taken it 

into this place. And again, the demutualized 

model, not the mutualized model. So I think 

that's where the work needs to be done.

 And the reason hair is not on fire is 

because we do have a lot more strength in our 

CCPs. There is margin. We saw the results of 

the recent report that came out at 4 times 

coverage and 1.4 times scale up, right?

 Those are good things. But time, we 

need to sort it out it seems to me. So really 

please keep doing this really important work so 

we can finish taking it to the hoop.

 ACTING CHAIRMAN GRUENBERG: Thank you. 

Anything else for today?

 (No audible response.)

 ACTING CHAIRMAN GRUENBERG: Well, 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
192 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

thank you all. This has been a very helpful 

discussion, and we appreciate you all taking 

part. And we'll do it again next year. Thank 

you, all. And we'll have lunch upstairs.

 (Whereupon, the above-entitled matter 

went off the record at 12:33 p.m.) 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
Neal R. Gross and Co., Inc.

(202) 234-4433 Washington DC www.nealrgross.com

193 

A

a.m 1:9 5:2 129:19,20 

abbreviated 110:20 

ability 5:19 6:5 10:21 

42:9 53:3 65:13,14 

83:13 92:10 112:12 

135:3 149:21 158:11 

172:12 

able 7:2 31:16 35:9 38:3 

67:11 90:4 92:1,4 

97:6 111:15 117:20 

120:17,19 125:13 

149:5 153:4,7 159:5 

160:10 161:18 162:18 

164:5 166:11 170:7 

182:15 

above-entitled 129:18 

192:5 

absence 188:15 

absolutely 6:4 70:14 

95:22 

absorb 101:20 108:3 

132:20 149:5,9 

157:15 158:12,16,19 

162:16 163:3 

absorbed 151:4 166:17 

166:19 175:20 

absorbency 108:1 

117:4 178:12 

absorbing 133:3 

149:10 186:13 

academic 89:8 98:16 

academics 133:6 178:6 

accelerate 62:5 

accelerated 62:6 

access 17:11 33:20 

35:20 36:6 37:21 

42:13 44:13 111:9 

162:19 163:14 164:4 

accessed 162:5 

accessible 84:14 

accomplish 26:13 

75:12 

account 109:13 153:20 

accountability 27:13 

81:18 86:18 91:1 

accountable 87:1 

accounts 14:22 109:10 

109:12 

accurate 93:1,13 

achieve 27:10 51:21 

185:6 

acknowledge 126:11 

185:1 

acknowledged 135:9 

acknowledging 100:9 

acquire 107:20 129:9 

acquirer 115:11,20 

116:3 124:15 125:21 

acquirers 105:15 

114:12 115:18 

acquisitions 115:6 

Act 10:9 17:6,10,15 

20:7 30:7,8 81:11 

185:22 

acting 1:11 3:2,4,17 

4:11,21 5:3 13:12,22 

14:12 15:17 16:6 

53:22 58:7 59:9 66:6 

66:10 70:3 127:5 

129:13 137:3 138:21 

140:11 142:9,19 

164:19 165:15 167:15 

172:7 177:20 183:5,8 

183:20 184:10 185:15 

191:19,22 

action 17:18 50:21 

165:14 

actionable 71:19 74:4 

actions 48:8 57:3 136:1 

150:7 152:5,7,7,9,12 

152:19 153:6,17 

162:15 167:9 

active 26:22 136:7 

activities 26:10 27:3 

129:2 

activity 32:8 104:21,22 

128:15,16 129:2,4 

actual 25:4 46:9,20 

83:10 146:12 

ad 31:4 

add 15:7 40:13 45:12 

45:13 47:10 49:14 

54:1 58:8 59:19 64:5 

120:6,7 128:13 135:7 

added 140:1 

addition 7:19 8:22 

18:15 58:11 108:22 

126:11 133:18 

additional 58:15 59:2 

59:16 74:21 87:9 

186:13 188:5,15 

address 24:22 36:8,20 

54:13 59:17 64:21 

66:16 130:21 135:21 

136:17 140:10 143:1 

151:15 

addressed 45:11 109:2 

addresses 60:6 

addressing 41:5 131:5 

138:4 

adequacy 29:8 137:20 

adjust 79:18 

administrative 17:2 

103:11 

adopt 25:8 26:2 

adopted 133:8 

advance 27:18 125:16 

144:22 153:15 161:21 

170:1 

advanced 11:16 18:2 

advantage 6:11 

advantages 111:2 

adverse 131:11 

adversely 65:14 

advisor 1:15 6:14 

advisors 70:20 

advisory 1:3,9 17:8 

28:6 50:1 71:3 

Affairs 2:14 

affect 49:19 62:8 

112:10 

affiliates 106:12 

afraid 143:8 

agencies 11:13 18:13 

22:3 26:19 34:20 

36:11 51:12,17 52:4 

63:9 64:21 71:22 75:1 

84:5 139:9,15 186:2 

188:13 

agency 5:22 6:1 17:13 

34:17 56:11 187:16 

agency's 76:21 

agenda 9:11 21:15,16 

21:19 24:5 37:1 70:6 

70:7 99:21 188:21 

ago 41:11 55:19 56:14 

56:21 115:3 122:21 

143:18 168:21 170:22 

agree 15:12 62:10 

84:18 121:17 167:17 

189:4 

agreed 8:20 138:14 

140:10 153:15 164:22 

agreement 186:12 

agricultural 180:22 

ahead 96:15 

aimed 53:9 

alert 90:6 

Alfred 3:12 16:21 22:9 

align 168:10 

aligned 170:19 178:6,7 

aligning 173:7 

alignment 168:13 

alike 123:15 

alive 56:13 

allay 82:16 

allocated 81:10 

allocation 149:15 

151:21 155:22 

allow 37:12 115:21 

allowed 6:20 190:7 

allowing 132:22 

amount 15:15 69:5 

135:13 138:11 

amplify 64:4 

analysis 30:9 33:18 

49:7 73:7 119:15 

120:3 

analytical 29:17,20 

analyze 138:2 

ANDREW 3:9 

Andy 16:20 22:9 50:9 

announcement 83:2 

annual 5:15 32:10 

161:2 

annually 139:21 

annuitants 59:5 

another's 136:18 

ANPR 15:4 18:3,11,17 

127:1 

answer 18:22 60:4 

64:17 73:1 92:19 

124:11 170:17,17 

176:5,5 

answers 177:6 

ante 92:8 98:22 136:2 

154:20 167:10 

anti- 169:7 170:13 

anybody 27:21 98:3 

141:12 

anymore 64:11 69:15 

178:1 

anyway 176:17 

apart 162:9 

APNR 119:16 120:2 

apologies 142:22 

apologize 143:10 

144:21 

apparent 105:5 

application 132:14 

applied 42:18 

apply 188:11 

appoint 181:13 

appointed 132:3 

appreciate 19:13 

116:20 192:2 

approach 25:1 26:2 

27:10,15 52:2 57:18 

65:20 71:10,15,19 

75:8 77:9,13 97:3 

116:21 173:5 189:22 

approaches 25:9 42:10 

124:11 140:6 

appropriate 31:9 34:16 

122:14 173:7 178:15 

178:21 

appropriately 82:22 

approval 145:13 182:17 

approved 18:6,8 162:22 

architecture 64:12 

area 5:17 49:15,18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
194 

71:21 96:2 131:6 

134:16 143:17 145:22 

183:2 

areas 7:11 49:21 51:6 

155:1 

arguable 7:12 

arguably 141:9 

argue 69:7 162:3 

argument 88:18 

Arlen 73:14 

arm 60:18 

Army 56:7 58:9 59:20 

72:8 

arrangement 160:2 

arrangements 32:7 

36:17 

array 108:19 

Art 137:5 

ARTHUR 3:11 

article 88:12 

asked 17:3 

aspect 132:6 

aspects 20:18 

assertions 34:9 

assess 111:19 137:20 

assessing 33:11 

assessment 34:2 53:16 

88:8 110:15 120:16 

146:21 

asset 46:11 128:16 

148:11 

assets 81:3 85:1 87:13 

104:9,21 108:20 

110:1 

Assistant 1:19 

Associate 130:6 

associated 35:14 73:17 

138:18 

assume 85:2 

assumptions 34:8 

atrophy 57:19 

attack 174:13 

attempt 185:6 

attendance 17:8 

attention 12:16 66:14 

141:1 183:11,12 

189:1 

attentive 100:18 

attune 181:6 

auction 179:14 

auctioned 166:17 

audible 27:22 142:17 

183:7 191:21 

audience 81:20 

audit 44:18,19 45:5,6,8 

55:15 

auditing 45:18,19 

Audits 45:15 

authorities 20:3 23:6 

24:22 32:3,12 42:22 

43:2,5 47:11 54:4 

60:10 66:22 67:22 

68:1 75:4,18 76:9 

77:6 87:2,15 113:16 

130:22 134:19 135:11 

135:16 136:13 137:20 

140:3 142:10 153:16 

153:22 164:11 184:16 

184:18 186:1,4,7 

187:4,21 

authority 8:12 10:10 

20:20 43:3 49:1 52:17 

52:21 78:16 80:2 

102:9 103:3,4,19 

132:12 135:2 152:18 

153:4,7 154:4 157:9 

161:14,17 162:18 

163:13 164:1,4 166:2 

166:5 167:3,6 172:12 

187:15,19 188:15 

191:4 

Auto 119:22 

availability 132:15 

available 27:18 71:20 

76:21 77:4,11 84:7 

92:16 97:13,14 98:3 

101:11,15 102:11 

103:10 108:6 115:20 

131:17 132:14,20 

153:2 157:3 159:15 

161:16 

average 89:16 109:18 

avocation 153:19 

avoid 43:22 91:16 

92:10 156:22 170:11 

170:17 174:10 175:16 

avoiding 24:18 

aware 71:15 77:12 

awareness 71:14 76:15 

awful 179:12 

B

B 82:14 

back 35:19 38:17 55:14 

57:20 59:5 65:20 82:4 

91:9 96:3 97:7 98:5 

98:13 120:13,14 

127:8 129:16,22 

143:7 147:7 149:12 

160:21 161:4 163:11 

174:9,17 175:13,18 

180:6 183:13 189:4 

backdrop 140:8 

background 140:13 

181:13 

backstop 172:22 186:5 

backstopped 103:18 

backup 42:21 45:1 

bad 14:17 72:17 94:17 

99:21 143:21 

bail 128:8 

bail-inable 178:10 

bailed 94:21 

bailing 91:18 

bailout 126:1 157:12 

160:7,16 163:15 

179:19 180:1 

bailouts 118:15 

Bair 1:12 20:8 

Baker 3:7 70:21 78:2,3 

80:6 

balance 121:8 148:10 

balanced 119:14 

160:13 

balances 109:17 

ball 61:21 62:3 

balloon 64:16 

balls 57:2 61:22 

bang 160:16 

bank 3:6 12:22 23:2 

35:7 51:14 55:4 69:15 

70:18 84:21 89:18 

95:17 99:8 100:10,17 

100:22 106:7,22 

107:10,20 109:1 

111:14 112:19 113:11 

114:8 121:7 124:6,14 

124:18 125:18 126:14 

128:1 133:16 139:6 

139:19 140:17 141:19 

165:7,9 166:6 176:3 

183:1 184:1 187:20 

190:19 

banking 1:15 6:14 9:20 

10:22 11:9,13,19 

14:22 18:5 25:2 34:17 

34:20 64:9 85:5,8 

104:22 117:22 127:12 

186:3 187:16 188:9 

bankrupt 150:6 

bankruptcy 1:14,20 

15:22 21:7 48:22 51:3 

80:11 81:12 133:19 

151:19 166:21 

banks 11:7 22:19 23:10 

25:5 35:6 43:15 45:18 

49:9 58:15 63:4 84:5 

89:14 97:5 100:1,20 

100:21 103:15 104:18 

105:7 106:17 107:2,8 

109:11,13 111:8,14 

114:5,8,18,19 118:8 

119:9 121:13 122:22 

126:21 127:15 128:5 

128:21 129:4 145:9 

148:2,4 149:8 150:5 

157:13 169:2 174:22 

barrier 38:7,11 

barriers 116:6 135:4 

based 15:21 31:14 

128:14,15 

Basel 137:14 143:3 

144:17 

basic 90:13 92:15 

basically 80:13 142:10 

169:3 171:2 179:13 

183:18 190:2 

basics 86:21 92:14 

basis 6:5 32:10 112:5 

BAU 26:7 27:3 136:1 

BCBS 137:15 

bear 6:11 20:11 118:21 

174:4 187:22 

becoming 54:15 

beginning 65:10 

behalf 34:16 

behave 98:15 

behaving 98:15 122:3 

Behnam 168:16 

believe 5:10 60:3 65:11 

67:5 68:18 90:1 187:7 

187:9 

belong 171:15 

belongs 39:14 40:10 

beneficial 134:11 

benefit 9:9 13:7 87:19 

92:13 134:8,17 165:4 

188:9 

benefits 28:21 47:20 

72:6 138:18 146:22 

160:18 

benefitting 161:7 

best 5:13 36:19 69:19 

136:18 174:3 175:1 

188:13 

Betsy 70:20 71:2 78:3 

81:16 86:5,14 

better 1:15 6:14 10:15 

10:18 22:13 28:3 

31:17 44:1 48:19 51:6 

51:22 66:5 77:21 

135:22 141:12 157:21 

162:10 164:15 173:6 

176:5,6 178:20 

bible 87:6 

big 7:3 12:15 57:12 

64:5 82:9,9 86:16 

96:14 98:17,18 

117:18 124:20 151:7 

159:11,19 167:4 

170:11 173:19 180:9 

181:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
195 

bigger 114:13 

biggest 159:13 

bilateral 93:7 136:13 

147:5 

bilaterally 168:22 169:4 

Bill 9:3 

billion 104:9,12,15 

179:21 

binary 62:7 124:4 

BIS 13:2 140:20 144:11 

bit 6:10 16:3 21:9 43:13 

43:20 44:5 46:12 

51:17 62:13,13 64:13 

69:8,16 83:12 87:22 

89:1 94:19 105:2,4 

117:14 118:19 134:9 

139:18 170:9,10 

172:11 182:4 190:12 

Bitcoin 182:5 

black 39:7 

blast 85:22 

blatantly 145:2 

Blend 2:11 

blocker 122:11,14 

board 1:10,16 2:4 3:5 

7:17 8:9,11 12:17 

13:11,13 14:13 17:7 

17:12,16,20,22 18:7,8 

34:14 46:21 50:1 56:9 

67:6,6 115:4 136:11 

159:20 172:15 182:2 

182:12 

boarder 32:8 

boards 44:19 55:15 

bodies 133:6 136:10 

Bodson 9:8 

body 94:10 119:22 

bond 180:1 

bonds 157:13,14 160:7 

160:17,22,22 163:15 

179:19 

book 15:6 57:22 87:5 

132:13 150:10 151:17 

152:10 153:11,18 

154:13 167:8 171:2 

books 131:20 149:11 

152:8 155:3 161:22 

175:6 

border 21:6 26:22 32:2 

60:13 75:15 80:20 

114:20,21 129:2 

137:7 141:20 186:16 

188:17 

borrowing 103:19 

boundary 68:2 

box 107:12 

boy 142:11 

branch 3:17 29:4,4 30:3 

31:20 71:3 

branches 29:1,5 30:9 

31:2,8 32:18 

break 38:11 105:2 

123:3,11 125:13 

129:14 

breaking 129:3 

bridge 22:5 25:20 81:1 

81:2,5 103:3,4 108:9 

108:17,20 110:4,14 

113:10 115:22 124:14 

124:18,20,21 125:6 

125:11,12,20 126:5 

126:13 185:10 

brief 21:21 129:14 

briefing 41:11 

briefly 23:17 28:13 

145:7 

bright 127:22 

bring 25:21 39:13 46:16 

58:21 183:13 187:21 

bringing 32:21 

brings 21:14 

broad 68:1 71:13 

124:11 

broadened 25:6 

broader 141:13 185:16 

broadly 42:18 53:12,18 

broken 9:12 

broker 128:15 

broker- 189:8 

broker-dealers 21:9 

brokered 119:21 

Brookings 2:7 

Brothers 166:13,14 

brought 20:10,16 28:15 

127:9 172:15 

buckets 31:14 40:6 

120:20 121:4 127:16 

build 23:4,8 26:14 27:3 

29:20 32:11 38:4 

63:13 72:12 74:17 

76:14 88:2,18 178:1 

184:19,22 188:16 

building 49:20 50:11 

72:11 74:1,1 126:12 

184:5 

builds 96:18 134:3 

buildup 74:13 

built 73:20 186:20 

188:8 

built- 126:8 

built-in 113:3,12 

bulk 64:10 

bunch 85:16,17 

burden 107:4 

Bureau 3:3 13:14 

burn 60:4 

business 9:6 17:13 

29:1,5 30:12 33:8 

105:21 110:12 125:14 

134:15 153:13 161:9 

166:3 

businesses 105:7 

147:20 

busy 76:3 

buy 97:7 177:20 

buyer 120:18 149:1 

buyers 114:21 115:1 

buying 98:7 

C

C 1:13 122:20 

C-O-N-T-E-N-T-S 4:8 

calculate 111:15 

calculated 48:15 

calculations 45:20 

calendar 5:7 

calibrated 121:18 

call 59:5 74:12 87:14 

89:6 100:20 156:15 

159:7 163:1 171:3 

172:13,22 174:6 

175:20,21 181:5 

called 78:15 156:8 

170:8 181:4 

calling 169:10 170:9 

189:9 

calls 133:9 149:21 

157:7,17,19,22 158:3 

158:22 159:1,6,11 

163:21 171:3 190:1 

capabilities 21:8 34:4,8 

45:20 49:21 52:20 

58:17 59:5 72:2 73:10 

73:12,13 126:12 

128:7 134:2,12 135:6 

187:5 

capability 11:5 73:15 

184:9 

capacities 12:10 

capacity 8:15 11:20 

107:17 115:19 142:3 

159:2 

capital 46:10 48:2,4 

80:16 97:5,18 107:17 

114:17 117:2 119:2 

122:10 149:9,10 

151:5,5,7,12 161:3 

162:16 175:19 

care 17:1 65:1 

career 72:13 

careful 61:8 84:12 

85:21 118:1,15 120:2 

carefully 119:14 160:13 

carry 6:3 152:6,12 

174:16 190:13 

carrying 107:15 

case 60:19 76:7,7,8 

88:22 101:17 112:18 

145:3 154:11 155:17 

162:18 165:8 166:2 

cases 152:15 168:10 

cash 82:16 133:9 

149:21 157:7,17,19 

157:22 158:3,22 

159:1,6,7,10 163:1,21 

168:17 169:15 170:15 

172:13,22 174:6 

175:20,21 189:22 

categories 105:16 

category 106:6 126:20 

cause 63:3 112:9 170:5 

caused 25:8 150:22 

causes 159:8 

cautious 187:3 

caveat 159:11 187:2 

CCAR 97:2 114:17 

CCP 4:18 7:13 12:13 

49:9 130:3,14 133:4 

135:8,20 137:18 

139:5 142:2,4 144:6 

145:8,16 147:10,16 

147:19 150:17 151:4 

151:5,10,12,17 152:5 

152:13,19 153:8,13 

153:18 154:5 155:2 

155:12,15 156:1,2,5 

157:1,12,20 159:20 

160:5,21 161:3,18,21 

162:6,14 163:5,9,11 

163:19 165:11 166:3 

166:4,5 168:10 169:1 

169:5,18 171:2,15 

172:16 175:3,21 

180:3 185:5 189:11 

189:12,19 190:2,3,7 

191:6 

CCP's 132:13 145:18 

158:11 175:18 

CCPs 12:9 13:5 23:19 

37:2 130:7 131:18 

133:14 135:5 136:22 

137:16 139:18 140:2 

143:5,13 144:15,17 

145:8 146:2,9,15,18 

148:4 150:6 151:2,7 

152:17 155:17,20 

158:16 164:9,15 

166:11 172:18 175:15 

176:6,13,14,18 177:1 

177:5 179:3,11 180:4 

180:18 181:10,20 

185:19 187:11,18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
196 

188:8 189:6 191:12 

center 2:2 55:14 86:4 

central 6:4 7:9 12:3,4 

141:3 145:18 147:3 

148:20 

centralization 146:22 

centralized 189:22 

centrally 146:6 

CEO 2:18 7:5 9:7,8 

certain 35:20 53:19 

66:22 79:2 105:22 

111:17 116:12 133:7 

181:17 

certainly 72:6,22 73:2 

73:15 74:22 77:4 84:4 

103:16 110:18 125:13 

166:15 172:3 178:22 

179:12 

cetera 52:20 97:19,22 

114:17 127:20 128:17 

182:8 

CFPB 14:19 

CFTC 134:20 139:7,20 

142:7 144:6 168:16 

188:14 

chain 106:7 

chair 3:5 8:8,10,18,21 

9:3 61:13 130:10 

138:21 144:11 

chairing 13:1 140:19 

chairman 1:11,12,17,18 

2:1,4,18,19 3:2,11 

4:11,21 5:3 7:22 8:3 

13:22 14:12 15:17 

16:6,11 20:8 21:15 

22:20 35:5 53:22 

56:22 57:1 58:7 59:9 

65:8 66:6,10 70:3 

71:6 127:5 129:13 

130:5 137:3 138:21 

140:8,11 142:9,19 

158:5 164:19 165:15 

167:15 172:7 173:10 

177:20 183:5,8,20 

184:10 185:15 191:19 

191:22 

chairman's 137:5 

chairs 137:4 138:5 

challenge 6:2 11:2,3,11 

23:18 35:18 36:1 51:4 

55:7 56:1 68:18,20 

106:8 113:3,12 

121:10 124:16 131:16 

133:11 134:16 165:18 

166:22 

challenges 4:18 12:2 

19:18 21:7,14 22:3,11 

22:18 23:13 24:4 

25:15 36:20 69:3 

96:14 100:18 101:9 

102:3 106:10,15 

107:4,7,12,14 108:21 

109:6,7,19 110:7,9 

111:1 113:19 114:11 

120:4,7 130:3,4,17,21 

131:3,13 134:5 135:7 

136:17 139:13 140:5 

184:13 185:1 

challenging 14:16 

15:14 51:1 

chance 44:3 143:1 

chances 121:3 

change 59:12 69:13 

85:18 

changed 16:3 44:17,21 

53:7 91:5 

changes 25:11 135:6 

186:9 

changing 46:11 

CHAPMAN 1:13 

Chapter 15:22 

characteristics 26:9 

charge 167:7 176:20 

charted 103:7 

charter 47:12 

chartering 49:1 

Chase 2:15 

cheapest 179:14 

cheaply 177:10 

check 142:17 

checked 5:7 

Chief 2:8,9,12,14,16 

child 43:10,11 

chime 39:11 

chimney 60:3 

choice 46:5 175:12 

choices 138:19 152:5 

172:19 

choke 64:10 

Chopra 3:3 13:15 14:3 

14:6 66:17 

circle 50:6 

circumstance 110:8 

circumstances 68:11 

79:18 162:3 163:6 

165:19 

CISR 3:13 16:16 21:22 

22:8 24:10,15 26:1,8 

28:12,15,20,22 31:11 

32:17 34:18 38:10,15 

39:11 54:13 

Citigroup 2:19 

claim 85:2 

claimant 90:17 

claimants 81:8,13 

claims 81:9,14 82:2 

clarify 93:12 

Clark 1:15 6:13 14:2 

50:13 51:11 53:2 

class 102:13 103:1 

108:7 125:1 

classes 56:13 

clawed 82:4 

Clayton 1:17 7:21 62:10 

63:18 93:20 96:19 

116:8 189:3 

clean 21:3 

cleaner 115:12 

clear 12:10 52:7,9 

119:7 156:20 161:6,9 

166:20 177:21 

cleared 146:6,9 162:2 

clearing 7:6,9 12:8 

131:10 147:3 149:12 

150:9,14 151:14 

152:3,14 158:1,17,18 

158:20 159:3,9,13,15 

159:19 162:6 164:5 

165:20 170:7 172:22 

174:6,7 175:10,10 

176:1,22 177:7,9,10 

177:12 179:10,14 

180:2,15,17,20,22 

181:17,22 182:17 

190:6 

clearinghouse 166:15 

179:9,20 

clearly 24:20 53:14 

120:16 141:8 152:1 

172:14 180:21 

clock 70:5 

close 10:1 48:6 166:4 

closed 166:16 190:12 

closely 26:18 34:20 

36:10 45:4 58:19 

124:19 141:20 166:3 

closer 92:3 107:9 123:9 

Closing 4:20 

cloud 61:16 

CME 182:6 

CMG 32:21 139:20 

CMGs 31:22 32:16 

37:20 75:16,16 

co-chairing 168:15 

co-chairs 137:6 

Co-Director 2:2 

co-head 2:21 8:1 

CoCo 98:12 

COHEN 1:18 65:4 

coherent 186:1 187:13 

COHN 1:19 61:1 84:18 

collaborate 58:19 

188:14 

collaborated 141:20 

collaboration 10:2 

28:18 64:20 

collaborative 27:14 

31:12 

collaboratively 39:20 

collateral 49:7 172:20 

178:20 181:19 

colleague 78:2 

collect 67:1 

collective 69:20 

collectively 112:12 

118:14 178:18 

colleges 27:1,6 42:6 

color 90:6 

combat 56:8 

combination 43:5 

combine 107:3 110:17 

combined 135:1 

come 48:4 56:2 57:10 

57:11 58:5 60:9 63:6 

63:6 66:4 90:18 98:13 

127:3 129:16 138:19 

139:5 164:7 170:3 

175:7 180:6 181:10 

comes 29:18 56:8 78:1 

102:22 120:11 150:6 

151:22 157:9 161:19 

176:13 180:10 

comfort 92:4 

comforting 123:11 

coming 46:9 51:9 55:1 

91:19 97:1,2,4 126:18 

168:12 182:12 

comment 11:17 18:9 

68:17 88:19 89:15,17 

89:18 92:18 98:4 

116:17 121:6 127:8 

185:16 

commenting 88:9 

comments 13:16 18:11 

19:14 35:6 37:5 64:4 

72:19 88:3 91:10 97:1 

98:5 127:3 

commercial 179:8 

Commission 1:17 8:1 

Commissions 137:14 

committed 126:19 

committee 1:3,9 5:8,10 

5:16 6:9 7:3 8:20 9:3 

9:10 13:1 17:9 19:15 

20:9,11,16 21:5 23:11 

23:18,22 28:6 31:6 

40:4 44:19 54:12 99:6 

106:18 137:12,15 

140:19 141:15 144:11 

144:13 165:1 183:13 

committee's 19:19 

committees 55:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
197 

63:10 181:14 

committing 138:5 

commodity 146:15 

168:18 

common 35:18 97:9 

130:21 

communicate 81:8 

83:13 92:7 

communicating 10:14 

communication 28:17 

33:5 90:17,22 91:4,5 

communications 77:22 

91:15,20 

communities 101:5 

community 8:15 107:2 

companies 21:4 35:7 

35:12,15,22 36:3 

37:11 68:4 111:6 

185:19 186:7 

company 34:17 36:9,22 

84:22 99:9 103:8 

104:20 108:16 185:21 

187:11 

compared 100:22 

compel 67:1 

compensated 81:14 

compensation 82:2,4 

competition 155:19 

competitiveness

121:15 

complement 31:10 

complemented 186:5 

complete 179:3 

completed 15:22 

completely 84:18 

116:20 

complex 3:7,8,10,15,16 

16:9,15 20:4 24:13,19 

28:10 30:6 33:15 

58:19 108:16 109:12 

110:12 131:5 147:4 

148:10 158:4 161:19 

complexities 15:19 

complexity 15:15 25:5 

26:10 105:4 109:22 

118:3 129:1 135:8 

compliance 14:4 

complicated 164:21 

components 117:12 

118:11 

composition 138:11 

compressed 100:4 

107:21 115:14 116:1 

Comptroller 3:4 

concentration 146:18 

147:9,17,19 

concern 14:13 15:7 

concerned 66:13 84:21 

114:6 

concerning 18:4 

concerns 38:5 42:16 

82:16 

conclusion 17:22 

condition 33:14 

conduct 17:13 110:22 

138:6 

conducted 34:15 102:1 

conducting 104:22 

confidence 23:1,5,9 

71:12 76:6,10 77:22 

78:15 79:15 80:8 81:5 

82:7,11 85:5,7 96:18 

confident 90:20 

confirms 99:18 

conflicted 94:19 

confusion 52:3 

Congress 20:2 

connects 139:4 

Conneely 3:8 16:8,11 

16:13 19:2 25:20 28:1 

40:13 42:19 45:12 

47:10 49:11 52:9 

62:19 67:20 70:13 

99:16 129:21 

consent 67:8 

consequence 12:5 

141:9 146:20 

consequences 85:4,22 

132:17 

conservatorship

101:17 

consider 138:3 186:20 

considerable 35:2 

consideration 17:21 

23:11,22 

considerations 106:19 

153:21 160:12 

considered 45:6 133:8 

considering 79:20 

106:16 138:16 

consistency 27:13 97:8 

consistent 76:12 97:3 

147:1 

consolidate 26:1 

constant 44:10 

constantly 63:10 

constituencies 92:2 

constitute 17:15 

constraints 168:4 

consultation 67:9 

consumer 3:3 13:13 

14:21 

contact 37:19 

contained 69:14 

contemplate 64:7 126:1 

contemplated 108:13 

contemplating 120:17 

contest 179:11 

context 101:7 124:6 

132:16 133:4 140:13 

contingency 121:22 

contingent 119:13 

122:9 

continue 12:18 19:18 

50:1 70:9 76:16 77:14 

117:7 132:22 137:2 

160:4 162:6 175:11 

continued 23:21 137:8 

continuing 64:14 142:2 

continuity 106:7,10 

108:22 109:4 127:11 

continuum 30:17 

contract 190:1 

contracting 80:2 

contracts 59:3 108:20 

146:9,17 147:5 149:1 

149:7,8 150:3,8,15 

152:1 166:20 

contrast 133:16 184:1 

contribute 149:19 

contributing 159:10 

control 113:15 152:19 

165:12 167:8 

controlled 177:8 

controller 13:12 

convened 1:9 20:9 

conversation 13:7 

70:11 181:8 

conversations 40:7 

46:16 68:12 189:5 

conveyed 78:3 

cooperation 28:18 32:2 

32:7 60:7 166:4 

186:17 

coordinate 75:5 80:20 

112:12 

coordinating 37:7 

coordination 22:2 

25:15 26:22 27:12 

30:1 31:20 32:1,17 

33:5 50:14,16 74:22 

cope 163:3 

core 20:18 

corner 43:21 

corporation 1:1,10,13 

2:19 3:2 7:6 34:14 

corporation's 20:12 

correct 65:16 

cost 74:11 103:10 

108:10 110:15 114:14 

114:15 121:22 122:1 

125:2 161:5 163:17 

174:16 176:20 179:15 

179:16,19 180:1 

costly 101:3,16 102:19 

102:20 124:17 

costs 103:2 108:5 

115:9 117:9 119:12 

138:18 160:17,19 

161:4,8 174:8,10 

180:6 

Could've 123:12 

Council 1:20 15:11 

counsel 1:13 3:9,13,17 

16:21 70:21 

count 88:8 

counter 12:3,4 

counter- 79:5 

counter-parties 7:9 

141:4 149:4 150:16 

counter-party 145:21 

147:14 148:13,17 

189:20 

counterfactual 154:11 

counterpart 148:20 

188:12 

counterparts 134:20 

135:11 139:2 147:3 

countries 42:9 

country 60:11 

couple 14:11 15:7 17:1 

19:2 21:17 24:10 

32:18 99:9 105:10 

116:18 168:21 177:17 

coupon 161:2 

course 15:16,19 51:15 

66:17 72:13 75:14 

83:6 103:12 106:2 

109:16 110:14 111:22 

137:10 146:11 150:13 

153:11,21 154:7 

161:4,10 163:6,18 

164:8 174:11,19 

179:15,19 

coverage 191:14 

covered 145:1 

covers 102:16 

COVID 98:7 

CPMI 130:9 137:13 

138:5 

CPMI-IOSCO 164:8 

180:12 

crack 184:11 

cramped 6:10 

create 15:15 74:18,19 

117:10 118:2 182:9 

created 41:14 117:10 

127:17 

creates 65:12 

creating 51:13 116:22 

171:19 

creation 25:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
198 

creative 69:17 101:14 

creatures 61:2 

credential 50:3 

credibility 5:21 23:9 

50:22 51:2 

credible 45:9 53:17 

72:3 186:21 

credibly 15:21 

credit 2:1 8:3 38:18,20 

38:20 99:1,11 145:21 

146:5 147:14 148:14 

148:17 155:3 163:7 

creditor 154:9 171:1,7 

171:10,21 175:4 

creditors 81:7 82:3 

102:14 126:3 

crime 6:18 14:1 

crisis 12:6,7 20:2 22:2 

27:2,6,19 30:17 31:21 

32:8 42:6 55:1 57:21 

61:8,14 63:4 73:1,3 

83:14,19 98:7 100:13 

101:12 107:8 137:7 

139:17 141:7 146:1,7 

146:10,21 160:7 

163:20 

critical 30:9,13,13,18 

33:9,10 34:3 75:1 

76:6 95:22 105:9 

117:6 131:6,10 133:1 

185:8,10 

criticism 52:4 

Cromwell 1:18 

cross 21:6 25:21 26:14 

26:22 32:1,8 60:13 

75:15 80:20 114:20 

114:21 127:19 129:2 

137:7 141:20 159:8 

186:16 188:17 

crowd 85:12 

crypto 87:13 

crystal 119:7 

culpable 81:21 

cultural 42:1 

Cunliffe 3:6 12:21 24:2 

130:8 140:15 142:16 

142:21 144:10 145:5 

164:14 165:17 168:14 

173:11,14,18 177:14 

179:2,7 182:13 

183:15 

curious 42:17 55:12 

62:14 112:7,11 178:5 

Currency 3:4 

current 142:2 154:14 

175:5 

currently 18:9 137:3 

138:20 

curve 57:2 

cushion 119:1 

customers 79:5 

cut 123:10 

cutting 157:18 

cyber 33:2,7 61:15 

151:1 163:19 172:21 

174:13 

cycle 57:16,16 178:21 

cyclical 132:9 

D

D 2:1 

daily 37:17 40:8 48:15 

55:17 

damaging 151:20 

dance 39:1 

Darryl 98:16 

Dartmouth 9:6 

dash 168:17 169:15 

170:15 

data 29:19 35:20 36:16 

46:9 65:7 66:3,4,18 

67:1 106:13 111:19 

120:3 185:2 

daunting 110:8 

David 3:17 16:21 

Davis 2:22 8:2 

day 5:18 89:3 111:6,7 

130:2 180:5 

day-to-day 55:9 

days 91:18 99:5 

DC 1:10 

de-GSIB'ed 127:15 

deal 12:12 38:19 39:5 

60:12 61:18 68:10 

91:21 92:1,6 123:17 

145:7 161:19 163:14 

163:22 164:10,11,16 

165:13 184:9 186:2 

dealer 189:9 

dealers 128:15 

dealing 84:8 118:20 

121:22 122:18 

deals 72:17 

dealt 42:17 

dear 13:20 

debate 43:22 158:4 

debated 133:5 

debt 11:18 21:2,3 95:16 

95:18 99:7 101:20 

108:3,11 119:8,10 

125:22 127:1 178:10 

190:9 

decade 47:21 98:12 

December 5:11 182:5 

decent 99:3 

decide 80:11,15 

decision 47:14 113:15 

147:7 

decisions 68:6 80:10 

111:20 182:15 

deck 62:13,16,20,21,22 

declared 15:18 

dedicated 58:15 111:4 

133:3 

deep 44:4 60:14 119:17 

119:18 

deeper 171:17 

deeply 137:2 

default 31:15 40:2 

148:18 149:19 150:6 

150:22 151:4,8,17 

155:6,17 159:7,8 

160:5,9,22 163:3 

166:12,14 169:22 

170:5 174:16 177:3 

182:7 187:19 

defaulted 165:20 

defaulter 170:1 

defaulting 149:17 

152:16 

defaults 131:21 149:5 

166:10 

define 7:10 8:5 

definitely 6:18 91:3 

129:7 

degree 26:10 105:13 

109:5 

delicate 86:12 

delivery 64:11 

demand 91:11 176:11 

demutualized 178:14 

191:7 

deneutralize 172:18 

department 38:18 

depend 109:22 115:20 

162:18 180:19 

depending 150:17 

157:17 

depends 124:4 

depleted 132:1 

deposit 1:1,10,12 3:2 

9:20 75:8 102:16,20 

103:7,9 109:9,12,17 

111:15 190:20 

depositor 102:13 103:1 

108:7 125:1 

depositors 102:15,17 

103:3 114:3,4,7 118:9 

depository 7:5 102:12 

103:6 

deposits 23:2 43:2 

91:19 119:19,21 

121:9 124:21,22 

125:3 

deputy 1:15 3:6,9,10,11 

3:12,14,17 6:16 12:21 

16:19,20 28:9 70:19 

130:9 137:5 140:17 

143:12,20 

derivatives 12:8 111:20 

146:3,5 

describe 131:3 

described 73:12 136:19 

155:4 

design 95:19 148:4 

designate 66:3 

designated 15:11 66:1 

105:9 127:14 

desire 89:9 

destabilizing 118:4 

destroyed 108:8 125:4 

detail 30:2 54:7 89:7 

131:15 

detailed 54:3 89:18 

details 74:1 

deteriorating 165:13 

determination 81:9 

135:19 

determine 17:13 52:13 

138:9 156:19 

determined 6:2 

determining 30:18 

develop 20:12 31:17 

136:2,15 

developed 44:11 77:11 

134:13 

developing 11:4 29:16 

29:17 31:1 

development 20:21 

39:18 45:17 

developments 21:10 

83:22 

devoted 11:12 37:1 

dialogue 32:9 44:10 

Dick 127:8 165:2 

Dick's 91:10 

DIF 103:2,16,22 122:1 

differ 80:21 

differed 99:9 

difference 42:1 45:14 

89:11 105:12 124:20 

174:22 180:21 

differences 148:6 165:7 

different 27:8 32:12 

33:9 45:11 48:20 57:6 

72:16 75:7 77:16 

81:11 86:3,14 87:20 

92:1,8 99:11,12 

116:15 121:16,19 

123:15 144:19 145:8 

148:8 161:10 162:14 

168:2,5 179:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
199 

182:15,16 185:5,13 

187:8 

differently 117:15 

118:19 

difficult 35:15 36:20 

38:22 41:16 67:20,21 

68:15 87:21 106:3 

107:21 110:16 114:22 

115:7,16 122:5 135:9 

174:12 

difficulty 168:20 

dig 171:17 

digital 87:13 

diligence 102:1 115:8 

Dime 116:14 

dimensions 78:18 

Dimon 115:3 

direct 36:6 52:22 

134:17 

direction 18:12 55:2 

directions 22:8 

directly 135:3 136:11 

139:2 

director 1:15,19 3:2,3,8 

3:9,10,12,14 6:16 

13:12,17 14:3,6,19 

16:8,14,20 28:9 54:11 

65:21 66:17 68:16 

70:19 95:13 130:6 

Directors 16:20 17:7,12 

18:7 

disagreements 152:13 

disappear 152:3 

disappears 150:9 

disciplinary 26:14 

disciplines 28:22 32:19 

disclose 84:2 

disclosure 42:16 83:10 

disconnect 173:4 

discontinuities 127:18 

discover 39:1 

discovered 41:14 

discuss 22:15,21 28:14 

37:21 101:10 130:15 

discussed 14:12 20:22 

21:6 23:17 35:18 

131:8 157:11 

discussing 39:22 

100:10 

discussion 7:18 12:19 

16:5 18:20 19:9 37:3 

43:14,18 44:12 51:12 

53:7 99:17 100:21 

102:7 104:8 113:2 

120:13 184:2 192:2 

discussions 17:17 31:3 

31:4 38:1,3 40:4 41:9 

50:10 53:18 145:1 

disincentives 161:9 

disinformation 91:16 

91:22 93:11 

disruption 101:4 

disruptive 124:7 

distance 161:12 

distinct 11:1 

distinguished 1:15 

6:14 7:20 

distinguishing 106:22 

distribution 123:22 

160:15 

District 1:14,21 

disturbing 172:1 

dive 119:17,18 

diversified 105:7 

dives 44:4 60:14 

dividend 97:18 

dividends 97:7 

dividing 127:9 

division 3:7,8,10,14,15 

3:16 16:8,14 24:11 

26:15 28:10,16,22 

58:15 

divisions 26:19 

documents 54:6 136:3 

Dodd- 10:8 

Dodd-Frank 20:7 25:7 

30:8 54:2 81:10 82:2 

185:22 

doing 6:6 23:13 41:1 

47:5,16 57:22 81:21 

85:1 89:5 93:9 98:1 

99:7 112:19 119:15 

119:17 120:1 126:14 

136:6 145:15 168:15 

172:22 174:20 191:17 

dollar 104:12,15 

dollars 104:9 

domain 80:7 

domestic 14:15 87:15 

domestically 7:15 

36:11 130:17 186:11 

Don 95:14 182:3 

Don's 98:6 

DONALD 2:4 

Donaldson 9:3 

doubling 44:6 

doubters 83:6 

DOUGLAS 2:16 

downturn 101:7 112:21 

drafters 34:10 

DRAIN 1:20 

draw 58:18 59:10 

117:21 

drawn 68:2 

drill 69:4 

drills 60:20 

drive 177:22 

driven 25:2 117:6 120:3 

drove 118:22 

dry 167:1 

DSIBs 100:20 

DTC 2:10 

DTCC 2:9 7:6 9:9 

due 102:1 103:16 

110:18 115:7 

Duffy 98:17 

dwindled 83:19 

dynamic 53:6 68:5 

94:11 101:14 135:1 

E

E 2:21 

earlier 55:15 68:21 

81:16 91:10 128:19 

133:12 139:19 152:2 

152:21 158:13 184:2 

185:17 187:15 

early 13:14 26:8 39:3 

72:16 91:18 95:2 99:5 

120:11 145:14 

easier 16:16 123:16 

easy 42:13 55:18 93:16 

142:11 166:6 176:4 

ECB 43:16 

echo 14:8,11 

economic 1:19,20 2:6 

59:12 101:7 180:4 

economics 122:6 

economists 26:16 

economy 64:7 65:2 

EDT 1:10 

effect 112:16 163:21 

167:10 175:8 

effective 10:4 51:21 

64:6 71:17 92:22 

145:7 147:16 152:3 

158:1 170:15 

effectively 149:11 

150:9 151:18 153:2 

159:7 161:15 

effectiveness 33:1 

effects 114:6 131:11 

147:10,17 

effort 138:9 

efforts 9:15 20:12 23:8 

28:3 36:19 131:2 

134:14 

eight 44:11 

Eighty-five 146:8 

either 18:20 30:7 89:8 

155:7 161:14,22 

171:16 

elaborate 21:17 84:12 

elaborated 54:5 

elevate 183:10 

eliminate 52:2 97:22 

ELIZABETH 3:9 

Elke 3:5 8:7,10,12,17 

42:12 141:19 

Elke's 186:18 

embedded 118:16 

embodying 142:10 

emerge 64:22 

emerging 29:11 

employees 108:19 

enable 160:4 162:6 

enabling 146:17 

enact 190:15 

encourage 50:1 57:15 

engage 17:16 26:22 

136:11 141:16 

engaged 70:4 137:2 

engagement 21:6 35:17 

75:15,17 79:1 112:3 

134:2,18 139:5,13 

173:1 

engaging 48:8 

engender 70:11 

engineered 123:13 

England 3:6 12:22 

139:7 140:18 141:19 

166:7 183:1 184:1 

enhance 6:22 20:12 

126:14 135:4 186:9 

enhanced 12:12 32:17 

33:1 119:12 

enhances 71:11 

enhancing 10:21 

enormous 5:17 6:7 

11:10 14:21 15:15 

186:15 

ensure 31:8 32:13 

148:22 152:22 155:3 

156:21 157:5 

ensuring 157:2 

entice 7:2 

entities 30:13 33:9 

42:15 43:4 189:7 

entitled 104:2 

entity 103:7 109:8,20 

entry 20:22 71:14 72:2 

77:9 108:12,15 113:7 

135:20 

envelope 160:21 

envied 89:12 142:5 

environment 58:10 

59:12 63:15 68:5 

69:12 119:11 

equal 160:22 161:3 

equaling 117:17 

equally 58:4 162:13 

equity 121:8 150:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
200 

155:16 156:7 163:8,9 

168:9 170:20 171:5,6 

171:14,20 175:3,7 

equivalent 190:19 

Ervin 2:1 8:3 38:16 56:5 

91:9 98:4,10 114:10 

121:11 127:7 167:16 

167:17 

escalate 114:13 

escalation 31:11 39:19 

46:22 

especially 56:1 101:6 

107:20 

essence 23:6 

essential 147:15 148:6 

167:12 

essentially 148:13 

establish 10:15 

established 20:2 54:8 

establishing 11:18 

establishment 20:19 

et 52:20 97:19,22 

114:17 127:20 128:17 

182:8 

euro 151:8 

Europe 8:9,12 43:12 

98:11 121:12 170:13 

European 3:5 8:14 60:9 

60:17,20 

euros 183:3 

evaluate 15:20 

evaluated 31:13 

event 27:19 30:4 35:22 

46:20 47:6,8 58:10,22 

61:15,16 62:2,8 78:15 

110:5 112:9 132:11 

157:20 

events 59:17 61:18 

62:7,20,22 98:11 

168:2,11 

eventually 51:9 

everybody 5:4 23:1 

58:2 68:14 75:12 

93:11 107:6 122:2 

123:4,12 129:22 

everybody's 71:11 

evolution 25:2,22 49:5 

95:9,15 

evolved 12:12 

ex 75:7 92:8 98:22 

136:2 154:20 167:10 

exactly 69:9 72:20 

149:1 170:18 

exam 41:20 

examination 33:17 

41:13 115:5 

examinations 34:15 

examiner 41:18 

examiners 40:17 

example 33:4 40:20 

59:11 80:22 90:5 92:2 

95:10 121:12 146:4 

182:6 185:20 188:10 

excellent 40:14 98:1 

exceptionally 164:20 

excess 82:16 

Exchange 1:17 7:22 

exchanges 87:14 

exchanging 32:12 

exclusively 131:18 

excuse 18:1 

execute 83:1 100:4 

102:19 187:10 

executed 76:12 187:1 

executing 24:12 126:7 

execution 23:5 30:5 

48:15 73:22 78:8 

executive 2:8,9,12,17 

31:7 

exercise 54:15 55:8 

57:5 62:16 

exercises 56:18 58:1 

63:8 68:21 74:5,11 

exercising 76:9 

Exes 74:12 

exhaust 158:21 

exhausted 132:2 

152:20 153:2 161:17 

exist 15:12 30:12 32:1 

87:9,11 147:18 155:2 

187:5,7 190:22 

existing 135:11,16 

138:14 184:15,16 

exists 155:8 

exit 113:12 125:7,8,12 

125:18,21 126:1,9 

exits 125:18 

expand 28:3 64:18 

116:2 

expanded 12:9 146:13 

expect 88:22 

expectation 44:21,22 

74:19 95:20,21 

expectations 44:17 

73:5 76:11,13 77:21 

82:21 107:5,9 

expected 48:5 176:13 

expended 69:5 

expenses 103:11 

expensive 114:19 

experience 46:19 83:15 

93:3 96:5 

experiences 14:17,18 

22:11 63:19 

experiment 160:21 

expertise 20:10 27:17 

28:16,17,19 

experts 15:12 

expired 9:2 

explain 82:12 85:19 

100:11 

exponentially 45:3 

expose 176:10 

exposed 156:13 171:16 

177:2 

exposures 189:18,20 

190:3 

extend 174:2 

extended 123:18 126:5 

extension 45:14,21 

extent 34:15 37:14 49:4 

66:18 132:13 152:8 

179:3,7 

externalities 117:10 

118:21 

externality 121:21 

extra 114:11 122:16,20 

153:10 155:1,6 

157:12 160:16 

extraordinary 86:6 

190:14 

extremely 53:15,21 

68:22 124:17 

F

face 19:18 36:21 130:17 

131:16 148:13 160:11 

faced 22:3,12 52:4 

faces 13:18 

facilitate 11:20 32:1 

104:4 186:14 

facilitated 134:6 

facing 59:11,11 

fact 7:2 35:19 36:3 

110:12,17 177:2 

185:21 

factor 97:16 

facts 68:11 79:18 

fail 98:18 103:16 110:18 

113:17 118:12 132:5 

149:17 159:13,19 

failed 39:8 102:2 132:5 

160:3 

failing 105:20 107:7 

113:20 124:5 176:21 

fails 111:8 

failure 5:19 10:22 11:5 

11:9,21 12:13 14:15 

14:20 15:2 20:5 24:18 

25:16,18 30:4 35:13 

100:22 101:13,22 

107:9,21 110:10,11 

110:16 112:8,20 

145:8,22 147:9,17 

148:16 153:4,5 

158:16,19 160:1 

163:19 187:20 

fair 102:2 188:18 

fairly 67:2 186:20 

fairytale 16:1 

faith 85:5,7 

fall 38:21 39:6 

Falloon 3:9 70:20 71:1 

71:2 

familiar 13:18 190:17 

190:18 

fan 40:11 

Fannie 2:12 

fantastic 99:17 

far 40:5 43:11 45:7 

48:22 68:5 116:9 

121:1 153:6 160:14 

Farr 1:13 

fashion 67:2 

fast 63:6 165:21 

faster 69:8 91:14 

FBOs 106:9 

FDI 30:7 81:11 102:9 

FDIA 102:11 

FDIC 5:4,18 7:7,14 9:17 

11:14,15 12:15 14:17 

15:4 17:7,19 18:6,16 

18:21 20:3,8 21:11 

22:22 23:2,15 25:8,12 

35:19 36:6,13,17 

42:19 56:22 57:1,11 

67:6 79:13,17 80:10 

81:4 83:9 85:8 86:19 

87:5 95:2 97:2 100:15 

101:12 102:18 103:8 

107:10 108:6 109:21 

111:16 113:10,14 

119:5 126:4 130:20 

132:2,11 133:15 

134:9,17 135:2 136:9 

136:22 139:8 141:15 

142:6 144:8 183:12 

FDIC's 16:8 17:12 24:12 

28:10 97:13 131:8 

133:22 134:7 135:21 

feasible 125:11 

features 154:16 

February 139:11 

Fed 6:20 9:8 11:14,16 

14:2 15:4 26:21 47:13 

67:6 119:6 139:7 

142:6 188:13 

federal 1:1,10,12,16 2:5 

3:2 6:17 18:8 34:16 

45:2 49:17 50:17 77:8 

126:19 134:21 

feedback 14:10 20:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
201 

76:22 

feel 98:10 112:11 128:9 

163:12 

feels 92:12 

fellow 2:6 9:5 

Felton 3:9 16:20 47:18 

48:12 

FICC 2:10 

fifth 129:12 

fight 56:7 68:19 

figure 178:22 

figured 55:20 

file 126:22 133:14,17 

final 18:14 87:8 

finally 11:22 35:3 82:5 

150:2 162:10 

Finance 2:3 

financial 2:2,21 3:3,6 

3:12 5:20 7:1,17 8:2 

8:16 10:14 11:11 

12:17,22 13:13 14:16 

15:9,10 20:2,4,6 22:2 

23:15 24:14,17,19,22 

26:13 29:14 30:6 32:5 

33:15 35:12,13,15 

36:3,9,22 53:14 64:11 

65:2,7,9 66:22 75:1 

100:13 101:1,6,12 

107:8 122:20 130:9 

131:12 132:17,20 

136:10,21 137:5,21 

138:6 140:18 141:6 

143:12 144:5 145:19 

146:1,2,7,10,14,20 

147:12 150:13 151:22 

152:2 153:20 159:4 

159:21 182:4 185:18 

185:20 187:11 189:13 

189:16,17 

find 60:5,12 66:7 85:14 

89:15,16,18 104:18 

114:19 120:18 147:16 

159:14 

finding 50:22 149:7 

findings 45:10 

fine 89:16 

finish 191:18 

finishing 8:17 

fintech 87:12 

fire 46:7 60:1,2,20 

191:10 

firefighters 59:21 

firehouse 72:8 76:4 

firm 29:6,9 30:14,16,16 

32:6 33:8 36:18 39:22 

40:3 45:8,11 46:18 

47:3 66:18 74:14 79:2 

80:16 121:6 132:21 

134:1 186:14 187:20 

firm's 26:9 34:4 72:1 

134:4 

firms 29:11,12,19 31:13 

33:22 34:9,22 35:18 

36:15 37:22 38:2,3,5 

39:21 40:5 45:18 48:5 

50:19 51:3,6,22 52:22 

71:22 72:12 73:12 

85:16 109:5 134:12 

159:5 184:21 186:8 

187:17 

first 7:21 8:14 9:14 11:6 

16:19 17:2,5 20:9,17 

21:20 24:7 76:9 78:18 

83:8 86:4 88:4,7 91:4 

91:5 100:9 105:5,9 

107:12 111:4 120:10 

120:14 130:6 131:16 

133:13 139:3 142:17 

145:17 148:6 149:13 

149:15 151:16 152:17 

155:14 158:8 168:14 

170:22 173:8 179:2 

184:11 

Fisher 9:4 

five 58:1 129:15 139:9 

139:15 

fixed 52:22 

flesh 37:12 

flexibility 79:17 86:19 

flexibly 153:8 

flip 91:13,13 

flow 30:8 

flows 147:6 

flying 61:21 

flyover 102:8 

FMI 136:20 137:6 

focus 9:15 10:6,11 

12:16 24:21 25:1 

31:14 45:15 66:14 

96:2 113:13 124:13 

125:10 130:16 138:20 

focused 13:3 20:18 

29:10 30:20 35:6 

100:13 106:20 114:2 

137:15 141:1 

focuses 136:22 

focusing 29:7 50:18 

105:10 155:10 

folks 13:19 55:6 56:4 

58:12 69:21 86:11,22 

87:6 

follow 63:18 93:20 

150:10 165:2 190:5 

follow-ons 172:10 

followed 154:13 

following 17:22 20:1 

99:4 152:4 

footprint 12:9 14:21 

force 121:12 182:4 

forcing 118:21 

foreign 92:6 106:11 

114:18,19 136:12 

139:2 140:2 

forget 53:13 54:21 

173:14 

forgetting 61:4 

formal 19:7 32:10 37:10 

formally 44:3 

formation 38:10,15 

39:11 42:2 

formative 8:4 

formed 103:8 

former 1:12,14,15,17 

1:19 2:1,4,11,14,18 

2:19 6:16 7:22 8:3 9:2 

9:3,4,7 38:18 56:22 

formidable 23:14 

forms 137:9 154:8 

formulates 30:4 

forward 13:20 16:5 

19:19 22:7 24:1 28:12 

56:1 127:2 146:17 

168:13 

foster 27:14 

fostering 22:22 

foundation 73:7 93:14 

foundational 20:21 

49:8 

founding 8:10 

four 5:11,14 9:1 48:5 

69:14 158:16,19 

159:13,18 160:1 

fourth 29:4 

frame 115:8,15 

framework 43:13 54:3 

73:20 74:3 80:11 

90:13 91:7 137:20 

148:5 154:1 186:1,21 

187:13 188:7,10,19 

frameworks 136:2,17 

franchise 106:1 108:8 

120:12 125:4 

franchises 125:15 

frank 2:8 7:4 10:9 40:4 

Frankfurt 43:16 

frankly 50:20 51:2 52:6 

58:17 188:11 

fraud 150:22 163:19 

fresh 74:20 75:22 76:1 

Friday 83:2,3 

friends 69:21 

front 41:6 47:8 55:14 

69:17 130:5 136:6 

145:12 178:1,9 

fronts 135:14 

FSB 136:11 137:11,19 

138:5,13 170:21 

FSB's 136:20 137:4 

FSOC 65:22 66:2,2,14 

144:4 

FSP 162:8 

full 9:11 17:21 44:13 

72:15 85:5,7 88:18 

125:8 127:19,20 

160:8 161:1 

fullest 34:15 

fully 26:8 68:2 95:17 

102:4 109:2 

function 19:6 148:19 

functional 54:10 63:14 

functioning 50:16 

functions 10:1 25:10 

131:10 133:1 144:14 

fund 75:6,9 102:16,21 

103:9,10 149:19 

151:8 160:9 163:3 

174:4,16 182:7 186:5 

fundamental 10:3 

28:21 56:11 141:14 

funded 75:7 157:5 

181:5 

funding 82:5 

funds 157:15 

furniture 103:6 

further 19:19 55:5,5 

70:11 92:3 95:13 

110:21 136:7 138:6 

158:2 185:6 

future 70:2 98:22 128:4 

138:10 164:18 183:4 

futures 180:22 

G

G6 129:12 

gained 33:16 

Gallagher 1:14 

game 156:2,6,11,15 

171:13 172:5 

games 56:19 

gap 181:22 185:17 

gaping 65:17 

gaps 22:6 74:20 138:2 

138:4 

Gary 1:19 9:6 62:11 

63:19 67:18 68:17 

86:11 

gather 65:10 

general 3:9,17 17:16 

79:5 81:19 82:3 86:1 

90:12 92:18 165:22 

176:9 

generalized 104:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
202 

generally 18:11,18 

32:10 65:9 98:14 

104:7 107:12 121:12 

122:6 144:2 151:2,5 

169:4 

generation 56:15,16 

geopolitical 62:22 

Germany's 88:9 

getting 38:12 40:10 

41:6 51:21 83:21 84:9 

90:3 92:14 93:7 109:8 

116:22 170:17 

GFC 146:3 

gift 82:9,9 

gilts 168:21 

give 62:18 66:4 86:7 

89:7 90:6 92:4 128:7 

129:14 141:13 154:19 

155:1 156:14 162:10 

162:22 171:20 183:1 

184:11 

given 35:15 45:1 49:7 

53:7,13 107:14 

157:16 

gives 122:17 186:6 

giving 88:6 

glad 50:7,15 184:11 

global 2:17 7:1 101:12 

107:7 147:20 166:18 

177:22 183:18 186:2 

globally 23:20 63:9 

146:4 148:2 

goal 50:19 101:7 

gossip 88:11 

governance 47:22 48:7 

176:14,15 177:18 

government 12:21 

17:10 

governor 3:6 130:9 

140:17 143:12,20 

Governors 1:16 2:5 

18:8 

graciously 8:20 140:9 

grade 123:21 

grades 123:2 

greater 54:7 103:22 

151:10 161:3 

greatly 20:11 133:21 

green 19:4 

gritty 83:21 

gross 147:5 

ground 79:19 86:4 

group 42:2 44:9 70:4 

77:17 87:9 95:17 

115:1 137:4,6 138:22 

139:9 142:4 143:1 

155:9 158:6 168:16 

169:14 180:12 

groups 27:2,6 31:21 

42:6 57:22 58:20 59:2 

92:8 139:17,21 

grow 128:5 

grown 146:12 

grows 65:18 

growth 25:3 

Gruenberg 1:11 3:2 

4:11,21 5:3 13:22 

16:6,12 21:16 35:5 

53:22 58:7 59:9 66:6 

66:10 70:3 127:5 

129:13 137:3 140:11 

142:9,19 164:19 

165:15 167:15 172:7 

183:5,8,20 184:10 

185:15 191:19,22 

Gruenberg's 158:6 

GSIB 11:1,3,20 15:6 

22:16 48:13,21 

101:18 107:1 113:4,5 

122:22 128:20 141:21 

GSIBs 11:2,5 15:17 

23:10 89:15 100:22 

104:10 117:5 118:22 

121:13 123:3,11 

126:9 127:13 128:22 

132:18 133:16,19 

160:1,3 

guarantee 171:7,10 

guaranteed 120:10 

guarantees 82:15 

guess 42:12 51:8 83:12 

124:2 144:3 178:17 

181:9 

guest 8:7 12:19 24:2 

130:8 139:4 140:9,14 

guests 28:7 

guidance 51:13,16 52:1 

52:11,14 53:5,8,12,13 

53:19,20 54:6 76:18 

89:7 126:20 134:3 

137:19 138:1,4 

170:22 

guide 31:16 139:14 

H

H 1:18 

hair 191:10 

haircut 150:1 190:20 

haircuts 114:8 

haircutting 157:7 

190:16 

half 125:7 

hand 19:6 121:20 

152:14 154:6 156:1 

180:22 

handful 109:6 

handle 6:2 107:10 

109:10 

handled 101:13 

hands 62:13,15,20,21 

62:22 96:16 191:5 

happen 62:4 63:16 83:5 

95:3,12 154:12 175:6 

181:9 187:9 189:14 

happened 74:14 163:10 

happening 67:10 69:13 

81:4 165:19 

happens 61:15,16 

104:12,14 112:15 

114:22 171:17 

happy 18:22 145:6 

hard 5:10 68:11 72:19 

72:20 91:11 109:15 

178:4,18 

harder 38:8 108:9 125:2 

harm's 92:3 

hats 144:18 

hazards 118:15 

head 66:8 

heading 40:12 

headlines 97:11 

healthy 99:14 

hear 21:8 50:15 55:12 

79:8,22 82:19 106:17 

117:12 130:6 

heard 80:9 94:16 

hearing 24:1 

heart 13:20 22:14 

heartedly 88:18 

heartening 40:21 

heavily 61:5 

heavy 160:6 

hedges 150:16 

hedging 146:17 

heightened 63:7,17 

held 17:14 20:14 

114:16 166:15 

help 19:19 23:8 29:20 

34:8 36:12 51:6 57:14 

78:14 79:15 82:10 

93:9 125:17 128:8 

138:1 160:9 181:11 

helpful 66:20 80:7 82:7 

83:12 91:21 92:22 

125:16 140:12 182:11 

192:1 

helping 8:4 

helps 30:21 54:13 72:9 

136:15 

Herring 2:2 41:22 83:8 

83:18 99:4 122:15 

165:3,5 167:14 

Hi 50:12,13 78:3 

hierarchy 81:10 82:2 

high 18:19 74:6,7 107:4 

131:12 139:12 163:18 

higher 45:3 114:17 

highlight 133:12 139:1 

highlighted 184:13 

185:3 

highlights 130:19 

highly 62:6 101:3 

hinges 80:13 

history 57:11 

hit 40:11 

hoc 31:4 

hog 88:1 

hold 43:11 68:12 96:1,1 

149:9 

holding 21:3 35:7 86:22 

91:17,20 99:8 104:20 

163:17 

holds 43:10 105:3 

147:8 

hole 65:17 

home 32:3 80:21 

honest 40:3 180:8 

Honestly 67:22 

hoop 191:18 

hop 53:11 

hope 6:10 50:15 60:1 

84:15 98:15,21 

113:17 119:16 120:1 

145:12 162:22 164:17 

165:9 170:2 

hopefully 40:9 51:8 

hoping 27:10 66:16 

169:16 

horizon 64:6 

horizontally 29:12 

host 32:4 80:21 139:17 

hosted 140:3 

hot 119:19,21 

hour 85:18 

hours 111:16,17 

Hsu 3:4 13:12,17 54:11 

68:16 95:13 

huge 51:4 65:22 69:5 

85:20 94:22 115:9 

123:3 

hugely 111:5 

human 58:18 59:16 

I

idea 44:8 50:15 174:14 

ideally 83:2 169:19,20 

identify 22:12 64:1,21 

74:20 138:2 140:7 

144:20 

IDI 104:21 106:8 108:15 

126:15 

IDI- 111:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
203 

idiosyncratic 98:13 

99:2 112:20 163:18 

IDIs 101:13 104:8 

ignore 147:9 

II 10:8,13 20:6 22:16 

23:6 30:7 34:5 35:3 

36:8,21 67:5 70:17 

71:4,10,21 72:6 73:8 

73:14,16,21 77:14 

78:9,16 80:13 82:10 

83:1 86:10 88:21 

92:15 103:5 107:1 

117:5 118:22 130:7 

130:14 132:13 133:22 

135:18 186:4 187:19 

illustration 187:12,18 

immune 37:15 

impact 15:1,1 26:12 

33:9 86:14 96:13 

105:10 112:14 114:2 

169:1,2 

impacted 65:2 

impacting 114:4 

impacts 52:19 113:22 

132:9 137:17 

impaired 106:1 108:7 

impediments 36:9 

109:3 

imperative 152:18 

implement 20:13 52:10 

52:11 145:14 

implemented 54:1 

implementing 54:4,8 

implications 11:11 41:3 

41:19 50:4 53:1,19 

133:20 

importance 5:18 10:1 

important 14:15 15:9 

25:22 26:11 32:4 50:7 

57:19,20 58:5,8 60:5 

60:12 64:15 66:11 

67:3 74:4 75:4 82:12 

93:22 94:18,20 115:1 

122:16 128:6 129:8 

133:15 146:14 148:3 

150:15 154:8 163:12 

164:3 165:8 171:22 

183:10 191:17 

importantly 27:16 

102:13 103:14 111:3 

125:6 144:13 

imposes 17:11 

imposing 119:11 

imposition 119:8 

impossible 143:6 

impressive 37:6 

improve 27:12 72:1 

77:22 78:7,14 79:15 

80:8 100:16 135:15 

168:13 

improved 47:21 140:7 

improvement 48:1 

improvements 134:7 

improves 71:12 117:3 

impulse 177:8,10 

in-depth 34:21 

incentive 175:6,8 

incentives 155:15,18 

156:21 161:6 168:10 

170:19 171:12,19 

172:3 173:7 

incentivizing 157:1 

include 18:18 164:10 

includes 134:1 

including 20:19 81:8 

84:4 122:2 135:19 

138:17 139:10 184:14 

188:8 

inclusive 178:10 

incompletely 46:11 

incorporated 34:1 

incorporating 34:12 

increase 121:4 135:17 

155:12 157:4 

increased 108:5 119:12 

increasing 10:12 

increasingly 112:2 

incredibly 60:5,12 

93:22 

incremental 25:12 

incurred 125:1 

independent 40:17 

indicate 18:12 123:14 

individual 89:14 134:4 

181:3 184:21 

industrial 128:10 

industries 69:18 

industry 25:3 29:14 

64:9 93:15 177:22 

178:8 

IndyMac 101:17 

influence 53:3 177:4 

influences 61:5 

inform 30:21 

informal 37:10 

information 27:17 

28:19 29:18 30:8,20 

31:4 32:6,12 33:21,22 

34:2 36:7,18 42:16 

44:13 72:10 77:4 

84:10 88:6 92:10 93:7 

93:10 111:9 116:22 

117:19 135:21 184:20 

185:14 

informed 158:8 

informs 34:5 133:21 

134:22 

infrastructure 13:2 

136:21 137:12 140:20 

144:12 188:19 

infrastructures 183:18 

infrequent 54:18 

initial 167:21 168:3 

169:22 

initially 171:16,17 

input 6:7 19:19 21:10 

23:12 99:18 

insert 156:16 

insight 35:8,17 66:21 

67:10 69:22 181:21 

insights 49:17 131:4 

insolvency 151:13 

inspection 44:4 

inspired 42:1 

instability 65:2 

instance 52:17 76:17 

instances 63:1 152:16 

institute 2:20 51:15 

institution 2:7 3:7,8,10 

3:12,15,16 5:20 7:1 

8:13,14 9:18 14:16,20 

16:9,15 24:19 28:10 

29:2,6 30:7 40:19,22 

46:10 49:20 58:13,14 

58:20 60:13,18,19,20 

94:2 95:1 102:2 103:6 

108:20 110:3 111:1 

112:14,15 113:6 

114:15,16 115:13,15 

115:22 122:4 126:3 

185:10 189:16,17 

institutional 43:13 

85:13 89:9 

institutions 2:2,22 8:2 

8:16 11:10 15:9 20:5 

24:14 26:5 27:7 32:5 

33:16 35:10 37:8 

47:12 53:14 54:7 

57:18 60:8 62:9 65:8 

65:10 66:2 88:22 93:4 

93:8,15 94:18 97:14 

100:14 101:10 102:9 

102:12 104:1,6,17 

105:3,6,14,16,18 

106:5 107:19 108:2 

108:13,16 109:18 

111:5,18 112:4,10,21 

113:17,18 114:1 

116:4,7,19 117:9,22 

118:20 124:5 125:14 

126:2,6,21 130:19 

134:18 141:6 159:4 

185:7 189:13 

insurance 1:1,10,13 3:2 

9:21 25:10 43:2 75:9 

84:22 85:8 102:16,21 

103:9,13 111:15 

insure 27:17 43:1 

insured 102:12,16 

103:2 124:22 

integrate 9:15 21:22 

26:14 28:3 

integrated 26:2 39:4 

42:2 166:8 

integrating 40:8 49:5 

integration 4:13 10:2 

24:9 38:13 54:14 

55:11 

intend 71:10 

intensive 69:1 

intent 54:19 

interaction 37:8 38:4 

interactions 37:11 

interagency 50:16 

interconnectedness

30:15 

interdisciplinary 27:15 

interdivisional 31:6 

interest 9:14 51:15 

83:19 119:10 146:8 

151:9 167:20 169:17 

181:1 

interested 71:7 83:21 

106:17 112:6 

interesting 63:22 69:18 

83:22 95:8 122:8 

182:8 183:22 

internal 32:17 44:18 

47:21 48:2,7 74:5 

internalize 117:9 

121:21 168:6 

internalized 122:4 

internally 51:7 63:8 

international 7:7 13:6 

30:1 31:19 121:15 

128:16 136:6,9 

137:13 140:21 141:1 

144:15 147:21,22 

148:1 158:6,9,18 

183:17 187:6 188:16 

internationally 7:16 

12:11,16 13:4 36:12 

42:4 130:20 155:20 

169:17 186:12 188:4 

interoperability 50:2 

93:4 

intervene 165:11 

intervention 46:8 

intrigued 41:22 

introduce 7:4 8:6 22:21 

71:4 101:9 140:9 

introducing 6:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
204 

Introduction 4:10 

introductory 19:14 65:5 

invaluable 8:22 

invested 135:13 

investment 74:7 151:1 

173:21 

investments 172:19 

investors 95:16 98:3 

invitation 183:16 

invoking 67:4 

involve 108:18 

involved 67:7 68:7 

93:16 105:21 130:20 

135:18 136:9 166:3 

involvement 136:20 

176:11 

involves 112:2 

IOSCO 137:14 138:5 

144:14 168:15 

IPO 125:21 

isolation 189:12 

issue 8:5 10:19 12:1 

13:6 39:5 51:1 55:3 

58:9 121:15 132:6 

153:3 155:14 156:10 

170:16 180:9 181:2 

183:10,11 185:16 

issued 11:16 160:21 

issues 13:3,19 14:13 

17:20 20:15 21:11 

25:13 27:15 38:5 41:5 

41:13,20 45:8,11,15 

45:19 49:19,19 52:22 

55:1 68:15 70:8,12 

75:22 93:3 102:3 

104:15 140:22 141:5 

141:22 144:16,22 

160:10 162:9 177:11 

180:8 181:18 

issuing 157:12 

it'll 41:2 107:20 108:18 

109:22 

item 70:7 

ivory 55:7 

J

J 1:11 2:2,11 3:2,4,11 

4:11,21 

JAMES 3:10 

Jamie 115:3 116:14 

jargon 97:22 

Jay 1:17 7:21 56:20 

65:17 68:17 95:5 96:3 

Jenny 3:16 36:2 130:6 

130:11 140:12,12,19 

142:3 184:11 

jeopardizing 121:6 

Jim 3:10 16:20 22:9 

28:2,8 37:6 67:15 

Jim's 133:12 

job 38:8,12 40:9 72:15 

75:12 92:14 

Joe's 119:22 

John 2:18 3:8 16:7,10 

16:13 28:5,12 31:21 

35:5 37:5 38:17 41:11 

65:4 67:15 70:12 71:6 

75:2 100:2 130:12 

167:17 183:21 

join 7:2 8:20 42:9 

joined 6:13 7:19 13:11 

16:18 

joining 8:7 12:20 16:13 

28:8 142:15 

joint 11:16 137:11 

144:13 

jointly 139:20 

Jon 3:6 12:21 13:1,8 

24:2 130:8 140:14,16 

141:11,17,19 142:5,7 

142:13,14 164:19 

165:15 172:9 183:6,8 

Jon's 142:2 164:22 

165:4 186:18 

journey 87:11 

JPMorgan 2:15 102:1 

Judge 1:14,20 

judgments 84:6 

jump 19:8 47:18 169:11 

170:11 

jumped 117:16 

jumping 13:21 

June 20:8 

jurisdiction 172:4 

jurisdictional 161:11 

jurisdictions 12:18 

32:4 121:16 130:22 

133:7 136:18 138:2 

140:4 156:5 161:10 

170:12 182:16 186:17 

K

K”nig 8:7 

keep 43:19 55:13 56:12 

73:3 74:19 75:22,22 

164:5 165:12 191:17 

keeping 57:16 111:13 

keeps 76:3 

kept 150:18,19 

key 10:7,20 12:7 29:7 

30:10 33:6,10 36:6 

46:6 55:12 68:13 75:3 

76:10 80:9 130:17 

136:22 145:21 146:2 

153:3 155:14 156:17 

156:20 186:17 

keys 47:15 80:12 

kick 98:6 

kickoff 24:7 

kids 56:13 

kinds 87:20 

kit 138:15 

knew 88:15 189:8 

Knight 43:21 

knock 54:19 

knock-on 112:16 114:6 

knowing 30:10,20 

167:11 

knowledge 20:10 33:16 

69:21 74:19 161:21 

knows 23:1 75:12 

KOHN 2:4 48:10 94:14 

KTMNIG 3:5 43:8 59:19 

60:1 88:2,17 120:6 

L

L 2:16 

La 2:8 7:4 92:17 

lack 131:17 133:13 

135:2 

lagged 46:10 

laid 137:19 

language 48:14 60:15 

large 6:9 8:15 10:22 

11:7,9 14:22 18:5 

20:4 22:19 23:10 

24:19 30:6 33:15 

58:18 59:1 64:10 

70:18 78:19 100:1,10 

100:17,21,22 101:19 

103:15,18 104:18 

106:17,22 107:8,20 

109:9,16 111:13 

113:11 116:19 126:7 

126:13,14 145:20 

156:10 158:18 166:14 

174:17 

largely 109:22 

larger 6:9 104:17 109:4 

112:20 128:21 147:5 

159:4 

largest 6:22 11:19 

24:13 25:5 58:13,14 

100:14 101:13 109:11 

116:6 126:21 158:17 

158:20 189:19 

late 39:4 137:10 

Laughter 14:5 19:1 

25:19 51:10 59:22 

66:9 80:5 83:17 88:16 

96:21 98:9 100:6 

116:16 142:8 144:9 

145:4 164:13 173:15 

law 15:20 85:16 153:22 

lawsuits 115:6 

lawyers 26:16 

lay 79:13 140:13 

layer 122:16 

lays 54:3 

lead 151:12 

leader 13:6 140:21 

leadership 137:1 

leading 30:5 70:15 

118:10 

leads 86:17 134:3 

lean 122:6 

learn 136:18 188:10 

learned 34:2 73:2 

170:14 

learning 14:18 87:18 

least-cost 102:18 

leave 52:12 

leaving 70:10 

led 137:11 138:4,21 

left 9:2 110:1 120:12 

legal 3:13 16:21 17:2 

18:21 67:4 70:21 

115:2 116:4,9 136:2 

172:1 

legally 180:2 

legislated 156:14 

legislation 154:18 

182:22 

legislative 133:5 

Lehman 166:13,13 

lend 90:14 

lenders 87:12 

lesson 100:3 

lessons 73:3 170:14 

let's 129:14 177:16 

letters 76:22 

level 11:1,20 18:19 23:5 

26:12 75:5,9 111:19 

131:13 139:12,14 

171:11 

levels 97:18,18 176:22 

leverage 33:19 43:7 

45:16,21 

leverages 26:3 

liabilities 81:3 92:2 

116:12 

liability 122:17 148:11 

lie 177:7 

life 14:1 38:18 48:18 

142:11 164:10 

lighting 143:9 

lights 19:4 

liked 143:2 

likelihood 153:5 

limit 8:19 108:5 149:12 

limited 67:2 101:16 

105:15 115:18 162:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
205 

162:17 

limits 113:9 

line 29:1,5 49:2 104:13 

104:15 105:17 118:6 

127:9,19,22 128:1,2 

142:13 161:14 162:10 

186:7 187:17 

lines 30:12 33:8 110:12 

125:14 

liquidation 10:10 20:20 

49:7 75:6 104:2 110:6 

124:16 186:5 

liquidity 46:4,13,20 

48:3,14 80:14 103:16 

103:17,21 104:3 

110:19 117:2 119:1 

148:9 159:14 

list 18:18 78:20 

listed 87:15 

listening 18:12 

little 6:10 21:8 30:2 

46:12 51:16 57:8 

62:13,13 64:13 87:22 

94:19 105:2,4 117:14 

118:19 139:18 142:12 

143:9,9 156:2 168:20 

172:11 182:3 187:3 

live 55:7 62:6,7 87:4 

lived 55:6 56:16 58:3 

livestreamed 19:12 

LLP 1:18 2:22 

local 101:4 168:20 

located 30:14 

logical 42:14 

London 166:15 179:20 

long 22:22 26:6 43:11 

45:9 52:6,8 55:19 

56:21 62:17 100:17 

117:19 121:1 126:8 

168:20 

long-term 11:18 21:2,3 

95:16 101:20 108:3 

119:8,10 125:22 

127:1 173:5 

longer 57:8 177:22 

look 13:20 19:18 22:7 

24:1 27:8 29:13 45:5 

45:7,10 50:2 57:11 

61:2 62:10 74:10 

78:18 93:21 95:9,14 

113:11 116:5 118:7 

123:9,21 127:2 

128:20 129:9 143:8,9 

162:9 165:18 166:7 

167:7 169:5,16,17 

173:6,18 184:15,21 

185:9 189:12 

looked 122:21 158:9 

169:15 171:8 181:12 

looking 16:5 23:7 27:7 

29:12 39:21 49:12,20 

50:7 70:5 76:16 99:8 

105:14 115:9,21 

116:2 124:19 125:16 

169:13 172:4 188:22 

189:8 

looping 89:21 

lose 145:5 152:3 174:1 

loss 108:1 131:19 149:9 

151:14 156:13 186:13 

188:5 

losses 81:10 101:21 

102:15 103:1 108:3 

125:1 132:21 133:3 

143:5 147:2 149:6,11 

149:15,18 150:6,21 

150:22 151:1,3,4,11 

151:17,21 153:19 

155:6,17,22 156:3,9 

157:15 158:12 162:12 

162:16 163:4,4,15 

164:1,16 166:17,19 

169:22 172:11 173:19 

173:21 174:12 175:2 

175:20 

lost 149:8 

lot 11:12 12:14 13:18 

14:9 22:4 23:20,20 

25:14,16 26:20,20 

29:18,18,19 38:4 40:3 

40:15,19 41:8,14 42:3 

46:3 51:11 52:16,20 

54:22 58:21 59:14 

61:9,22 71:18 72:6 

73:16 74:6,13 75:14 

75:16 77:3,16 78:4,21 

79:1 82:17,17 83:7,18 

85:18 88:20 91:11 

96:8 99:18,19 103:4 

107:3 109:7 112:5 

113:11 114:13 115:6 

118:2,3,3 119:9 120:4 

121:13 122:17 124:8 

128:22 130:4 141:10 

179:12 183:14 184:4 

184:17 185:3 188:11 

191:11 

lots 56:8 

love 38:21 39:6 118:5 

178:22 

low 74:11 

lucid 164:21 

lunch 192:4 

M

machinery 176:15 

macro 112:9 

macro-prudential

143:17 

Mae 2:13 

magazine 88:11 

magic 104:12,14 

magically 127:22 

main 150:21 

maintain 24:16 27:3 

32:9,11 63:7,16 81:5 

111:4,12 131:9 149:3 

maintaining 109:3 

113:9 

major 7:16 61:15,16 

122:22 138:20 

majorities 67:6 

makers' 23:20 

making 7:8 38:8 52:4 

53:7 106:7 113:16 

115:12 117:6 119:22 

125:10 170:18 184:3 

manage 5:19 10:21 

11:5 20:3 145:10 

147:16 155:18 176:8 

183:19 190:4 

manageable 178:3 

190:11 

managed 40:1 

management 27:2,6 

29:9 30:11 31:21 

33:15 42:6 55:9 57:22 

81:21 109:20 128:17 

131:19 137:7 139:17 

152:14 154:6 157:1 

172:16 173:2,8 

176:12,15 191:6 

managements 91:6 

152:5 

managers 31:7 

managing 24:18 131:21 

mandate 174:7 180:2 

mandating 12:7 146:2 

manner 53:4 

map 73:21 

March 62:12 95:10 

138:7 

Margaret 8:1 

margin 147:6 150:1 

157:7,18 169:5,10,11 

169:18,22 170:4,6,9 

170:10 174:1 176:20 

179:3,17 180:10,13 

181:6,19 190:16 

191:12 

margined 168:22 

margining 147:1 169:3 

margins 167:22 168:3 

178:21 

mark 39:7 

market 13:2 57:3 62:20 

67:10 94:3,15 95:5,9 

96:12 97:8 98:14 99:1 

110:22 115:21 121:19 

125:20 133:1 136:21 

137:12 140:20 144:12 

185:8 188:2 190:9 

marketing 101:21 

markets 1:15 6:15 

10:14 16:3 49:5,6 

50:4 97:15 99:10 

132:9 145:21 146:13 

146:14,15 147:15 

152:2 165:21 167:20 

168:18 

Martin 1:11 3:2 4:11,21 

142:17 

Marty 14:14 16:14 

144:10 155:9 164:18 

183:16 

Massachusetts 2:20 

massively 48:19 

matchbook 149:3,7 

material 30:12 33:8 

36:17 

matter 105:13 122:5 

129:18 145:17 183:12 

192:5 

matters 17:2 19:20 

maturity 148:9 

MAYOPOULOS 2:11 

112:7 

McGraw 3:10 16:20 

28:2,5,9 37:16,19 

38:9 39:9 41:10 44:20 

46:15 50:9 52:16 

53:10 

mean 37:16 54:18 59:6 

65:13 67:21 68:3 

86:11 87:5 94:19,20 

128:19 146:21 148:17 

166:1 169:6 173:18 

176:2 181:9 184:12 

185:2 

meaning 90:2 

meaningful 6:21 100:16 

means 54:20 96:7 

102:18 108:4,15,17 

119:11 125:3 135:2 

138:3 147:18,19 

151:18 

meant 138:1 

measure 99:6 170:3 

measures 170:14 

mechanics 67:4 82:13 

mechanism 82:6 

178:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
206 

mechanisms 47:22 

48:8 81:19 169:7 

media 91:16 

meet 6:5 13:19 47:1 

68:4 139:21 147:20 

160:4 164:5 

meeting 1:5 7:21 17:4,9 

17:14,15 18:1,16 19:8 

19:11 20:9 22:14 

130:15 143:3 186:19 

188:21 

meetings 5:16 20:14,18 

20:22 32:10,21 33:1 

37:22 40:4 139:12,21 

140:2,4,5 142:5 164:8 

meets 17:12 31:8 

Meg 2:21 121:17 

member 37:6,18 38:7 

38:16 41:22 44:15 

48:10,13 49:3,22 

50:13 51:11 53:2,11 

56:5 57:15 61:1 62:10 

63:18 64:3 65:4 83:8 

83:18 84:18 86:2 

89:20 91:9 92:17 

93:20 94:14 96:19,22 

98:4,10 99:4 112:7 

114:10 116:8,17 

119:4 121:11 122:8 

122:15 127:7 128:13 

129:11 131:21 149:17 

165:5 167:14,17 

170:7 172:9 173:13 

173:16 177:9,11,13 

177:16 179:6 181:15 

183:22 189:3,15 

190:6 

members 6:12 7:20 9:2 

13:12 17:7,16 20:1,11 

28:7 32:9 66:13 

148:19 149:12,19,22 

150:2,4 151:3 152:15 

152:16 154:6 155:22 

158:2,17,20 159:3,10 

159:13,15,19 163:11 

165:1,20 168:7 171:4 

173:1 174:18 175:9,9 

175:13,19,22 176:8 

176:10,10,19,22 

177:7,12 179:14 

180:7,15,17 181:11 

181:12,17,17,22 

189:6 

membership 42:8 

memories 54:20 56:13 

memory 73:4 74:17 

mental 105:2 

mention 32:16 33:3,12 

71:6 139:3 165:6 

187:14 

mentioned 12:1 14:14 

15:3,17 18:3 22:20 

23:16 31:19,21 35:4 

36:5 38:17 39:19 

44:15 64:13 65:4,9,21 

73:6,15 75:2 77:5 

81:15,16 120:9 

130:13 133:12 140:19 

142:3 149:14 177:20 

180:12 

mentioning 47:19 

merger 128:9 

mergers 123:6 

message 79:7 99:10 

109:8 

met 5:8,10 16:4 65:6 

131:7 136:19 139:9 

metrics 123:8 180:16 

Michael 3:4 9:8 

micro-prudential

143:16 

microphone 19:4 

middle 86:3 124:13 

166:18 

midsize 89:17 

Mike 13:12,15 14:1 98:5 

Mike's 98:5 

militant 59:20 

millimeter 128:1 

million 56:14 109:12 

151:8 

mind 43:20 104:7 

116:18 166:1 174:4 

mindful 76:5 79:16 89:3 

minds 23:20 

mindset 60:9 

minimal 90:12 

minimum 108:1 150:19 

168:3 170:8 

Minneapolis 9:7 

minute 19:21 

minutes 24:10 30:2 

129:15 136:5 

mismatches 148:12 

mission 24:15,20 

mitigate 115:10 

mobilize 58:9 59:2 

mode 18:12 

model 42:18 105:2,17 

113:5 118:5 178:14 

178:15 189:21 191:8 

191:8 

modeling 48:2 

models 169:18 180:10 

180:14,18,19 181:6 

modular 69:8 

moment 27:20 86:12 

178:17 

money 75:11 82:14 

85:10,11,19 87:13 

119:19 173:22 179:15 

179:17 

monitoring 29:16 33:14 

40:22 47:16 136:1 

month 8:18 

months 59:14 

moral 118:15 

morning 5:4 7:18 8:7 

9:12 13:10,14 16:12 

28:6,13 36:2 37:2 

70:6 71:2 143:3 

move 24:5 27:21 39:2 

47:3 55:20 56:1 70:6 

75:11 112:6 185:9 

movement 129:6 

moves 178:13 

moving 55:2 56:16 

86:15 104:5 110:4 

165:21 

MREL 121:12 122:10 

multilateral 136:13 

175:13 

multiple 57:3 62:8 

112:10,21 113:18,20 

125:17 174:15 

Murton 3:11 137:5 

muscle 55:17 73:4 

74:17 

mute 165:16,17 

mutual 101:18 120:9 

136:15 

mutualization 147:2 

156:8,9 171:16 

mutualize 173:21 

mutualized 156:3 

178:14 191:8 

N

nailed 177:18 

name 28:8 169:7 

narrative 92:11 

national 1:19 15:1 

60:10 

nations' 25:5 

naturally 25:11 49:16 

49:16 70:14 145:20 

nature 180:20 181:19 

navigate 67:17 

NCSS 2:10 

near 13:19 98:22 

nearly 35:16 

necessarily 117:16 

118:20 124:3 

necessary 24:18 48:9 

149:6 150:3 159:2 

162:5 

need 16:2 17:1 19:7 

22:17 26:4 30:19 

36:13 43:19 44:9,12 

48:15 53:14 56:8,9 

58:5 59:4 60:2 63:4 

69:10 73:2 74:21 

77:20 78:19 79:4,8,10 

79:16,17,21 80:12,13 

80:17,19 81:17 82:1 

82:10,11 83:14 84:3,8 

84:14,16 87:10 88:19 

89:3 90:4 91:3,15 

93:17 109:10 110:13 

111:10 113:10,14 

114:10 116:7 119:7 

120:22 121:5 125:8 

131:21 138:16 145:7 

147:16,22 148:12 

149:5 154:22 155:6 

158:21 160:12,20 

162:19 163:9 164:14 

169:5,7 170:8,9 171:9 

172:2 175:9,10 181:3 

182:9,14 183:18 

185:14 190:12 191:16 

needed 25:21 35:21 

65:7 82:5 107:18 

138:11 

needs 23:7 30:20 55:13 

59:17 93:13 96:8 

100:3 121:18 135:21 

148:5 150:18,19 

153:4,7,10,11,13,14 

161:6 164:1 171:8 

181:4 189:1 191:9 

negative 90:15 

netting 147:2 

network 93:8,14 

neutralize 149:18 

172:18 

neutralized 177:3 

never 48:16 50:21 

60:10 89:18 92:20 

new 1:14,21 6:12 7:20 

13:19 18:4 19:22 20:2 

23:11 25:8 45:22 56:2 

72:10,10 99:19 103:6 

145:11 162:21 182:17 

182:21 

newer 69:11 

news 94:17 189:15 

nice 5:5 123:2 

nicely 139:4 

night 83:3 

nighttime 143:8 

nimble 69:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
207 

nitty 83:21 

nodes 145:18 

Non- 151:3 

non-bank 15:8 185:18 

non-default 143:5 

150:20 151:11 162:12 

163:4,14,22 164:16 

172:11 174:12 175:2 

177:3 

non-GSIB 22:18 100:1 

non-prefunded 158:10 

nonbank 35:12,14 36:3 

36:9,22 65:7,9,18 

66:1 67:5 87:12 

185:20 187:11,17,21 

188:8,20 

nonbanks 49:9 64:13 

65:13 

nonessential 166:20 

nonpublic 36:18 

normal 89:2 93:7,14 

169:11 170:10 

notably 20:6 

note 35:4 110:5 141:16 

142:3 

noted 42:1 70:17 

108:21 127:1 130:5 

notes 19:3 

notice 11:16 17:11 18:2 

46:18 77:8 111:16 

noticed 42:4 

noting 20:10 

November 1:7 137:18 

NPOE 80:18 

NPR 18:13 

number 14:22 15:19 

45:1 78:20 89:5 

100:16 109:9 126:18 

135:14 137:8 157:15 

158:11 184:13 

numbers 45:3 48:4 

NW 1:10 

O

O'CONNOR 2:14 49:3 

49:22 53:11 57:15 

64:3 89:20 116:17 

172:9 173:13,16 

177:13,16 179:6 

181:15 189:15 

objective 40:17 105:1 

156:21 

objectives 27:11 131:8 

obligation 174:7 

obligations 160:5 

189:10 

obliged 180:3 

observe 70:4 159:6 

observing 188:5 

obsessed 11:4 

obstacles 154:21 162:1 

obvious 93:2 145:2 

148:7 175:16 

obviously 14:14 15:8 

16:3 20:18 37:9 66:12 

67:17 80:9 105:6 

107:16 110:11 117:3 

126:15 

OCC 11:14 26:21 45:2 

47:13 103:7 

OCC's 35:1 

occur 49:19 114:8 

137:17 

occurring 172:15 

occurs 101:6 

October 5:9 18:7 

OFC 122:19 

offer 91:7 116:14 119:2 

142:14 158:7 160:8 

171:10 178:11 

Office 3:9 66:21 122:19 

Officer 2:9,10,12,15,17 

officers 38:20 

official 17:20 

offset 149:7 

offsetting 149:1 

offsite 33:17 

old 60:3 189:4 

OLF 80:14 82:8,13 

omnipresent 55:3 

once 112:10 113:20 

123:9 154:4 157:8 

167:3,6 

one- 129:11 

ones 47:14 57:10 74:7 

ongoing 10:7 75:3 

112:4 130:19 133:2 

134:6 139:15 183:11 

online 28:8 

onsite 29:7 32:22 33:13 

33:20 37:20 40:22 

44:4 45:1 111:4 

open 17:21 18:9 37:4 

64:8,12,12 76:22 77:1 

77:18 151:9 

opening 65:21 190:3 

operate 114:20 126:13 

147:15 153:22 154:20 

162:7 190:7 

operating 108:16 

150:18 

operation 164:6,9 

operational 58:17 

79:17 106:7,9 107:14 

107:18 108:22 109:3 

110:7 126:12 134:5 

148:15,15 150:21 

186:9 

operationalize 21:1 

185:12 

operations 29:4 30:13 

33:10 92:7 105:9 

106:6 113:9 117:7 

135:7 151:6 185:8,10 

opportunities 74:11 

opportunity 19:13 51:5 

117:8 

opposed 146:6 

opposite 96:13 

option 72:3 116:11,15 

122:17 124:14 157:10 

163:7 

optionality 121:5 

options 22:18 101:11 

101:15 107:13 108:6 

126:7 128:7 134:5 

140:7 153:1 162:1 

164:16 176:7 183:4 

order 20:16 82:21 91:4 

91:5 131:11 170:11 

190:20 

orderly 5:19 10:9 11:21 

20:3,20 21:4 137:22 

186:4 

ordinary 107:2,10 

organization 25:14 

55:18 137:13 186:3 

organizational 28:14 

186:8 

organizations 10:22 

11:19 18:6 

original 34:10 123:10 

ought 84:1 

outcome 62:7 71:13 

90:15 

outlook 59:13 

outside 75:16 106:6 

109:1 153:10 167:21 

outweigh 160:18 

outweighs 177:9 

overall 34:2 

overarching 27:11 

overcome 116:7 

overlap 35:3 42:7 

overprudently 170:10 

oversee 29:22 31:8 

81:4 181:20 

Oversight 15:10 

overview 66:5 131:13 

165:6 183:9 

owe 150:1 175:22 

owners 152:14 154:6 

156:1,6 171:15 

ownership 163:10 

171:14 

P

P 1:15 3:8 

P-R-O-C-E-E-D-I-N-G-S

5:1 

p.m 192:6 

pages 157:11 

paid 166:19 

panel 57:1 70:15,16 

111:4 

panelist 16:19 

paper 54:15 88:9 89:7 

parameters 68:3 

parent 106:12 

pari-passu 102:15 

Parliament 88:4,13 

89:19 145:12 154:19 

162:22 

Parliamentary 145:13 

part 9:19 25:22 27:3 

31:22 33:19 37:14 

46:17 49:22 53:2 

54:12,17,19 55:6,11 

59:1 73:10 74:4 82:6 

96:7,16 100:2 105:1 

105:22 109:7 113:1,2 

113:2,21 118:18 

120:14,19 124:2 

129:6 131:20 134:13 

138:9 158:8 172:3 

182:6,22 192:3 

PARTICIPANT 59:8 

participants 18:19 

19:11 132:9 

participate 34:21 140:2 

participating 19:5 

43:14,18 

participation 33:17 

186:19 

particular 10:11 13:4 

112:19,19 130:16 

134:12 

particularly 19:22 49:6 

50:5 59:10 76:8 90:8 

108:7 114:2 116:6 

131:20 140:22 151:22 

155:19 174:13 179:10 

180:1 

parties 12:4 59:4 68:7 

79:6 148:21 

partly 83:15 

partner 2:21 6:18 8:1 

14:1,3 

partnership 6:19 

parts 79:2 125:14 

party 12:3 124:15 

pass 5:14 102:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
208 

124:21,22 125:2,3 

149:11 151:3 

passed 161:4 163:11 

174:8,17 

passing 151:9 

path 38:22 110:10 

117:13 118:11,17 

patience 84:11 

patterns 91:17 

pay 85:2 97:7 116:12 

170:1,7 

paying 103:2 

payment 13:3 103:12 

140:22 141:17 143:14 

144:11 

payments 13:2 137:12 

140:20 

payroll 119:22 

peacetime 56:7 91:12 

peak 147:4 

Pen 70:21 

pending 17:18 

PENFIELD 3:13 

Pennsylvania 2:3 165:3 

people 14:8 19:9 39:6 

44:17 46:21 47:16 

54:20 56:15 57:4 65:1 

71:15 79:6,12 82:11 

83:3,13,20 84:2,5,7,9 

84:14 85:6,12,18 90:3 

91:18 94:20 95:6,11 

98:17 122:3 145:5 

166:19 167:22 181:13 

184:4 190:3 

people's 172:1 

perceived 31:15 40:2 

percent 104:20 109:18 

118:9 146:5,7,8,10 

perfect 48:17 123:8 

perfectly 191:3 

perform 132:22 

perineal 55:22 

period 91:12 110:14 

126:6 167:13,19 

perpetual 68:20 

person 5:10 14:8 143:2 

143:22 

personnel 106:13 

perspective 10:5 30:18 

32:22 34:6 68:9 81:6 

89:22 104:11 105:19 

106:16 129:10 141:13 

144:3,4,5,6,7,21 

155:10 185:21 

perspectives 27:8 

144:19 

pessimistic 83:12 

Peter 9:4 

PETERSON 2:16 44:15 

96:22 128:13 129:11 

PFMI 144:16 

phasing 128:9 

phonetic 41:5 73:14 

98:17 138:22 147:4 

159:12 164:12 174:22 

182:20 

pick 69:2,4 116:4 145:6 

picked 115:5 

picture 64:5 

pieces 190:12 

pitch 61:20 62:3 

place 31:10 36:16 38:12 

47:9 59:6 84:7 92:12 

119:16 121:16 154:15 

156:8,9 172:6,19,20 

185:22 187:8 188:6 

188:20 191:7 

placed 31:14 40:5 

156:22 

plan 26:4 33:19 34:2,13 

34:20 35:1 38:1 51:1 

51:2 53:16 65:15 

67:12 68:12 87:17 

131:22 153:14 161:18 

161:20 166:8 180:16 

190:19 

planned 96:16 143:4 

planning 4:16 21:13 

22:16 32:8,13,20 33:2 

33:11,12 36:10 58:13 

59:1 70:17,18 71:9,21 

72:5,9,11,12,14 76:18 

78:5 80:22 84:12 

87:10 100:3 112:1,3 

112:13 115:19 120:20 

121:2 126:16 127:20 

133:20,22 134:14 

136:3 167:10 184:15 

184:22 188:3 

plans 6:21 15:13,21 

31:1 34:1,10,18,22 

36:5,5 50:22 54:5 

59:6 72:10 73:6,13,18 

76:20 78:8 87:20 

89:13 117:5 126:22 

133:14,17 139:14 

154:21 186:6 189:18 

plant 112:2 

play 15:6 57:22 99:12 

102:22 146:16 

playbook 116:22 

played 8:4 136:22 

please 19:8 76:4 79:19 

173:13 191:17 

pleased 167:5 

plug 49:1 

plus 7:3 42:22 107:4 

pocket 173:2 

pockets 168:12 

point 20:21 34:10 35:6 

57:9,20 63:3 64:10 

71:13,14 72:2 74:1 

77:9 82:14,14 91:2 

93:12,22 108:12 

110:10 113:6 117:1 

120:12 122:16 123:1 

123:3 125:5 128:19 

148:3 150:14 151:16 

152:11,17,22 155:20 

156:16,17,20 158:22 

164:6 176:16 181:9 

points 15:7 21:17 94:5 

154:2 159:17 

policy 1:19 23:20 29:16 

51:14 100:12 138:10 

138:19 

policymakers 52:12 

78:22 

polite 168:19 

political 88:11 

Polk 2:22 8:2 

pool 114:21 

poor 152:2 

Pop 74:12 

portfolio 29:11 111:20 

portfolios 125:15 

portions 76:20 109:16 

posed 100:19 137:16 

posit 117:22 

position 42:20 43:6 

44:1 83:3 111:18 

162:14 

positioned 157:22 

positions 166:14,16 

positive 129:22 168:11 

possibility 11:18 

possible 34:15 48:7 

75:19 84:2 101:19 

105:15 116:14 137:17 

177:10 

possibly 52:1 

post 75:7 

post-crisis 7:11 188:22 

posted 77:1 

potential 18:4 26:12 

31:18 46:3 110:15 

132:7 138:2,19 190:1 

potentially 101:5 

118:16 132:8 159:22 

Powell 56:20 

power 77:21 156:14 

163:1 182:14 183:2 

powers 25:6 44:2 64:18 

64:20 87:1 151:2 

154:20 155:2 162:21 

182:17,20 

practice 18:15 69:19 

143:21 144:1 186:22 

practices 29:9 136:19 

practitioners 52:10 

133:7 

praise 83:9 

pre- 132:8 157:4,21 

181:4 

pre-commitment 79:15 

pre-funded 103:18 

149:18,20 155:6,12 

156:7 157:2 158:10 

158:21 162:4 174:5 

178:19 179:15 

pre-positioned 149:16 

pre-stress 181:6 

pre-work 96:8 

predict 63:12 

predictable 178:3 

190:11 

preexisting 101:20 

preferable 147:3 

157:17 

preliminary 17:17 

premium 98:18 

prep 68:19 

preparation 35:10 47:7 

92:9 

preparations 6:3 

prepare 31:17 47:7 

100:4 

prepared 14:9 24:3 

50:20,20 51:7,22 

96:17 111:10 120:21 

120:22 131:22 

preparing 32:21 47:5 

prescriptive 116:21 

presence 33:13 37:20 

111:5 120:15 186:18 

present 1:12 3:1,20 

12:13 17:16 55:3 

59:14 119:3 

presentation 101:8 

164:21 167:18 

presentations 22:10 

presents 23:14 

preserve 57:7 171:5 

185:7 

preserving 106:1 

president 1:19 2:8,9,11 

2:12,16 7:5 9:7,8 67:9 

presiding 1:11 

press 19:4 

pressure 83:10 168:8 

176:19 179:9,13 

pressures 181:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
209 

pretending 57:1 

pretty 24:15 26:17 37:9 

54:9 57:12 70:4 71:13 

92:14 121:16 123:21 

146:13 151:5 160:6 

162:17 164:21 174:17 

176:3 

prevent 15:5 

previous 145:1 149:14 

previously 12:1 14:1 

prices 46:11 95:4,9 

165:20 

primarily 24:11 

primary 95:3 

prime 187:12 

principle 44:7 95:19 

principles 139:6 

prior 38:15 47:8 82:4 

141:16 187:7 

priorities 7:7 10:7 

82:20 99:12 

prioritization 131:2 

prioritize 24:4 

prioritizing 30:22 

priority 7:8,14,16 10:20 

11:12 12:15 31:14 

40:6 89:11 116:13 

189:1 

privacy 42:15 

private 154:3 155:21 

privilege 13:11 142:22 

proactively 26:8 135:4 

probability 31:15 40:2 

probably 5:20,21 10:17 

57:10 60:21 61:1 

69:22 78:11 79:3 

88:19 89:6 91:14 

92:11 107:9 112:9 

114:10 120:15 122:20 

125:4 149:6 178:15 

189:1 

problem 43:9,9,20 

54:17 57:8 65:12 

85:20 118:6 119:13 

123:17 126:4 128:11 

128:12 135:9 142:16 

170:20 173:20 

problems 54:13 56:6,11 

66:1 

procedural 184:3 

procedure 184:17 

process 10:4 31:12,12 

33:20 46:17 47:1 

54:10 71:12 76:12 

77:2 81:15 112:4 

122:13 126:16 133:2 

133:21 134:1,11 

150:12 151:20 

processes 135:18 

procyclical 157:20 

163:21 180:18,19 

procyclicality 169:8 

170:4,14 180:14 

produce 121:4 

productive 90:8 

products 182:18,21 

professional 84:16 

97:15 98:2 123:2 

professionally 84:3 

professionals 26:15 

Professor 2:2 

profile 31:15 39:22 

profound 141:8 

program 2:6 13:9 16:7 

programs 29:16 31:5 

34:3,7,12 

progress 7:8,13 135:12 

136:7 140:6 141:10 

184:3 186:16 

projections 110:13 

prominently 51:14 

promise 102:6 

pronounced 104:16 

pronouncements 97:4 

proof 128:4 

proper 98:21 

properly 155:18 

property 172:1 

proportional 160:17 

proportions 146:11 

proposal 15:4 

proposals 17:18 145:11 

proposed 11:16 18:2 

133:5 163:2 

protect 24:16 131:11 

145:20 168:3 

protected 95:7,8,19 

172:2 

protection 3:3 13:13 

147:13 160:15 163:8 

169:21 171:1,11,21 

175:5 

protects 163:8 

protocol 31:11 47:1 

protocols 39:19 63:10 

proven 134:14 

provide 17:3 19:14,15 

33:22 36:6 54:7 82:7 

82:10 90:14 111:16 

111:18 126:20 161:22 

173:2 

provided 25:7 

provides 29:6 94:8 

providing 66:3 133:18 

169:3 

provision 131:10 

154:10 155:4 

prudent 147:1 

prudently 169:10 

psychological 115:5 

public 10:15 11:17 

18:17 19:11 22:17,22 

70:17 76:20,21,22 

77:11,18 79:5 80:7 

81:5,20 82:22 83:11 

84:16,19 85:4 86:1,9 

87:22 89:11 90:12 

97:9 153:22 175:14 

175:15 187:19 

publicly 78:12 84:7 

102:4 133:5 

publish 18:16 

published 76:19,19 

77:8 88:7,10 137:19 

138:9,13 158:13 

169:13 

publishing 90:16 

pull 47:15 91:21 

pulls 49:1 

purchase 115:13 

purpose 38:10 66:3 

132:21 

purposes 17:14 39:12 

pursuant 116:13 

pursue 70:1 

push 51:5 52:21 118:5 

pushed 48:22 

put 34:9 36:16 67:16 

69:10 84:20 85:10 

86:9 87:21 114:9 

122:20 163:2 170:22 

173:22,22 176:10 

185:22 

puts 43:5 187:7 

putting 44:8 87:3 94:5 

Q

Q&As 76:19 

QFC 111:19 

QFCs 21:4 

qualified 120:18 

quantitative 29:17 

47:22 

quantum 146:12 

quarterback 93:6 

question 38:16 39:10 

40:14 41:8 49:4 50:14 

51:9 52:7,15 53:2 

55:15 58:8 62:11 66:7 

66:11 67:21 86:12 

88:4,5 113:22 118:4 

121:7 122:1 155:5,15 

157:2 159:5 160:14 

168:8 173:8 174:9 

177:15 178:17 188:18 

191:5 

questions 18:20 24:5 

27:21 37:5 41:15 

54:11 80:22 82:17 

140:10 145:6 165:1 

183:6 

quick 33:3 50:13 74:12 

98:4 102:8 143:11 

150:20 

quickly 69:13 91:15 

92:1 99:5 104:6 

106:21 115:17 116:4 

116:10 124:9 161:15 

165:13 166:12,19 

quire 125:17 

quite 14:16 15:11 16:3 

56:21 74:18 89:4 

110:8 115:16 123:15 

128:2 147:11 160:13 

166:12 167:13,20 

179:18 

quorum 17:12 

R

R 3:13 

radical 65:19 

raise 19:6 66:11 157:12 

181:17 

raised 51:14 155:21 

185:17 

raises 155:5 

raising 161:5 

ramp 127:18 128:6 

129:5 

ran 56:20 

range 20:15 50:12 

71:20 72:4 116:3 

ranging 109:17 

rapid 32:14 

rapidly 46:12 

rate 119:11 146:8 

rates 167:20 181:1 

ratings 84:4 

re-capitalized 175:21 

reach 96:10,11 

reaching 84:15 

react 180:15 

reaction 112:6 

read 17:6 88:15 97:10 

readily 27:18 125:13 

129:5 

readiness 3:15 27:4 

29:3 30:3,19,21 31:2 

31:13 34:19 47:5 53:1 

63:8,17 70:20 71:3 

72:7 73:14,16 75:2 

76:3 134:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
210 

ready 41:4 63:4 72:20 

72:22 75:11 111:8 

129:22 

real 47:17,20 48:6,18 

57:5 67:9 96:6 165:18 

realistic 120:15 

reality 53:20 118:14 

realize 41:7 

realized 11:8 

realm 43:15 

reason 62:18 156:4 

157:4 163:15 191:10 

reasonable 70:12 

reasonably 57:16 

reasons 114:1 141:10 

143:19 155:11 157:16 

161:11 175:16 

recall 131:7 

recapitalization 117:8 

178:12 

recapitalize 132:21 

163:5 

receive 36:17 83:4 

receiver 132:3 

receivership 3:17 109:8 

109:20,20 110:2,7 

116:12 

recession 86:16 

recognition 118:5 

recognize 9:1 34:11 

49:12 72:18 160:20 

recognized 123:8 

recommendations

180:11 

record 22:22 111:13 

129:19 192:6 

recovery 34:18,22 35:1 

38:1 39:2 49:8 50:21 

132:5 137:18 138:7 

150:7 152:5,19 153:5 

153:8 155:7 158:12 

161:16 162:15 164:15 

176:6 189:18 191:3,3 

reduce 110:21 113:14 

154:4 176:20 

reduces 154:5 

reducing 161:5 

REED 2:18 37:6,18 38:7 

183:22 

reemphasize 82:1 

refer 28:11 88:14 

reference 168:19 182:3 

referred 100:19 

refined 134:3 

reflect 148:5 

reforms 12:7 21:1 

regard 7:13 22:9 42:20 

91:1 130:5 

regarding 17:5 

regardless 65:3 

regards 18:2 

regime 102:11 145:10 

145:11 154:14,15 

156:13 174:2 

regimes 145:7 

regional 15:1 100:20 

124:6 125:15 128:21 

129:4 

Register 77:9 

regular 6:5 18:15 31:3 

32:9 

regulate 64:18 

regulated 65:15 

regulating 66:1 

regulation 1:16 6:17 

143:15 180:4 

regulator 144:6 182:20 

regulators 66:20 77:5 

78:22 93:5 95:3 133:6 

178:6 181:3 182:10 

182:14,16 188:2 

regulatory 2:14 36:11 

48:4 55:4 75:1 77:6 

94:1 114:13 116:6 

134:20 

reintroduce 24:10 

relate 17:17 107:13 

111:13 

related 18:4 34:17 

62:11 141:2 181:18 

189:6,11 

relating 12:2 18:17 

141:5 185:18 

relationship 67:12 

94:11 141:21 

relationships 32:11 

76:1 106:11 109:14 

187:6 188:17 

relative 25:4 104:1 

151:6 

relatively 45:22 101:1 

relevant 32:13 34:17 

reliable 45:6 

reliance 50:5 

relies 113:5 

reload 160:8 161:1 

rely 34:14 73:13 134:19 

157:6 

relying 113:8 

remain 17:21 21:14 

remaining 149:22 159:3 

remains 136:4 

remarks 4:20 65:5,22 

130:10 133:13 142:14 

remediated 45:8 

remember 22:1 56:20 

73:3 91:18 107:6 

115:2 144:8 159:19 

166:18 

remind 19:10 

reminded 122:18 

remotely 19:5 

remove 15:5 81:20 

135:3 147:13 154:21 

removes 150:16 

repeat 52:7 

repo 169:3 

report 138:8 169:13 

179:20 191:13 

reporting 170:2 

reports 83:11 97:17 

179:12 

represent 146:18 

representations 187:3 

represented 85:17 

186:18 

representing 32:3 

require 69:16 154:20 

156:5 

required 8:18 36:4 

81:20 133:17 187:10 

requirement 11:19 

108:2,4 112:1 119:9 

133:14 186:12 188:3 

requirements 17:11 

18:5 21:3 54:8 111:13 

requires 15:20 67:5 

69:12 111:14,17 

requiring 66:4 135:5 

Research 66:22 122:20 

reserve 1:16 2:5 6:17 

18:9 45:2 49:17 50:17 

126:19 133:3 134:21 

reserved 133:9 138:16 

Reservists 59:8 

reservoir 162:4 

resilience 172:21 

resiliency 26:11,11 

29:8 

resist 158:2 159:5,6,10 

resolution-specific

111:12 

resolutions 46:3 104:4 

138:15 159:22 

resolvability 6:22 88:8 

100:17 126:15 135:1 

135:5,16 186:10 

resolve 30:6 102:6 

111:10 117:20 122:5 

160:10 

resolved 51:3 102:5,10 

104:2 148:12 

resolvers 46:2 

resolving 8:15 22:18 

35:12 58:15 101:10 

102:12 113:18 130:18 

resource 18:5 33:18 

59:16 113:9,14 

resources 26:2 27:17 

30:19 58:18,22 59:3 

69:6 92:15 107:18 

113:6 128:8 131:17 

132:1,6,12,20 133:3 

135:13 137:21 138:3 

138:6,12,16 149:16 

149:20 153:1 155:7 

155:12 156:7 157:3,5 

157:12,21 158:11,21 

159:14 160:7 161:16 

162:4,20 163:14 

164:4 171:13 174:5 

174:19 178:2 179:15 

186:13 187:5 188:5,5 

respect 18:13 19:16 

86:7 131:8,21 

respective 136:16 

respond 18:10 90:7 

94:17 115:17 123:19 

184:11 

response 27:22 32:14 

37:13 100:12 183:7 

191:21 

responses 101:14 

responsibilities 9:16 

22:1 24:13 26:4 43:1 

141:17 143:13 188:1 

responsibility 6:3 9:18 

9:19,21 35:11 42:11 

42:12 143:18 

responsible 24:11 

29:15 30:5 84:6 

109:21 141:18 143:22 

responsiveness 169:5 

169:18 

restore 149:6 

result 12:6 25:4 101:4 

151:13 

results 191:12 

resume 5:15 

resumed 129:19 

retail 14:21 

retain 116:11 

rethink 122:14 

retired 59:5 

return 97:6 

returned 23:16 

returns 147:18 

reverse 123:12 

review 33:19 34:13 38:1 

47:20 73:11 133:20 

138:14 

reviews 21:7 34:21 73:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
211 

revisit 130:13 

Richard 2:2 41:21 

rid 40:10 

rightly 156:22 

rights 172:1 

rising 119:10 

risk 3:9,13 7:10 12:13 

21:21 26:12 28:16 

29:2,3,6,7,8,10,14,21 

30:11,17 31:2,13,14 

31:20 32:19 33:3,4,7 

33:11,15 34:19 39:22 

40:1,6 47:2 50:12 

55:9 99:11 115:11 

116:5,9 117:11,17 

124:3 127:10 131:6 

137:16 141:15 145:21 

146:18 147:9,14 

148:14,15,17 150:21 

155:18 160:14 173:1 

173:7 176:12,15 

177:1,8 181:18 

risks 29:11,13 30:10 

54:15 56:2 64:22 

73:17 141:2 145:9 

148:7,13 151:15 

167:12 172:14 176:8 

176:10 177:2 182:11 

road 73:21 

ROBERT 1:20 

robust 8:13 35:9 37:3 

131:19 154:9 

Rodgin 1:18 66:11 

Rohit 3:3 13:15 16:7 

role 8:4 42:21 44:18 

97:13 137:1 145:18 

146:15,16 187:16 

roles 68:14 

room 1:10 28:7 58:2 

85:6,17 

root 36:20 

Ros 168:16 

round 72:15 120:14 

route 101:22 161:13 

routine 72:8 

routinely 107:11 

rows 105:10 

RSG 138:22 

rule 18:14 34:11,13 

35:1 52:5 54:5,9 

131:20 132:13 149:10 

150:10 151:17 152:8 

152:10 153:11,18 

154:12 155:2 161:21 

167:8 171:2 175:5 

rulemaking 11:17 18:3 

54:2 183:1 

rules 50:3 51:13 52:5 

52:11,14,14 53:8 

82:13 99:15 135:6 

rules-based 52:2 

rumors 92:10 

run 38:18 46:7,14 81:2 

94:22 98:20 110:18 

148:7 149:21 

running 99:20 

runs 46:4 167:2 

runup 35:21 

runway 110:20 111:7 

runways 184:14 

Ryan 3:14 70:20 99:22 

116:8 127:6 

S

S 2:18 

S&P 2:17 

sad 89:4 

safe 23:3 

salable 105:14 

sale 46:7 101:18 108:9 

124:15 

sales 125:15 

Salla 2:8 7:5 92:17 

Sandie 2:14 172:8 

Sandie's 68:17 128:19 

sat 41:11,17 62:1 

saw 91:14 145:22 

168:16 191:12 

saying 57:21 63:19 

91:19 92:20 95:5 

117:13 128:10 173:5 

176:17 190:19 

says 167:7 171:2 

178:18 

scale 103:21 110:1 

112:8 117:21 128:5 

191:14 

scales 115:15 

scaling 92:9 

scan 64:6 

scare 84:19 

scary 86:10 

scenario 59:1 67:16 

74:14 112:13 124:4 

132:4 

scenarios 71:20 72:4 

116:3 

scheme 116:13 

School 2:3 9:6 

scores 122:22 123:22 

127:10 128:20 

scoring 129:1 

seat 189:4 

SEC 1:17 9:4 67:7 

134:21 139:7,20 

142:6 144:6 188:14 

second 8:17 10:6 18:1 

22:13 23:9 54:17 

57:20 70:7 83:12 88:5 

115:2 120:14,16 

133:11 156:15 157:4 

168:8 174:3 175:1 

177:14 

secondly 27:14 142:22 

seconds 96:12 

Secretary 66:15 67:8 

secrets 152:9 

section 64:15 

sector 65:16,18 154:3 

155:21 175:14,15 

187:11 

securities 1:17 7:22 

81:14 137:14 

seeing 5:14 47:2 114:8 

127:2 

seek 23:12 

seen 5:5,12 49:18 72:14 

96:9,11 98:16 120:7 

123:5 146:15 152:15 

155:10 166:11 168:18 

segment 37:1 

seismic 61:14 

Seivold 3:12 16:21 

select 85:12 

sell 123:16 177:21 

seller 149:2 

selling 15:6 110:3 

Send 74:15 

sending 99:2 

senior 1:13,15,18 2:6 

3:10,13 6:14 9:5 

16:19 28:9 71:2 

102:13 176:22 

seniority 181:12 

sense 42:3 53:6 117:21 

119:20 142:1 184:2 

185:19 

separates 127:22 

separation 42:5 

series 137:11 

serious 184:8 

seriously 53:15,21 

serve 31:16 139:12,14 

serves 140:17 

service 8:19 150:9,17 

151:14 162:6 164:6 

175:10,11 

services 30:13 33:10 

64:11 106:13 108:19 

109:1 150:14 152:3 

174:8 176:1 179:10 

180:20 

serving 9:10 

session 4:13,16,18 

9:14 10:6 12:1 16:19 

21:20 22:14 23:12,16 

24:8 129:17 130:2 

131:1 133:13 

sessions 9:13 

set 8:18 19:22 51:20 

54:16 59:6 63:10 74:4 

77:21 145:6 170:22 

180:8 187:4 

sets 24:20 152:10 

setter 144:14,15 

setting 60:6 76:11 

82:21 95:21 136:10 

settlement 143:13 

144:17 

seven 20:14 129:15 

share 6:6 22:12 48:10 

56:5 63:2 67:15 88:3 

102:15 131:5 140:6 

shared 27:18 48:16 

75:19 77:6 106:12,13 

106:13 135:17 140:5 

shareholders 171:11 

sharing 28:18,19 31:4 

32:7 36:16 

sharpen 36:12 

she'll 8:18,21 

sheet 121:8 

sheets 148:11 

Sheila 1:12 20:8 

SHELLEY 1:13 

shift 45:13 

shifting 50:3 

shock 117:3 178:11 

shocked 167:21 

shocks 169:6 

Shop 119:22 

shore 64:14 

short 54:20 57:17 88:12 

184:14 

shorter 165:14 

shortly 20:7 162:11 

should've 58:11 

shy 19:10 

side 30:21,22 37:17 

40:11,16 44:14 48:2 

50:18 51:5 52:19 55:4 

55:4 85:13 120:8 

142:6,7 177:20,21 

180:8 185:18 187:18 

188:8,9,16,20 

sided 179:18 

sides 27:9 79:2 

SIFIs 107:7 

sight 161:14 162:10 

186:7 187:17 

sign 23:2 61:19 62:3 

signal 95:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
212 

signals 67:11 99:1,3 

significant 9:19 21:12 

31:22 58:17 100:18 

101:4 102:1 103:19 

104:3 113:19 123:21 

124:16 125:22 135:13 

significantly 106:3 

110:2 125:4 132:1 

146:13 

similar 25:13 43:13 

95:5 104:16 

similarly 106:9 114:5 

114:18 

simple 10:17 88:17 

91:22 104:19 117:18 

120:21 160:20 

simpler 142:12 

simplified 110:3 

simply 15:6 60:19 84:6 

100:20 101:8 187:6 

simultaneously 62:9 

single 3:5 8:9,11 20:21 

71:14 72:2 77:9 

108:12 113:6 124:10 

125:20 

Sir 12:21 24:2 130:8 

140:14 

sister 26:19 

sit 95:15 

site 44:16 

sitting 58:3 61:13 

174:21 

situated 114:5 

situation 27:19 41:21 

44:5 95:10 131:22 

161:20 165:12,22 

169:21 175:18 

situations 175:22 

size 25:4 105:11 117:15 

117:16,22 128:15 

129:7,7,11 151:6 

156:18 174:12 

sizes 128:20 

sizing 170:2 

skin 156:2,6,10,15 

171:13 172:4 

slide 21:18 24:14 33:12 

76:4 78:20 79:19,19 

80:3 100:8 102:8 

104:5 105:1 106:14 

123:20 126:11 136:8 

slightly 86:3 

slowly 56:16 

small 45:1 77:17 118:8 

151:6 

smaller 58:16 69:8 

105:7 109:13 117:21 

118:2 121:13,13 

smoother 128:4 

sniffs 96:12 

social 91:16 

society 84:9 

solely 172:15 

solicit 14:10 20:17 

solid 93:14 

solution 168:4 

solutions 115:21 

solve 43:12 119:12 

solves 128:10 

somebody 41:18 99:14 

somewhat 51:16 

sophisticated 25:9 

sorry 45:13 165:18 

190:17 

sort 37:10,13 62:12,15 

63:14 64:15 72:7 

73:20 76:15 83:20 

89:20 90:10,10,12,13 

90:21 91:2,6,8,12 

93:6 99:6 113:8 

115:20 118:6 127:11 

127:18 128:9 140:13 

148:15 161:7 168:3 

172:10 185:13 191:16 

sorts 42:15 106:14 

sounds 93:2 

source 103:17 111:9 

Southern 1:14,21 

space 133:16 139:19 

190:2 

speak 19:3 60:15 140:9 

140:10 144:19 

speaker 24:2 130:8 

139:4 140:14 152:21 

speaking 53:12 107:13 

144:4,7 

special 8:6 12:19 

specialists 25:17 

specialized 25:13 

105:21 

specific 17:18,20 29:6 

30:12 32:6 33:21 36:1 

66:18 79:18 89:18 

112:1 

specifically 131:9 

138:15,17 

spectrum 58:16 

speech 149:14 

speeches 77:15 

speed 92:9 

spend 58:12 131:14 

136:4 172:21 

spending 12:14 

spiked 98:13 

spin 93:19 

split 144:2 

SPOE 21:2 80:17 

132:18 

SPOEs 48:13 

spot 69:4 

spotted 43:8 

spread 94:17 122:2 

spreads 98:6,12 99:1 

spring 116:18 

square 171:5 

SRAC 100:11 130:15 

134:9 

SRB 8:21 

stability 3:6,12 7:17 

11:11 12:17,22 15:10 

20:6 24:17 25:1 26:13 

35:13 90:15 101:2 

130:9 131:12 132:17 

136:11 137:6 140:18 

143:12 144:5 150:14 

153:20 182:5 

stabilization 166:9 

stabilize 173:3 

stabilizing 46:8 94:12 

96:4,5,6 97:1,16 

167:10 

stable 189:21 

stadium 61:22 

staff 14:9 17:2 18:10,21 

21:21 22:15 25:13 

27:9 33:14,20 34:18 

40:21 41:4,12 74:15 

75:5,5,9 139:14 

staffs 85:21 

stage 19:22 91:2 158:8 

162:8 

stages 151:19 156:12 

157:8 

stakeholder 95:17 

stakeholders 76:11 

77:7,12 79:4,8 87:9 

stand 148:20 184:6 

standard 136:10 144:14 

144:15 158:18 

standardized 182:8 

standards 114:17 

144:17 147:21,22 

148:1 164:9 

standing 58:9 59:3 72:8 

standpoint 33:2 107:17 

stands 30:17 141:8 

Starke 3:13 70:22 

start 26:7 47:5 48:8 

49:11 100:8 116:20 

129:16 144:18 145:13 

150:1 173:19 

started 16:22 49:12 

54:2 87:11 95:20 

102:7 130:15 

starting 46:18,19 78:7 

78:11 85:22 87:16 

107:11 117:1 126:17 

164:17 

starts 26:5 47:5 

state 63:7,17 66:20 

statement 17:5 18:1 

24:20 93:22 94:7,9,13 

96:6 

statements 17:3 18:21 

51:17 96:4,9 

states 1:14,20 7:15 

12:11 34:13 47:13 

87:16 184:7 188:12 

statutory 42:21 188:15 

stay 127:16 

stays 110:6 

steering 137:4 

stems 148:18 

step 79:14 106:21 

152:18 153:4,12 

154:22,22 161:15 

steps 8:21 31:17 71:18 

71:22 74:4 75:20,20 

76:14 100:16 154:4 

167:3,7 175:14 

Stern 9:6 

stick 16:17 

sticky 119:20 120:1 

stock 97:6 101:20 

stop 27:20 37:4 112:5 

162:11 164:18 

stopped 92:20 

story 71:9 77:19 

straightforward 24:16 

strange 143:9 

strategic 101:11 107:13 

108:6 

strategies 31:10 108:10 

113:10,13 

strategy 20:22 21:2 

30:6 71:14 72:3 77:10 

80:16 84:1 90:19 

104:11 105:11,19 

113:4 124:10 125:7,8 

125:9 126:9 129:9 

185:4,12 

streams 136:14 139:16 

Street 1:10 

strength 191:11 

strengthening 52:1 

126:17 

strengths 9:17 

stress 32:15 46:19 47:2 

48:3,3 58:10,22 94:8 

97:17 112:22 117:2 

124:6 132:10 134:15 

146:16 147:11 150:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
213 

150:19 157:20 158:2 

159:16,18 161:7 

165:22 166:18 167:13 

169:11 170:4,11 

180:15 181:7 

stressed 168:7 

stresses 26:6 119:2 

stressful 159:16 

strides 21:12 

strikes 56:10 92:11 

115:13 165:8,10 

strong 42:5 45:6 147:22 

stronger 38:14 188:17 

strongly 53:5 

structural 21:1 

structure 28:14 49:10 

54:12 104:20 108:11 

108:14 128:11 

structured 31:3 

structures 72:1 135:6 

148:11 

struggle 40:18 

stuck 127:14 

studies 2:6 98:16 

study 95:9 98:17 

stuff 83:16 98:14 

stupid 98:10 

stylized 89:1 

subject 34:22 66:12,16 

164:22 167:19 

submission 112:3 

submissions 126:18 

submit 36:4 

submitted 34:22 

subordinated 82:3 

Subsequent 20:22 

subsidiaries 104:10 

106:9 

subsidiary 104:21 

substantially 64:7 

substantively 18:10 

184:6 

success 76:6 

successful 36:14 

120:10 

successor 9:10 

sufficiency 138:14 

158:10 

sufficient 153:9 156:22 

161:21,22 

suggest 181:16 

suggested 158:15 

suggestion 65:20 

suggestions 145:16 

Suisse 2:1 8:4 

Sullivan 1:18 

summaries 89:13 

summary 18:16,18,19 

summer 88:7 139:10 

sunny 89:2 

Sunshine 17:6,10 

super 64:15 67:5 

superb 183:9 

supervise 65:15 

supervisible 182:20 

supervision 1:16 3:7,8 

3:10,15,16 4:13 6:16 

9:15 10:2 13:4 16:9 

16:15 22:4 24:9,12 

25:9 26:16 28:4,11,16 

28:20 30:22 32:20 

33:6 37:9 38:14 39:15 

39:20 40:8 42:13 

50:18 55:9 58:12 

141:3 143:14 187:14 

188:1 

supervisor 39:8 43:10 

43:15 44:6,7,10 46:5 

143:22 

supervisors 25:15 

36:18 44:16 46:2 

48:16 49:16 166:5 

184:18 

supervisory 9:19 21:22 

24:21 26:3 27:1,5 

29:7,15 31:1,9 32:2 

32:22 33:14,20 34:3,7 

34:12 35:8 37:17 

40:10,16,21 41:12 

42:5,11,21,22 44:1,14 

45:2 48:2 51:4 52:19 

59:15 67:12 75:17 

120:15 134:19 136:1 

136:12 187:16 

supplement 33:21 

155:8 

support 32:7 35:9 

99:13 131:18 136:3 

137:21 175:15 

supporting 29:15 36:7 

supports 29:5 76:2 

108:11 

surprise 14:19 

survive 190:21 

Susan 3:7 70:21 78:2 

86:5,14 

suspect 140:16 

swaps 146:5 

swiftly 107:11 

swing 61:21 

Switzerland 143:8 

synergies 9:22 

system 2:5 9:20 18:9 

23:15 24:17 37:15 

85:5,8 101:6 127:12 

128:3 140:22 141:8 

141:17 145:19 147:12 

151:22 153:19 159:21 

systemic 1:3 3:9 5:20 

7:1,10 8:5 10:8 12:5,9 

12:12 19:17 20:15,19 

21:12 25:6 29:2,10,10 

29:14 31:20 50:11 

61:14 73:19 99:2 

100:14 117:11 118:11 

118:20 124:3 127:10 

131:6 133:19 137:16 

141:6,14 145:20 

146:4 148:2 158:11 

158:16 160:6,10 

161:7 163:20 185:20 

186:3 187:20 

systemically 14:15 15:9 

32:4 151:20 168:11 

systems 57:18 143:14 

143:14 144:12,17 

systemwide 137:17 

T

table 16:18 58:11,22 

69:21 

tables 58:4 

tabletop 60:15 

tabletops 74:5 

tackle 131:3 

Tahyar 2:21 8:1 48:13 

86:2 119:4 122:8 

taken 31:17 53:5,21 

57:9 71:18,22 76:14 

100:16 153:6 169:2 

182:1 191:6 

takes 75:10 120:22 

156:8,9 

tale 115:2 132:10 

160:14 

talk 10:4,18 11:21 25:16 

25:17 30:1 36:2 41:4 

46:9,12 53:4 68:14 

71:7 72:7 75:15,21 

77:14,16 95:15 99:22 

117:14 141:11 143:4 

145:3 148:14 176:18 

176:21 179:10 

talked 41:17 97:12 

103:5 124:15 132:19 

133:21 139:18 172:10 

174:15 184:17 187:15 

talking 56:3 68:21 

89:14,19 93:9 104:8 

130:2 136:5 144:20 

159:22 172:17 182:22 

184:4 188:4 

targeted 37:11 82:15 

task 10:17 182:4 

tasks 114:13 

tax 122:11,14 

teach 56:13 

teaching 83:15 

team 39:17 

teams 26:14 39:4 74:18 

tear 150:3,8 157:8 

190:1 

tearing 150:15 152:1 

tease 162:9 

technical 19:3 111:9 

technology 2:20 64:12 

teleconference 3:20 

tell 13:15 49:2 71:8 

77:19 85:1 95:6 99:3 

176:18 

telling 84:20 189:9 

templates 74:2 

temporary 103:17 

temptation 79:12 

ten 58:1 78:10 97:4 

151:8 

ten-plus 97:17 

tend 104:19 106:5 

127:16 159:3 

tends 107:10 

tension 40:15,15 41:8 

46:1,3 

tensions 38:19 154:5 

term 8:17 

terms 9:2 59:16 78:4 

83:14 103:11 106:12 

114:22 115:12,19 

127:10,15 129:8 

146:16,22 169:12 

171:11 179:17 186:16 

terrible 118:13 

terrific 165:6 167:18 

terrorist 90:5 

test 5:21 20:16 34:8 

98:21 102:18 108:10 

tested 48:17 94:2 

186:21 

testing 21:8 48:3,3 

60:20 73:10 97:18 

117:3 134:2 167:2 

tests 94:15 97:3 125:2 

Tetrick 3:14 70:20 

99:22 100:2,7 112:17 

115:17 123:19 128:18 

thank 6:8 13:10,21 14:7 

16:6,11,12 28:4 70:15 

71:1 99:17 127:5 

130:12 140:11 142:14 

164:18,19 165:5 

167:14 183:8,15,16 

183:20 191:19 192:1 

192:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
214 

thanks 21:10 28:5 70:2 

100:2 142:16,21 

167:17 172:9 183:14 

183:15 

that'd 128:4 

things 14:12 40:20 50:7 

55:6 56:21 57:10 58:5 

61:7 62:4 63:11 64:1 

64:5 69:13 78:12 80:6 

80:8 82:18 83:7 91:17 

91:22 95:3 99:19 

106:14 109:14 116:2 

116:18 123:18 126:14 

127:11 143:4 144:2 

145:6 166:7 175:2 

177:17 179:16,18 

181:19 185:3 191:15 

third 23:16 27:16 59:4 

124:15 134:15 140:1 

thought 13:7 38:20 

69:10 143:21 144:18 

158:7 160:20 190:5 

thoughtful 51:7 119:5 

thoughtfulness 86:6 

thoughts 22:7 41:2 

56:4 131:2 158:7 

thousands 108:18 

threaten 20:5 

threatening 101:1 

threatens 35:13 

three 9:13,22 11:13 

29:1,5 31:7 57:17 

66:13 89:21 124:11 

159:12,18 163:3 

throw 56:18 114:11 

throwing 57:2,2 

tie 68:17 

tied 152:9 

tightened 124:1 

Tim 1:15 6:13,18,20 7:2 

14:2 50:12 

timeframe 100:4 

timeline 107:22 113:15 

timely 75:11 111:20 

184:9 

times 93:5 130:13 

132:19 139:10 148:22 

149:3 151:9,10 163:3 

169:10,11 170:10 

191:13,14 

timing 86:11 

TIMOTHY 2:11 

Title 6:20 10:8,13 21:7 

22:16 23:6 30:7 33:12 

33:19,22 34:4,5,9,12 

35:3,3,8 36:4,5,8,21 

38:2 47:20 52:17,19 

54:1,4 67:4 70:17 

71:4,10,21,21 72:5,6 

73:6,7,9,11,14,16,18 

73:21 76:18 77:14 

78:8,16 80:11,13 

82:10 83:1 86:9,10 

88:21 89:13 92:15 

103:5 105:8 107:1 

117:4,5 118:22,22 

126:22 127:20 130:7 

130:14 132:13 133:17 

133:20,22 134:1 

135:2,18 186:4,6 

187:19 

Titles 20:6 

TLAC 94:16,16 98:5,12 

127:20 178:19 186:13 

today 16:13 17:8 19:14 

19:15,22 21:9,15 

22:15 63:2 71:5 78:13 

82:20 87:9 94:6 95:18 

119:12 130:13 131:14 

132:19 134:16 139:19 

140:10 142:15 144:18 

184:13 189:5 191:20 

today's 17:3 144:3 

188:21 

told 176:16 

tomorrow 86:13 143:3 

164:8 

tool 82:9 138:15 

tools 6:21 20:13 29:17 

29:20 35:16 57:13 

63:13 66:18 115:11 

122:9 132:7,12 133:4 

133:8 153:8,10 

157:18 167:11 173:6 

184:16 190:14 

top 7:6,14 89:10 

topic 22:21 23:9,17,19 

37:3 43:19 71:4 76:4 

89:19 121:10 127:4 

130:14 

topics 22:16 37:21 

70:11 79:20 80:1 89:6 

89:6 

totally 92:18 

touch 105:17 110:10 

145:15 

touched 107:16 111:3 

124:8 134:9 

tough 57:8 67:13 

167:18 

toughest 107:3 

tower 55:8 

trade 41:18 148:21 

177:9 190:9 

tradeoff 132:8 

tradeoffs 138:18 

traditional 104:22 

117:20 141:21 

Traille 3:16 36:2 130:7 

130:12 184:12 

train 60:14 

trained 60:2 

training 56:17 57:6 

tranche 156:15 

transfer 21:4 108:18 

transferred 116:11 

transformation 148:10 

transmission 150:18 

transmit 147:11 

transmitters 87:13 

Transparence 92:22 

transparency 10:12 

22:17,21 70:18 71:8 

76:5 78:4,8 86:17,17 

90:1,4,14 91:11 93:13 

147:1 180:9,13 181:2 

182:9 

transparent 76:17 

78:14,19 79:10,21 

80:19 81:18 88:5,14 

90:7 97:21 

trapped 73:5 

Treasury 9:5 49:6 50:4 

67:8 75:6 103:20 

Tremendous 9:22 

tricky 102:3 

tried 39:12 115:4 

trigger 41:2 46:13 

triggered 46:4 

triggers 47:4,22 59:14 

159:8 

troops 56:9 

trouble 96:7 184:8 

true 74:18 114:18 

142:20 

truly 72:15 

Trust 7:6 

try 5:15 10:15 52:11 

62:18 63:12,16 67:21 

68:16 74:6,10 113:13 

127:16 140:6 159:10 

165:11 188:13,14,16 

trying 43:6,12 46:6 53:6 

57:3 74:3 96:20 185:7 

Tuck 9:6 

turn 16:7 27:20 28:2 

34:5 39:2,7,16 78:1 

80:12 99:22 100:7 

123:20 126:10 130:11 

140:8,14 

turned 11:6 

turners 68:13 

turning 75:3 126:2 

turns 58:2 

tweet 87:4 

tweets 84:10 

twin 54:13 

two 10:6 17:3 22:15 

27:7 39:4 41:11 42:10 

42:14 53:21 57:17 

58:5 64:5 90:13 91:2 

94:5 96:12 110:9 

111:12 114:11 120:22 

139:22 148:12,21 

155:11 158:18 160:1 

165:20 175:2 

twos 57:10 

type 103:4 108:12 

125:17,18,21 126:1 

129:3 132:10 

types 53:19 57:6 64:22 

109:13 168:2,5 

typic 26:21 

U

U.S 1:17 9:20 11:13 

15:20 20:5 24:17 

35:13 60:18,18 

103:20 104:10 122:22 

127:12 131:11 135:10 

142:5 

ultimate 5:21 53:15 

185:20 

ultimately 30:16 103:19 

185:4 

uncapped 189:22 

uncertain 59:13 

uncovered 41:20 

underexplored 102:4 

undermined 51:16 53:4 

underpinned 93:13 

underpinning 94:8 

underscore 67:3 

Undersecretary 9:4 

understand 10:17 26:9 

76:11 77:12 83:4 

85:13,14 94:4,20 95:6 

95:17 97:10,15 

135:15,22 140:5 

153:12,13 173:3 

176:12 

understandably 100:13 

understanding 10:16 

30:15,16 33:6 34:4 

36:13 71:11 73:17 

75:10,19 76:15 77:7 

111:6 134:4,22 

135:17 136:16 182:11 

184:5,19 

understands 68:14 

97:9 99:14 

understood 95:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
215 

103:9 178:3 

undertake 36:14 110:6 

undesignated 15:8 

undesirable 101:16 

unfair 52:6 156:1 

unfairly 53:9 

unfold 59:18 

unfortunate 63:19 

unfortunately 17:1 56:8 

unhelpful 92:18 

uninsured 102:14 

109:17 114:3,4,7 

118:9 119:18 

unintended 85:3,22 

146:20 

Union 3:5 

unique 26:9 28:14 

42:20 43:6 106:15 

139:13 

United 1:14,20 7:15 

12:11 184:7 188:12 

units 184:7 

University 2:3 165:3 

unknowns 185:14 

unlimited 171:3 

unlovely 169:7 

unproductive 92:19 

unrelenting 83:9 

unsecured 102:14 

untouched 150:11 

update 4:16 19:16 

21:21 70:17 

updated 123:5 

updates 63:22 

ups 190:1 

upstairs 192:4 

US/UK 142:4 

use 6:22 19:6 24:21 

35:9 57:13 64:2 73:6 

75:8 78:15 82:15,16 

104:4 118:19 124:14 

132:12 138:11 146:2 

153:7,10 170:13 

180:3,18 

useful 36:7 56:22 

134:14 

user 190:8 

users 161:5 174:9,10 

usual 134:15 161:9 

utilization 10:9 

V

validate 73:11 

valuable 33:18 68:22 

111:6 140:4 

valuations 110:14,22 

value 5:17 6:7 34:11 

106:2 108:8 

variation 157:7 190:15 

various 21:1 60:7 

vast 67:22 

venue 139:12 

venues 77:16,17 139:3 

version 144:16 

viable 8:13 

vice 2:1,4 8:3 

victory 15:18 

video 3:20 

view 48:6,10 56:6 86:3 

99:13 123:1 150:14 

153:19 176:9 178:22 

180:17 

viewed 6:1 

viewpoint 178:5 182:1 

views 170:3 

virtually 5:8 12:20 

virtuously 122:3 

visible 142:18 

vital 5:17 

vulnerabilities 29:8 

30:11 33:7 

W

waiting 93:11 174:21 

walk 21:18 23:1 

Wall 3:17 16:22 

walls 69:14 

WaMu 116:9 

wanted 6:11 130:13 

133:11 140:12 175:1 

wants 178:8 

war 56:19 68:20 

wargaming 167:11 

warning 95:2 

warrants 23:21 

Washington 1:10 

101:18 120:9 

wasn't 123:13 

watched 62:1 

waterfall 132:7 149:14 

150:7 151:19 154:14 

155:13 156:10,12,17 

162:19 166:12 171:18 

182:7 

waterfalls 131:19 168:6 

wave 147:4 

waves 57:12 

way 45:9 51:20,21 

54:16 57:7 60:6,21 

64:6 71:9,9,10 72:15 

77:18 79:14 85:14 

86:10 90:21 92:3 94:9 

97:21 107:3 111:21 

113:4 116:19 117:21 

121:18 124:2 147:21 

153:12 154:13 155:4 

157:13 162:12 166:8 

168:19 171:18 174:10 

178:10 181:5,20 

184:9,17 

ways 7:10 11:3 15:5 

22:13 52:18 56:18 

57:13 71:8 74:16 

76:16 86:20 103:22 

115:10 125:12 147:16 

weaknesses 30:11 

Webex 19:6 

website 18:17 78:6 

88:20 

websites 76:21 77:1 

WEDNESDAY 1:7 

weekend 108:18,21 

111:21 113:17 116:1 

165:10 

weeks 41:11 48:5 50:10 

168:21 

weigh 181:22 

weighed 132:16 

welcome 4:10 5:4 28:6 

went 21:16 61:22 88:12 

98:8 129:19 167:21 

182:5 192:6 

Wharton 2:2,3 

wheel 96:16 

White 43:21 

wide 20:15 108:19 

widely 147:11 

wider 71:20 72:3 101:5 

101:7 124:6 151:21 

Willkie 1:13 

Wilson 2:1 8:3 57:21 

167:15 

Wilson's 99:13 

wind 151:18 171:4 

windup 61:20 62:3 

wipe 151:12 175:2,7 

wiped 163:9 175:19 

wiping 168:9 

wisely 69:2 

wished 63:21 

woke 11:8 

wonder 51:8 56:17 

57:12 

wondered 94:14 

wondering 42:7 51:19 

81:17 123:6 168:1 

wood 54:19 

word 143:11 150:20 

162:12 170:13 

wording 118:18 

words 148:20 149:2 

169:9 

work 6:6 10:5,7,12 

11:22 15:16 16:2 

19:16,20 21:6,21 22:5 

23:13,14,21 26:8,18 

26:20,20 27:1 29:7,21 

35:2,8,14 36:10 37:13 

38:1,13 39:19 45:4 

47:20 48:18 60:17 

63:11,14 72:5 74:21 

75:3,21 76:18 77:5 

78:7,21 80:12,17 

81:15 86:15 88:21 

90:20 93:18 94:10 

98:1 103:4 109:15 

128:4 130:19 135:10 

136:4,5,14,15,20 

137:1,7 138:6,10,20 

139:2,14,16 141:18 

142:2 143:4 144:10 

158:9,13,15 162:8 

164:17 166:21 168:15 

169:13 183:17 184:17 

185:2,11 188:11 

191:9,17 

worked 32:20 135:15 

135:22 164:2 

working 25:13 34:19 

39:17 49:5 73:22 

78:10 98:19 137:6 

138:22 141:21 142:4 

works 26:8 41:9 83:5 

85:9 

workshops 137:11,15 

world 62:6 75:18 78:22 

87:4 91:16 92:13 93:4 

161:13 174:3 175:1 

188:22 

worried 14:19 177:1 

worry 90:9 127:11,17 

worrying 162:13 

worse 154:9 155:3 

163:7 171:1,7,10,21 

175:4 

worth 47:19 

would've 143:1 

wouldn't 123:13 132:4 

163:21 190:22 

wrestle 171:20 

wrestled 121:17 170:21 

writ 64:10 

writing 171:6,19 

writings 177:19 

written 155:16 157:11 

157:14 

wrote 182:3 

X

Y

year 72:15 126:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
216 

127:4 138:8 139:11 

139:11 145:14 158:14 

192:3 

year's 68:19 

years 5:11,14 25:3 

32:19 44:11 51:18 

56:14 57:17,17 58:1 

72:16 78:11 97:4,17 

99:10 115:3 120:22 

135:12 137:8 141:1 

143:18 166:21 170:22 

yesterday 56:9 

yield 74:7 

York 1:14,21 

Z

0

08 55:1 61:4,9,14,18 

62:14 

1

1.4 191:14 

10 109:11 146:6 179:21 

100 104:9,12 

11 15:22 

11:14 129:19 

11:20 129:16 

11:26 129:20 

12 59:13 

12:33 192:6 

129 4:18 

14 100:8 102:8 

15 104:5 

16 106:14 

165(d) 34:11 

17th 1:10 

18 59:13 

18th 18:7 

191 4:21 

1994 87:5 

2

2 4:16 126:20 

20 109:11 

2008 12:6 20:1 48:20 

56:14 91:14 141:7 

187:7 

2009 147:8 

2011 20:8 

2013 77:8 81:15 154:15 

2015 137:1 

2017 139:22 182:5 

2018 5:11 139:10 

2019 26:1 

2020 5:9 23:18 35:19 

62:12,19 95:10 

130:16 131:7 137:10 

137:19 168:17 

2021 137:10 

20210 140:1 

2022 1:7 18:7 

21 60:10 

24 4:14 59:13 111:15,17 

250 104:15 105:12,12 

3

3 4:18 24:14 126:20 

35 25:3 

4

4 21:18 191:13 

40 109:12,17 118:8 

146:9 

5

5 4:11 

50 109:18 118:8 

500 151:8 

550 1:10 

6

6 59:13 

60 146:5 

7

7 33:12 

70 4:16 

8

9

9 1:7 

9:00 1:9 

9:04 5:2 

95 104:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
217

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Systemic Resolution

Advisory Committee

Before: FDIC

Date: 11-09-22

Place: Washington, DC

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate DPNQMFUFrecord of the 

proceedings. 

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

7+671:67(

(202) 234-4433 :$6+,1*721'& www.nealrgross.com