Daniel K Tarullo: Dodd-Frank Act Implementation
Testimony by Mr Daniel K Tarullo, Member of the Board of Governors of the Federal
Reserve System, before the Committee on Banking, Housing, and Urban Affairs, US Senate,
Washington DC, 6 December 2011.
* * *
Chairman Johnson, Ranking Member Shelby, and other members of the committee, thank
you for the opportunity to testify on the Federal Reserve s implementation of the Dodd-Frank
Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).
The Federal Reserve s approach to Dodd-Frank implementation
Needless to say, implementation of the Dodd-Frank Act has been, and continues to be, a
formidable task. At the Federal Reserve, hundreds of staff members are contributing to
Dodd-Frank projects. We have issued 29 final rules, public notices, and reports already and
we have another 13 rules underway. All told, we expect the Board will issue approximately
60 sets of rules and formal guidelines as part of its implementation efforts. We are working
diligently to complete the remaining rules. The challenge arises from the sheer number of
studies, rules, and other implementation tasks the Act requires the Federal Reserve to
produce in a relatively short period of time. Moreover, much of the work involves the more
time-consuming process of joint rulemakings or coordination with other agencies, all of which
are facing similar demands.
For all the variation and complexity in our Dodd-Frank implementation responsibilities, we
have several unifying goals.
First and foremost, we want to get it right. This means implementing the statute faithfully, in a
manner that maximizes financial stability and other social benefits at the least cost to credit
availability and economic growth. To achieve this balance, we have assembled
interdisciplinary teams for our significant rulemakings, bringing together economists,
supervisors, legal staff, and other specialists to help develop sensible policy alternatives and
to help avoid unintended consequences.
Second, in addition to a thorough internal analytic process, we also are committed to
soliciting and considering the comments of others. We are, of course, consulting extensively
with other financial regulatory agencies, both bilaterally and through the Financial Stability
Oversight Council. The interagency consultation process has included staff discussions
during the initial policy development stage, sharing of draft studies and regulatory text in the
interim phases, and dialogue among agency principals in the advanced stages of several
rulemakings.
Along with the other agencies testifying today, we have gone well beyond the formal
consultation requirements of Dodd-Frank. Members of the Board, as well as staff at senior
levels, have regular meetings with their counterparts at other agencies to discuss
implementation issues of common interest. Consultations at multiple levels and across
agencies help to improve the consistency of regulation across the banking industry and
reduce the potential for overlapping regulatory requirements. In addition, these consultations
help highlight the interaction among different rules under development by these agencies, as
well as the interplay between proposed policy alternatives and existing regulations.
We are also trying to make our rulemaking process as fair and transparent as possible, with
ample opportunity for the public to comment. During the proposal stage, we specifically seek
comment from the public on the costs and benefits of our proposed approach, as well as on
alternative approaches to our proposal. We believe strongly that public participation in the
rulemaking process improves our ability to identify and resolve issues raised by our
regulatory proposals. We generally provide the public a minimum of 60 days to comment on
all significant rulemaking proposals, with longer periods permitted for especially complex or
significant proposals.
Federal Reserve staff have participated in more than 300 meetings with outside parties and
their representatives, including community and consumer groups. To promote transparency
in the rulemaking process, we include in the public record a memorandum describing the
attendees and subjects covered in any meetings involving non-governmental participants at
which Dodd-Frank rulemakings are discussed. These summaries are posted on the Federal
Reserve Board s website on a weekly basis, as are updates on Board rulemakings and other
Dodd-Frank initiatives.
Third, in drafting regulations, we have made special efforts to identify and, to the degree
possible consistent with statutory requirements, minimize the regulatory burden on smaller
entities. We conduct an assessment that takes appropriate account of the potential impact a
rule may have on small businesses, small governmental jurisdictions, and small
organizations affected by the rule, in accordance with the Regulatory Flexibility Act. We have
paid particular attention to reducing the regulatory burden on community banking
organizations. For example, the Federal Reserve has established community depository
institution advisory councils at each of the 12 Federal Reserve banks. These councils gather
input from community depository organizations on ways to reduce regulatory burden and
improve the efficiency of our supervision, and also collect information about the economy
from the perspective of community organizations throughout the nation. A representative
from each of these 12 advisory councils serves on a national Community Depository
Institution Advisory Council that meets semiannually with the Board of Governors to bring
together the ideas of all the advisory groups.
The Board of Governors has also established a subcommittee of our regulatory and
supervisory oversight committee for the express purpose of reviewing all regulatory matters
from the perspective of community depository organizations. These reviews are intended to
find ways to reduce the burden on community depository organizations arising from our
regulatory policies without reducing the effectiveness of those policies in improving the safety
and soundness of depository organizations of all sizes.
Fourth, we are working to complete our Dodd-Frank projects as quickly as possible while
meeting the three objectives already stated. There is obviously considerable value in
providing as much clarity as possible as soon as possible to financial markets and the public
about the post-crisis financial regulatory landscape.
Capital regulation after Dodd-Frank
The breadth of Dodd-Frank s provisions reflects in part that the pre-crisis regulatory regime
had been insufficiently attentive to a variety of risks from a variety of sources. But we should
not forget that strong capital requirements remain the most supple form of prudential
regulation, because they can provide a buffer against bank losses from any source. To put it
simply, the best way to avoid another TARP is for our large regulated institutions to have
adequate capital buffers, reflecting the damage that would be done to the financial system
were such institutions to fail.
Implicitly, passage of Dodd-Frank was a criticism of the specific features of capital regulation
that prevailed during the pre-crisis period. Basel I capital requirements relied almost
exclusively on capital ratios that were snapshots of balance sheets and thus frequently a
lagging indicator of a bank s condition. The kind of capital that qualified for regulatory
purposes was not uniformly reliable as a buffer against losses. Moreover, capital
requirements were set solely with reference to the balance sheet of each firm individually,
with little attention to the economy-wide impact of financial stress at large institutions. And,
most fundamentally, capital requirements had simply been too low, in general and with
respect to the risk-weightings of certain assets.
Strong capital requirements must be at the center of the post-crisis period regulatory regime.
The Federal Reserve is integrating the specific capital-related provisions of Dodd-Frank into
its overall capital program. That program has three basic components: improving capital
regulation at the level of individual firms; introducing a macroprudential or system-wide
element to capital regulation; and conducting regular stress testing and capital planning. I will
discuss each of the three areas briefly.
The first component is to improve the traditional, firm-based approach to capital regulation.
This work is mostly related to standards developed in cooperation with other supervisors in
the Basel Committee on Banking Supervision, but there is also a Dodd-Frank element. The
"Collins amendment" in Dodd-Frank provided a safeguard against declines in minimum
capital requirements in a capital regime based on bank internal modeling. The so-called
Basel 2.5 agreement strengthened the market risk capital requirements of Basel II. Basel III
upgraded the quality of regulatory capital, increased the quantity of minimum capital
requirements, created a capital conservation buffer, and introduced an international leverage
ratio requirement. In the coming months the banking agencies will be jointly proposing
regulations consistent with Basel 2.5 and Basel III.
The second component of our capital program is to introduce a macroprudential element to
capital regulation. Section 165 of the Dodd-Frank Act mandated that the Board establish
enhanced risk-based capital standards for large bank holding companies. This mandate
complements the Basel Committee s effort to develop a framework for assessing a capital
surcharge on the largest, most interconnected banking organizations based on their global
systemic importance. Both the Dodd-Frank provision and the Basel systemic surcharge
framework are motivated by the fact that the failure of a systemically important firm would
have dramatically greater negative consequences on the financial system and the economy
than the failure of other firms. In addition, stricter capital requirements on systemically
important firms should help offset any funding advantage these firms derive from their
perceived status as too-big-to-fail and provide an incentive for such firms to reduce their
systemic footprint.
Of course, Dodd-Frank requires the Federal Reserve to impose more stringent capital
requirements on all bank holding companies with assets of $50 billion or more, not just the
U.S. firms that will appear on the Basel Committee s list of global systemic banks. No
decision has yet been made as to whether the more stringent capital requirement to be
applied to large U.S. banking firms that are not on the eventual list of global systemic banks
will be in the form of a quantitative surcharge. However, analysis of the systemic footprints of
these other U.S. bank holding companies suggests that even if surcharges were to apply,
their amounts would be quite modest, at least based on the current characteristics of these
bank holding companies.
The third component of the Federal Reserve s capital program is to establish regular,
firmspecific stress testing and capital planning. Dodd-Frank creates two kinds of stress-testing
requirements. First, it mandates that the Federal Reserve Board conduct annual stress tests
on all bank holding companies with $50 billion or more in assets to determine whether they
have the capital needed to absorb losses in baseline, adverse, and severely adverse
economic conditions. Second, it requires both these companies and certain other regulated
financial firms with between $10 billion and $50 billion in assets to conduct internal stress
tests.
We will be implementing the specific stress-testing requirements of Dodd-Frank beginning
later in 2012. However, in the interim we are using a modified form of stress testing as part of
the annual capital planning process we have established for large bank holding companies.
Last month we announced the parameters and process for this year s capital review, which
will be completed in March, at which time the results of the stress test will be publicly
reported for the 19 largest firms.
Conclusion
For all the work that has already gone into implementing Dodd-Frank, both at the Federal
Reserve and at the other regulatory agencies, there is still considerable work to do. Final
regulations implementing some of the Act s most important provisions, such as the "living
will" requirement and the Collins amendment, are now in place. Measures to implement other
prominent provisions, such as the Volcker rule, have been proposed, but are not yet in final
form. Still others, such as the section 165 requirements, have not yet been proposed.
Whether completing work on proposed regulations, or moving forward with those yet to be
proposed, the Federal Reserve will continue to pursue the four goals I noted earlier.
Thank you very much for your attention. I would be pleased to answer any questions you
might have for me.
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