, data, and analysis underlying the proposed reforms. of course, this process must also incorporate the opportunity to solicit meaningful public comment. it is absolutely imperative that stakeholders - including bankers - share their views with policymakers on regulatory reform proposals. all of the comments, data, and analysis enable policymakers to make informed decisions throughout the rulemaking and proposal process. information about the intended and unintended impacts of these initiatives is especially informative. if the fed and other banking agencies have not provided sufficient context, data, and analysis to satisfy stakeholder questions or concerns, commenters should provide that perspective as well. as you know, there are a number of regulatory rulemakings under consideration by the board and the other bank regulatory agencies. some have already been published for comment including the proposal to implement basel iii " endgame " by significantly expanding capital requirements and bringing the threshold for compliance down to include all banks over $ 100 billion in assets from only the largest gsib banks, and the expansion of the long - term debt requirement from only the largest banks again to all 2 / 3 bis - central bankers'speeches banks over $ 100 billion in assets. still other proposals have not yet been published or moved to the next stage of the rulemaking process, including the community reinvestment act rulemaking, the further consideration of climate guidance, and others. the board has also publicly indicated it may propose additional revisions in the future to regulation ii. i recognize that in some instances, multiple, interrelated proposals out for comment at the same time may complicate or even frustrate the ability to provide meaningful comment. even so, i strongly encourage your participation to inform the rulemaking process. this audience is uniquely positioned to provide real - world feedback about the intended and unintended consequences of agency rulemakings. i look forward to all of the stakeholder comments and feedback throughout the current and upcoming regulatory rulemaking processes. i look forward to our conversation. 1 the views expressed here are my own and not necessarily those of my colleagues on the federal open market committee or the board of governors. 3 / 3 bis - central bankers'speeches

the tools we have are available and prepared federal reserve act, 12 u. s. c. 347b ; and dodd - frank act, 12 u. s. c. 5465 ( b ). for designated financial market utilities, this would require an affirmative vote by a majority of the board after consultation with the secretary of the treasury. - 7with trained and experienced staff ready to deal with the evolving risks of liquidity stress and pressure. finally, are there changes that need to be made to support contingency liquidity on the borrower side? one prominent issue that has come to light recently is whether there should be some form of pre - positioning requirement — whether banking institutions should be required to hold collateral at the discount window, in anticipation of the need for accessing discount window loans in the future. 14 arguably, requiring pre - positioning at the discount window may serve a variety of purposes. one use case is ensuring the system is efficient enough to allow borrowers to access discount window loans in a timely manner, including by getting collateral to the discount window to support loans. we have much work to do on this front. to fulfill its function, the discount window must be able to provide liquidity quickly. the failure of svb demonstrated how rapidly a run can occur and revealed that the discount window must be able to operate in a world in which new technologies, rapid communications, and the growth of real - time payments may exacerbate the speed of a bank run. identifying and mitigating the technology and operational issues that affect the discount window should go a long way to addressing this concern. understanding that these problems exist and requiring pre - positioning of collateral at the discount window may not fully address any technological and operational shortcomings of the discount window. see acting comptroller of the currency michael j. hsu, “ building better brakes for a faster financial world ” ( speech at the columbia law school, january 18, 2024 ), https : / / www. occ. gov / news - issuances / speeches / 2024 / pubspeech - 2024 - 4. pdf ; and working group on the 2023 banking crisis, bank failures and contagion : lender of last resort, liquidity, and risk management ( washington : group of thirty, january 2024 ), https : / / group30. org / images / uploads / publications / g30 _ lessons - 23 - crisis _ rpt _ final.