##s more quickly. before i suggest how, let me emphasize that here i am speaking for myself only, since the full board will address these issues only in future orders. we have already suggested a limited presumptive safe harbor where an acquisition involves less than $ 2 billion in assets or results in a firm with less than $ 25 billion in total assets. 38 personally, i would set the size of the resulting firm higher than $ 25 billion, but somewhat lower than the $ 50 billion dodd - frank threshold over which a firm is subject to special prudential standards. at the other end of the spectrum, i would urge a strong, though not irrebuttable, presumption of denial for any acquisition by any firm that falls in the higher end of the list of global systemically important banks developed by the basel committee for purposes of assessing board of governors of the federal reserve, capital one financial corporation, mclean, virginia, order approving the acquisition of a savings association and nonbanking subsidiaries ( pdf ), frb order no. 2012 - 2 ( feb. 14, 2012 ) at p. 28. board of governors of the federal reserve, order approving acquisition, pp. 28 – 29. board of governors of the federal reserve, order approving acquisition, p. 30. bis central bankers ’ speeches capital surcharges. 39 firms at the lower end of the basel committee list, or that u. s. authorities may later designate as domestic systemically important banks under a parallel basel committee exercise, 40 might have a slightly less robust, but still significant presumption against acquisitions. i would not apply the presumption in the case of certain de minimis acquisitions or in cases where asset dispositions were judged to offset any increase in systemic risk from the proposed new acquisition. it is reasonable to ask why these negative presumptions are appropriate, given my general view that the absence of both experience and consensus theory make a case - by - case approach necessary. one answer is that, notwithstanding the fact that analytic tools for assessing a firm ’ s systemic footprint are in a relatively early stage of development, everything we do know suggests that the firms on the basel committee list strongly implicate the kinds of systemic considerations mentioned by congress. second, it does seem incumbent on us to provide at least some guidance to firms where we can, particularly to inform smaller, less connected firms of the kinds of mergers that are unlikely to raise financial stability concerns and, conversely

purpose of the intervention or unnecessarily obstruct market innovation. in some instances this approach, which i suppose might be described as market - sensitive, involved encouraging the market itself to address the particular issue in question as a preferable alternative to official action. i think of the takeover panel, for example, or the work of people like adrian cadbury - under the auspices of the stock exchange - in developing corporate governance standards, or of the professional organisations which set and police accountancy rules. a similar approach was followed in relation to many commercial banking issues - through approved codes of conduct in relation to their dealings with customers accompanied by an ombudsman scheme. we were in this country sensitive to the need to distinguish between different aspects of financial market activity - very obviously in the case of the distinction between wholesale and retail activity - in trying to find the most appropriate ways of reflecting legitimate public concerns. where there has been official intervention, it has, again by now well - established tradition, sought to avoid discrimination - whether between different types of financial institution or in the form of protective nationalism in favour of british - owned businesses, provided everyone undertaking a particular activity played by the same rules. that approach has not necessarily always been popular, i have to say, with some of those who might have benefited from such discrimination! but it is certainly one of the reasons for london's attraction as an international financial centre including its attraction to so many financial companies from elsewhere in europe. and that international presence in turn contributes enormously to the efficiency of the london market - and indeed the european market of which we are very much a part. chairman, i could go on reflecting on our own experience of all this - but i'm conscious that the weekend beckons - and the relevant question is how it all relates to the development of the single financial market across europe. the potential benefits of integration i take for granted. the continuing debate is about how - given that we all start from different positions and with different traditions and with different public policy priorities, we get from here to there. it may well be that continuous public pressure for higher and higher standards in financial markets everywhere are leading to greater official intervention any way. but integration was itself always bound to involve more intervention as the eu member states moved towards some degree of harmonisation of standards, requiring legal agreement at the european level and then reflected in national legislation. and a great deal of progress has, of course, already been made in that direction through