and heads of supervision of the countries represented on the basel committee determined that implementation of both frameworks should be delayed while they are subject to further examination and possible revision. the lcr has been actively reconsidered within the basel committee over the last year or so. as this work proceeds, i think we should be considering three types of additional changes : first, some of the assumptions embedded in the lcr about run rates of liabilities and the liquidity of assets might be grounded more firmly in actual experience during the crisis. the current lcr seems to me to overstate in particular the liquidity risks of commercial banking activities. second, it would be worthwhile to pay more attention to the liquidity risks inherent in the use of large amounts of short - term wholesale funding. third, the lcr should be better adapted to a crisis environment as, for example, by making credibly clear that ordinary minimum liquidity levels need not be maintained in the midst of a crisis. as currently constituted, the lcr might have the unintended effect of exacerbating a period of stress by forcing liquidity hoarding. i am often asked whether the reforms i have just described will “ solve ” the too - big - to - fail problem. in response, i would say that too - big - to - fail is not a binary problem. expectations of government support for a particular firm can range from essentially zero to near certainty, and can also vary substantially depending on the degree of overall stress in the financial system at a given moment. while it is probably unrealistic to expect that any set of reforms, no matter how far - reaching, will eliminate too - big - to - fail concerns entirely, i do think that full implementation of the reforms discussed today would go a considerable distance toward diminishing expectations of government support for large banking organizations, as well as the potential for damage to the financial system from the failure of a large banking firm. of one thing i am sure : if we do not complete rigorous implementation of this complementary set of reforms, we will have lost the opportunity to reverse the pre - crisis trajectory of increasing too - big - to - fail risks. shadow banking while there is a well - defined set of regulatory measures to address too - big - to - fail, the same cannot be said for the second major challenge revealed by the crisis : the instability of the shadow banking system. although some elements of pre - crisis shadow banking are probably gone forever, others

elizabeth a duke : opening remarks at the public hearing on potential revisions to the home mortgage disclosure act opening remarks by ms elizabeth a duke, member of the board of governors of the federal reserve system, at the public hearing on potential revisions to the home mortgage disclosure act, washington dc, 24 september 2010. * * * good morning. on behalf of the board of governors of the federal reserve system, i ’ d like to welcome everyone to the last of our series of public hearings held to discuss changes to the home mortgage disclosure act ( hmda ). the knowledge and feedback we have gained from these hearings will help us to assess the adequacy of current mortgage data, examine the need for additional data, and explore possible changes to regulation c, which implements hmda. i ’ d like to thank our colleagues at the federal reserve banks of atlanta, san francisco, and chicago for hosting the first three hearings. our series of hearings kicked off just as congress passed regulatory reform legislation earlier this summer. the dodd - frank act provides for some changes to hmda data collection and submission, and we look forward to hearing from our panelists and members of the public about the implementation of these changes. the new law also transfers authority for hmda rulemaking from the board of governors to the new consumer financial protection bureau ( cfpb ). all information gleaned from these hearings will inform our own work for the time that we continue to have rulewriting authority. when that authority transfers to the cfpb, be assured that we will hand over the most current thinking about changes to regulation c. over the course of these hearings, we have heard from key players in the home mortgage market : lenders and other market participants, academics and researchers, consumer advocacy and community development organizations, data experts, regulators, and other public officials. although they play different roles, we believe that all share a common goal : to ensure that the mortgage market is responsible, transparent, efficient, and serves the needs of consumers and market participants alike. clearly, the recent mortgage crisis has highlighted the potential ramifications of a mortgage market that is not functioning well. hmda data do not create the market or solve all market problems, but they do help us understand what is happening in the market. the time is certainly ripe for reviewing and revising the data elements, standards, and reporting formats. hmda has three purposes. one is to provide the public and government officials with data that will help show whether lenders