the federal reserve system, august 15 ). publication is also forthcoming in the journal of money, credit and banking. this paper did not specifically address community bank lending, but the authors conducted subsequent analysis of community bank data using the methodology set forth in the paper. bis central bankers ’ speeches but just as important is what, unfortunately, is not yet getting as much attention in washington. what is not happening – what in fact may be difficult to achieve until this postcrisis work is near completion and the overarching goal of financial stability has been addressed – is a more proactive inquiry and articulation of a positive vision of what kind of financial system we want to foster or preserve. while we focus on the difficult task of implementing a wide range of rules, a number of questions about the industry remain, questions that we must shift our full focus to once the post - crisis work is near completion. for example, is diversity in both the size and type of financial institutions critical to the goals of stability and access to credit? should new technologies that permit mobile payments and mobile banking be fostered through federal policy? to what extent should we be concerned about cyber threats, and are there features of a financial system that can mitigate or thwart such threats? after a crisis caused in part by opaque financial engineering, how do we prevent such excesses without stifling innovation that might benefit customers and the public and foster economic growth? should financial inclusion and financial literacy be regulatory goals, as some have suggested, and what responsibility should banks bear in achieving such ends? what do we do to re - calibrate a multi - layered regulatory response that was partly dictated by the exigencies of a crisis rather than by calculated principles of best design? we have to address these and other questions if we hope to envision a post - crisis financial regulatory system that supports a strong, dynamic, and diverse financial system. this, to me, is the strongest motivation for moving ahead as expeditiously as possible on implementing statutory requirements and international agreements to raise capital standards so that we can begin lifting our vision beyond a crisis response. moreover, as we implement these requirements and agreements, one of the things that the agencies have been considering is how we can do so in a way that does not differentially harm those financial institutions whose actions were not, by and large, responsible for the need to develop a policy response to the crisis. timeliness let ’ s talk about the importance of timely implementation of

sarah bloom raskin : let ’ s move forward – the case for timely implementation of revised capital rules speech by ms sarah bloom raskin, member of the board of governors of the federal reserve system, at the ohio bankers day, columbus, ohio, 6 june 2013. * * * the views in these remarks are my own and not necessarily those of my colleagues on the federal reserve board. good morning and thank you to the ohio department of commerce division of financial institutions ( dfi ) for the invitation to come to columbus to share some thoughts with you on ohio bankers day. in my remarks this morning, i want to describe some features of an appropriate regulatory capital framework for banks – focusing on community banks – and i ’ ll cut to the chase by setting out what i believe to be two imperatives in finalizing this framework. each of these imperatives has, at its core, the inherent goals of minimizing uncertainty and promoting safety and soundness. these imperatives are timeliness and simplicity. to explain why timeliness – by which i mean timely implementation of final capital rules in the united states – and simplicity are imperative, it helps to set the stage. and to do that, i have to go back in time. way back, in fact, to when i was a child growing up in a small town in illinois, just minutes away from the indiana border. there was no bank in our town, but there was one in the next town over, which was where my family and our neighbors would do their banking. the bank probably had no more than $ 30 million in assets. on saturday mornings, my mother ( who essentially was the cfo of the family financial unit ) would toss me in the back seat of the car and drive over to deposit my parents ’ paychecks, which, in those days before atms, meant visiting a teller. if there were no checks to deposit, saturday morning would be when my mother would go to withdraw cash for the week. “ get in this line, ” my mother would order. “ we want shirley. ” sometimes, we would end with a visit to the vault. to my seven - year - old self, going to the vault was deadly serious, a ritual that began by signing in with a stern - looking man who held the keys. it felt like entering a cave and looking at gold, although in retrospect i suspect my mother was only checking on insurance policies or her passbook savings. after the vault,