decade ago, were the result of a defensible but not ineluctable analysis, and have not been refined since then. we should explore ways to bring these criteria into better alignment with our objectives. a third area in which i will be working with my board colleagues is a meaningful simplification of our framework of loss absorbency requirements. there are different ways to count the number of loss absorbency constraints that our large banking firms face — which is perhaps in itself an indication of a surfeit of complexity if we can ’ t be perfectly sure of how to count them — but the number i come up with is 24 total requirements in the framework. while i do not know precisely the socially optimal number of loss absorbency requirements for large banking firms, i am reasonably certain that 24 is too many. candidates for simplification include : elimination of the advanced approaches risk - based capital requirements ; one or more ratios in stress testing ; and some simplification of our tlac rule. i am not the first federal reserve governor to mention some of these possibilities, and we should put them back on the table in the context of a more holistic discussion of streamlining these requirements. let me be clear, however, that while i am advocating a simplification of large bank loss absorbency requirements, i am not advocating an enervation of the regulatory capital regime applicable to large banking firms. although not a post - crisis regulation, the board ’ s complex and occasionally opaque framework for making determinations of control under the bank holding company act ( bhc act ) is another area that is ripe for re - examination through the lenses of efficiency, transparency, and simplicity. as you know, a determination of control under the bhc act is significant because even remote entities in a controlled group can be subject to the bhc act ’ s restrictions on activities and a host of other regulatory requirements. under the board ’ s control framework — built up piecemeal over many decades — the practical determinants of when one company is deemed to control another are now quite a bit more ornate than the basic standards set forth in the statute and in some cases cannot be discovered except through supplication to someone who has spent a long apprenticeship in the art of fed interpretation. the process can be burdensome and timeconsuming both for the requester and federal reserve staff. we are taking a serious look at rationalizing and recalibrating this framework. finally, as i mentioned earlier

own impressions of what is next for post - crisis 2 / 5 bis central bankers'speeches regulation. in my early days as the vice chairman for supervision, i asked our staff to conduct a comprehensive review of the regulations in the core areas of reform that i outlined earlier — capital, stress testing, liquidity, and resolution. the objective is to consider the effect of those regulatory frameworks on resiliency and resolvability of the financial system, on credit availability and economic growth, and more broadly to evaluate their costs and benefits. this is a comprehensive and serious process, and work is still underway. i should note, however, that i have already formed views on a few areas that warrant more focus, and that i will be working with my colleagues on the board to constructively consider. i will start with the issue of tailoring supervision and regulation to the size, systemic footprint, risk profile, and business model of banking firms. the federal reserve has devoted considerable energy in its post - crisis regulatory work to incorporate the tailoring concept in its regulation and supervision across the spectrum of small, medium, and large firms. a recent example of this approach is our late 2017 proposal to simplify capital requirements for small - and medium - sized banking firms. in my view, there is further work for the federal reserve and the other banking agencies to do on the tailoring front. i would emphasize that tailoring is not an objective limited in scope to a subset of the smallest firms. as my colleagues and i have said before, the character of our regulation should match the character of the risk at the institution. accordingly, we should also be looking at additional opportunities for more tailoring for larger, non - global systemically important banks, or non - gsibs. in this regard, i support congressional efforts regarding tailoring, whether by raising the current $ 50 billion statutory threshold for application of enhanced prudential standards or by articulating a so - called factors - based threshold. irrespective of where the legislative efforts land, i believe we at the federal reserve have the responsibility to ensure that we do further tailoring for the institutions that remain subject to our rules to ensure that regulation matches the risk of the firm. take for example large non - g - sibs whose failure would not individually pose a risk to u. s. financial stability. even without financial stability implications, the distress or failure of these firms still could harm the u. s. economy by, for example