holding companies, ” notice of proposed rulemaking ( docket no. r - 1523 ), federal register, vol. 80 ( november 30 ), pp. 74931 – 32. the gsib has to satisfy both constraints. tlac encompasses both equity capital and eligible long - term debt. see board of governors of the federal reserve system ( 2016 ), “ federal reserve board proposes rule to support u. s. financial stability by enhancing the resolvability of very large and complex financial firms, ” press release, may 3. see board of governors of the federal reserve system and federal deposit insurance corporation ( 2016 ), “ agencies announce determinations and provide feedback on resolution plans of eight systemically important, domestic banking institutions, “ joint press release, april 13. bis central bankers ’ speeches the agencies found that five of the gsibs ’ plans fell short of the dodd - frank act ’ s standard and required those firms to fix the deficiencies in their plans by october of this year or potentially face more stringent prudential requirements. the agencies also identified lesssevere shortcomings in the plans of all eight gsibs, which the gsibs are expected to address in their next round of resolution plan submissions, due in july 2017. the deficiencies and shortcomings identified by the agencies touched on most of the categories i have just listed, especially liquidity, governance mechanisms, operational capabilities, and legal entity rationalization. i want to end by briefly addressing several criticisms that have been made of the dodd - frank act ’ s orderly liquidation authority and the board ’ s tlac proposal. one criticism is that there is no need for the backup orderly liquidation authority because the bankruptcy code provides an adequate framework for the resolution of any financial company. as title ii of the doddfrank act recognizes, however, the bankruptcy code may not be adequate to minimize the systemic impact of the resolution of a systemically important financial firm. the bankruptcy code does not direct the judge to take financial stability into account in making decisions, and it does not provide other important stabilizing features of the orderly liquidation authority, such as government liquidity support and stay - and - transfer treatment for qualified financial contracts. a related line of criticism holds that the orderly liquidation authority enshrines “ too big to fail ” and provides for taxpayer bailouts of systemically important firms through the orderly liquidation fund. however, under the board ’ s proposed tlac rule, a

reduce the importance of local bank branches in the provision of retail banking services. federal reserve staff and other economists continue to monitor and analyze the effects of these and other developments on the nature of competition within the financial services industry. if changes are needed in the ways that we evaluate the potential competitive effects of proposed mergers and acquisitions, the board is prepared to modify its approach. conclusion in closing, i hope that i have provided you with a useful perspective on the financial services industry and on the policies of the federal reserve. the united states has prospered from and, i believe, will continue to reap the benefits of a strong and competitive financial services industry. this industry is evolving at a sometimes breathtaking pace. the resulting changes require all of us to frequently revisit our assumptions, views, and policies and sometimes to revise those assumptions, views, and policies in order to continue to achieve the unchanging objectives of a sound and competitive financial system.