capital to risk - weighted assets. federal regulation also now requires stricter criteria for instruments to qualify as i use the terms “ bank ” and “ financial institution ” interchangeably, but note that the two terms are not synonymous in federal regulation. see joint notice of proposed rulemaking, “ regulatory capital rules : regulatory capital, implementation of basel iii, minimum regulatory capital ratios, capital adequacy, transition provisions, and prompt corrective action, ” june 12, 2012, at 32. bis central bankers ’ speeches regulatory capital and higher risk weights for many classes of assets. and the federal reserve mandated a new minimum supplementary leverage ratio that includes off - balance sheet exposures for the largest, most internationally active banking organizations and a leverage surcharge for large u. s. banking organizations. in support of these new regulations, capital assessment has become a focus of supervision since the financial crisis. examiners monitor capital reserves and put banks through periodic stress tests that are evaluated on a cross - firm basis. this has been one of the great advancements of bank oversight following the crisis. these evaluations enable supervisors to assemble a composite assessment of the nation ’ s banking sector, which materially assists the federal reserve in its statutory mandate to promote financial stability. 3 the dodd - frank act mandates supervisory stress tests that assess whether large bank holding companies have a sufficient level of capital to absorb losses during adverse economic conditions. 4 the federal reserve also conducts a capital planning exercise, called the comprehensive capital analysis and review or “ ccar. ” this evaluation combines the quantitative results from the dodd - frank act stress tests with a qualitative assessment of whether the largest bank holding companies have vigorous, “ forward - looking capital planning processes that account for their unique risks. ” 5 the criteria for both sets of stress tests are dynamic and change in response to evolving risks. for example, past tests have assumed a sharp, sudden, and widespread drop in markets triggered by, say, a large eurozone shock. the tests also evaluate market interconnectedness, including the risk of major counterparty default. to increase public transparency, the federal reserve now publishes the overall results of its stress tests. this helps rebuild confidence in the strength of the financial system. the most recent round of stress tests concluded in the first quarter of this year. in my view, the results were encouraging, although not uniformly satisfying. in general, “ firms participating in ccar have more than doubled their tier 1 common capital since 2009, an increase of $

william c dudley : improving financial institution supervision – examining and addressing regulatory capture testimony by mr william c dudley, president and chief executive officer of the federal reserve bank of new york, before the senate committee on banking, housing, and urban affairs financial institutions and consumer protection subcommittee, washington dc, 21 november 2014. * i. * * introduction chairman brown, ranking member toomey, and members of the subcommittee, thank you for this opportunity to testify on the effectiveness of financial institution supervision and the issue of regulatory capture. in 2008 and 2009 our country faced its worst financial crisis since the great depression. i mention those years as a touchstone for my remarks today. despite the passage of time and an economy that is steadily improving, the financial crisis is hardly something that happened in the remote past. for the too many people who are still unemployed or underemployed, or who otherwise continue to struggle financially, it is living history. while the causes of the crisis remain subject to debate, it is undeniable that banking supervisors could have done better in their prudential oversight of the financial system. this conclusion raises two fundamental questions : • first, how can we improve the stability of the financial system? in other words, how can we make the financial system more resilient and productive? • second, how can we improve our supervision of financial institutions? the federal reserve is working diligently to improve both stability and supervision. the two concepts are linked. since the financial crisis, the federal reserve has made significant changes to the substance and process of supervision. as a result, the financial system is unquestionably much stronger and much more stable now than it was five years ago. ii. substantive changes since the financial crisis, the federal reserve has redoubled its attention to bank capital. capital is the financial cushion that banks hold to absorb loss. 1 it provides an economic firebreak that helps prevent systemic stress from turning into a full - blown crisis. before the crisis, capital requirements were too low and inconsistent across jurisdictions. moreover, too much of the capital held by banks was of poor quality, and their internal capital assessments were not forward - looking. 2 since the crisis, new regulation and heightened supervision have increased both the quantity and the quality of equity capital at the largest financial institutions that we regulate and supervise. the federal reserve and other federal banking regulators implemented so - called “ basel iii ” international capital standards in july 2013, which raised the minimum ratio of common equity tier 1