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Financial Services Law Insights and Observations

Federal Reserve vice chairman discusses tailoring prudential standards to account for complexity and risk

Federal Issues Federal Reserve Bank Regulatory Stress Test S. 2155 EGRRCPA

Federal Issues

On July 18, Federal Reserve Vice Chairman for Supervision Randal K. Quarles spoke before the American Bankers Association’s conference in Salt Lake City to discuss ways the Fed can tailor the supervision and regulation of prudential standards for financial institutions with assets between $100 billion to $250 billion. According to Quarles, U.S. regulators should consider scaling back resolution plan requirements and tailor regulation to risk. In discussing resolution plans, also known as living wills, Quarles noted, among other things, that the Fed “should consider limiting the scope of application of resolution planning requirements to only the largest, most complex, and most interconnected banking firms because their failure poses the greatest spillover risks to the broader economy.” Furthermore, banks that do not qualify as global systemically important banks (G-SIBs) should also be granted some measure of regulatory relief, Quarles stated. Existing G-SIB tests and surcharge indicators could be used for measuring cross-border activity, short-term wholesale funding, as well as nonbank activities while the Fed determines adjustments for less complex banks between the $100 billion and $250 billion range. “This review should ensure that our regulations continue to appropriately increase in stringency as the risk profiles of firms increase, consistent with our previously stated tailoring goals and the new legislation,” Quarles said. “The supervision and regulatory framework for these firms should reflect that there are material differences between those firms that qualify as U.S. G-SIBs and those that do not.” Moreover, according to Quarles, while the Economic Growth, Regulatory Relief, and Consumer Protection Act mandates an 18-month deadline for regulators to issue proposed changes, the Fed plans to “move much more rapidly than this.”