mr. terullo's comments about the importance of capital. i know you have given a great deal of thought to this. for a long this for a long time. there may be many things we may not agree on but i think the emphasis on capital as a general matter is exactly the right direction we should be heading in. i fear that dodd-frank is a profoundly misguided effort to do many other things. i respectfully disagree with our chairman who tended to disagree with the characterization of dodd-frank as a very explicit attempt to require that regulators micromanage banks. i believe very much it is exactly that and it is guaranteed to fail in that respect. i want to touch on another topic. mr. gruenberg, you stated and i think this is within context that the typical path toward the failure of an insured banks starts with bad loans. my understanding according to the fdic website that over the course of 2009 and 2010, there were almost 300 banks that failed. that is a high rate of failure, the highest since the early 1990's. 95% of these failures were banks wit

mr. terullo's comments about the importance of capital. i know you have given a great deal of thought to this for a long time. there may be many things we may not agree on but i think the emphasis on capital as a general matter is exactly the right direction we should be heading in. i fear that dodd-frank is a profoundly misguided effort to do many other things. i respectfully disagree with our chairman who tended to disagree with the characterization of dodd-frank as a very explicit attempt to require that regulators micromanage banks. i believe very much it is exactly that and it is guaranteed to fail in that respect. i want to touch on another topic. mr. gruenberg, you stated and i think this is within context that the typical path toward the failure of an insured banks starts with bad loans. my understanding according to the fdic website that over the course of 2009 and 2010, there were almost 300 banks that failed. that is a high rate of failure, the highest since the early 1990's. 95% of these failures were banks with assets less tha