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Nov 7, 2015
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>> we did do an actual cost benefit on tlac. >> do we have a copy of that?>> it is described in the proposal we issued last week. so, in some cases, we have done a cost benefit analysis. >> some cases and others cases you do not? >> often, what we are doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view is beneficial. >> you are doing the rule -- >> the question becomes, when congress has directed us to write a rule that it's judged to be beneficial. what is the least -- >> let me stop you there, if i may. the regal act doesn't say you can pick and choose when to do a cost benefit. shall, not may, it sounds as though you are doing it in some cases but not other cases, which may explain why the governor couldn't give me a clear answer. let me move on to the other issue. the broader issue is, has anybody done an analysis of all the costs and cumulative of dodd frank. his answer was no. secretary liu we asked the question, it was no, but if congress wants to do it, we can do it. have you done a c
>> we did do an actual cost benefit on tlac. >> do we have a copy of that?>> it is described in the proposal we issued last week. so, in some cases, we have done a cost benefit analysis. >> some cases and others cases you do not? >> often, what we are doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view is beneficial. >> you are doing the rule -- >> the question becomes, when congress has...
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Nov 5, 2015
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>> we did do an actual cost benefit on tlac. >> do we have a copy of that? >> it is described in the proposal we issued last week. so, in some cases, we have done a cost benefit analysis. >> some cases and others cases dwr you do not? >> often, what we are doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view is beneficial. >> you are doing the rule -- >> the question becomes, when congress has directed us to write a rule that it's judged to be beneficial. what is the least -- >> let me stop you there, if i may. the regal act doesn't say you can pick and choose when to do a cost benefit. shall, not may, it sounds as though you are doing it in some cases but not other cases, which may explain why the governor couldn't give mae clear answer. let me move on to the brorder issue. the broader issue is, has anybody done an analysis of all the costs and cumulative of dodd frank. his answer was no. secretary liu we asked the question, it was no, but if congress wants to do it, we can do it. have you do
>> we did do an actual cost benefit on tlac. >> do we have a copy of that? >> it is described in the proposal we issued last week. so, in some cases, we have done a cost benefit analysis. >> some cases and others cases dwr you do not? >> often, what we are doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view is beneficial. >> you are doing the rule -- >> the question becomes, when...
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Nov 6, 2015
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>> well, we did do an actual cost benefit on tlac. >> do we have a copy of that? >> and it is described in the proposal that we issued last week. so in some cases we have done a cost benefit analysis. >> in some cases. in other cases you do not? >> well, very often what we're doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view will prove beneficial. >> you're doing the rule under the regal -- >> then the question becomes when congress has directed us to write a rule that it's judged to be beneficial, what is the least cost way of doing that? >> let me stop you there, if i may. the regal act doesn't say you can pick and choose as to when you do a cost benefit analysis, it says you shall -- so not may -- you shall consider and then it lays out those parameters. it sounds as though you're doing it in some cases but not doing it in other case, which may plain why governor trulu couldn't give me a good answer. let me move to the broader issue. since you're not doing it in all cases, your predecessor ben
>> well, we did do an actual cost benefit on tlac. >> do we have a copy of that? >> and it is described in the proposal that we issued last week. so in some cases we have done a cost benefit analysis. >> in some cases. in other cases you do not? >> well, very often what we're doing is putting into effect a rule that congress has directed us to write to implement changes that in congress' view will prove beneficial. >> you're doing the rule under the regal --...
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Nov 6, 2015
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can you elaborate for us how tlac works and how it makes it less likely that a government bailout will be needed in case of a future failure of one of these very large banks. >> well, thank you for that question. its's an important regulation that is intended precisely as you say, to mitigate too big to fail and to the extent that the ratings agencies recognize that a firm is more likely to be able to be allowed to fail, and they reduce the so-called uplift, that's good. >> it's my understanding here in congress that there is no willingness to repeat what we did back in 2008 to save the banking system. let me go to the next question. yesterday, we debated replacing the $50 billion threshold for mandated enhanced prudential standards with a financial oversight council designation process. what is your opinion on what the threshold should be? >> so we would not like to see an fsoc process that tells us exactly how to tailor our supervision to firms of different sizes. we already have an elaborate program in which we do tailor the requirements within the confines of law to match the footp
can you elaborate for us how tlac works and how it makes it less likely that a government bailout will be needed in case of a future failure of one of these very large banks. >> well, thank you for that question. its's an important regulation that is intended precisely as you say, to mitigate too big to fail and to the extent that the ratings agencies recognize that a firm is more likely to be able to be allowed to fail, and they reduce the so-called uplift, that's good. >> it's my...
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Nov 7, 2015
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e tlac proposal that was discussed last week. was that finalized last week? >> no. it's a notice of proposed rule making that's out for comment. >> it's been around for a while. you've been discussing it for a while. >> members of the fed and others have given speeches on this. it's something that is being discussed internationally in the fmp sb in fact. the united states has been contemplating this. we're working jointly with the fdic. it's an important step in ensuring that the fdic's single point of entry strategy would be workable in the title 2 resolution or in the bankruptcy resolution. we see it as very important. it's been under discussion for quite a long time. >> if i can interrupt you because in the short time left i have some specific things to ask you. in fact some of the analysis that i have been provided regarding the zraft proposal suggest that is it penalizes firms for what is broadly nderstood to be a desireable business model gathering deposits and making loans. some have even suggest it had effect of the new rule could be interpreted as a tax on
e tlac proposal that was discussed last week. was that finalized last week? >> no. it's a notice of proposed rule making that's out for comment. >> it's been around for a while. you've been discussing it for a while. >> members of the fed and others have given speeches on this. it's something that is being discussed internationally in the fmp sb in fact. the united states has been contemplating this. we're working jointly with the fdic. it's an important step in ensuring that...
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Nov 5, 2015
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can you elaborate how tlac works and how it makes it less likely a government bailout will be needed in case of a future failure of one of these very large banks. >> thank you for that question. its's an important regulation that is intended precisely as you say, to mitigate too big to fail and to the extent that the ratings agency recognize that a firm is more likely to be able to fail and they reduce the so-called -- >> here in congress, there is no willingness to repeat what we did back in 2008 to save the banking system. let me go to the next question. yesterday, we debated replacing the $50 billion threshold for mandated standards with a financial counsel designation process. what is your opinion on what the threshold should be? >> so, we would not like to see an fsoc process that tells us exactly how to tailor our supervision to firms of different sizes. we already have an elaborate program which we do tailor the requirements to the confines of law to match the footprint and complexity of the firms and there are only a few areas where we have concerns that we may be limited in
can you elaborate how tlac works and how it makes it less likely a government bailout will be needed in case of a future failure of one of these very large banks. >> thank you for that question. its's an important regulation that is intended precisely as you say, to mitigate too big to fail and to the extent that the ratings agency recognize that a firm is more likely to be able to fail and they reduce the so-called -- >> here in congress, there is no willingness to repeat what we...
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Nov 6, 2015
11/15
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before, from a quantitative impact study being conducted by the fsb prior to implementing the new tlac proposal? >> so i think that's frankly a mischaracterization of this proposal. the purpose of this proposal is to ensure that if a firm becomes insolvent that there is -- >> would you benefit -- forgive me, i've got 20 seconds left. would you benefit from a quantitative impact study being done prior to implementation? >> we have carefully analyzed this proposal, the costs and benefits -- >> have you done a quantitative impact study? >> we've done a quantitative analysis and -- >> would you share that with us? >> there is information contained in the proposal that we published. >> all right. well, the analysis -- is there any -- well, it looks like my time is expired. >> the point is that the deposits are not a liability that is capable of absorbing losses when a firm is in trouble. we've seen that in financial crises. and the point of this is to make sure -- >> thank you, my time is expired. >> -- there is enough assets at risk. >> time of the gentleman has expired. the chair now reco
before, from a quantitative impact study being conducted by the fsb prior to implementing the new tlac proposal? >> so i think that's frankly a mischaracterization of this proposal. the purpose of this proposal is to ensure that if a firm becomes insolvent that there is -- >> would you benefit -- forgive me, i've got 20 seconds left. would you benefit from a quantitative impact study being done prior to implementation? >> we have carefully analyzed this proposal, the costs and...