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S. HRG. 113–125

NOMINATION OF JANET L. YELLEN

HEARING
BEFORE THE

COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED THIRTEENTH CONGRESS
FIRST SESSION
ON
NOMINATION OF JANET L. YELLEN, OF CALIFORNIA, TO BE CHAIRMAN
OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

NOVEMBER 14, 2013

Printed for the use of the Committee on Banking, Housing, and Urban Affairs

(
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COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS
TIM JOHNSON, South Dakota, Chairman
JACK REED, Rhode Island
MIKE CRAPO, Idaho
CHARLES E. SCHUMER, New York
RICHARD C. SHELBY, Alabama
ROBERT MENENDEZ, New Jersey
BOB CORKER, Tennessee
SHERROD BROWN, Ohio
DAVID VITTER, Louisiana
JON TESTER, Montana
MIKE JOHANNS, Nebraska
MARK R. WARNER, Virginia
PATRICK J. TOOMEY, Pennsylvania
JEFF MERKLEY, Oregon
MARK KIRK, Illinois
KAY HAGAN, North Carolina
JERRY MORAN, Kansas
JOE MANCHIN III, West Virginia
TOM COBURN, Oklahoma
ELIZABETH WARREN, Massachusetts
DEAN HELLER, Nevada
HEIDI HEITKAMP, North Dakota
CHARLES YI, Staff Director
GREGG RICHARD, Republican Staff Director
LAURA SWANSON, Deputy Staff Director
KRISHNA PATEL, FDIC Detailee
BRIAN FILIPOWICH, Professional Staff Member
GREG DEAN, Republican Chief Counsel
MIKE LEE, Republican Professional Staff Member
DAWN RATLIFF, Chief Clerk
KELLY WISMER, Hearing Clerk
SHELVIN SIMMONS, IT Director
JIM CROWELL, Editor
(II)

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C O N T E N T S
THURSDAY, NOVEMBER 14, 2013
Page

Opening statement of Chairman Johnson .............................................................
Opening statements, comments, or prepared statements of:
Senator Crapo ...................................................................................................

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2

NOMINEE
Janet L. Yellen, of California, to be Chairman of the Board of Governors
of the Federal Reserve System ............................................................................
Prepared statement ..........................................................................................
Biographical sketch of nominee .......................................................................
Responses to written questions of:
Senator Crapo ............................................................................................
Senator Brown ...........................................................................................
Senator Hagan ...........................................................................................
Senator Warren .........................................................................................
Senator Vitter ............................................................................................
Senator Johanns ........................................................................................
Senator Kirk ..............................................................................................
Senator Moran ...........................................................................................
Senator Coburn .........................................................................................

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NOMINATION
OF
JANET
L.
YELLEN,
OF CALIFORNIA, TO BE CHAIRMAN OF THE
BOARD OF GOVERNORS OF THE FEDERAL
RESERVE SYSTEM
THURSDAY, NOVEMBER 14, 2013

U.S. SENATE,
URBAN AFFAIRS,
Washington, DC.
The Committee met at 10:01 a.m., in room SD–106, Dirksen Senate Office Building, Hon. Tim Johnson, Chairman of the Committee, presiding.
COMMITTEE

ON

BANKING, HOUSING,

AND

OPENING STATEMENT OF CHAIRMAN TIM JOHNSON

Chairman JOHNSON. I call this hearing to order.
Today we consider the nomination of the Honorable Janet Yellen
to be Chair of the Board of Governors of the Federal Reserve System for a term of 4 years.
Dr. Yellen is an extraordinary candidate to lead the Federal Reserve. She currently serves as a Member and Vice Chair of the
Board of Governors; she previously served as a Member of the
Board of Governors in the 1990s; she was the Chair of President
Clinton’s Council of Economic Advisers; and she served 6 years as
the President of the San Francisco Fed.
In addition, Dr. Yellen has an impressive academic record. She
is a professor at Berkeley’s Haas School of Business and was previously a professor at Harvard University, as well as a faculty
member at the London School of Economics. Dr. Yellen graduated
summa cum laude from Brown University and received her Ph.D.
in economics from Yale.
Dr. Yellen’s nomination is especially timely as our Nation struggles with high unemployment in the wake of the Great Recession.
She has devoted a large portion of her professional and academic
career to studying the labor market, unemployment, monetary policy, and the economy.
Dr. Yellen also has a strong track record in evaluating trends in
the economy; her economic analysis has been spot-on. The New
York Times recently noted that she was ‘‘the first Fed official, in
2005, to describe the rise in housing prices as a bubble that might
damage the economy. She was also the first, in 2008, to say that
the economy had fallen into a recession.’’
These forecasts were not an anomaly. The Wall Street Journal
recently analyzed 700 predictions made between 2009 and 2012 in
speeches and congressional testimony by 14 Federal Reserve policy
(1)

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makers and found Dr. Yellen was the most accurate. Such accurate
economic judgment would be a tremendous quality of a Fed Chair.
Dr. Yellen has proven through her extensive and impressive
record in public service and academia that she is most qualified to
be the next Chair of the Federal Reserve. We need her expertise
at the helm of the Fed as our Nation continues to recover from the
Great Recession, completes Wall Street reform rulemakings, and
continues to enhance the stability of our financial sector.
I am excited to cast my vote to confirm her as the first woman
to serve as Chair of the Federal Reserve, and when we vote on the
nomination, I urge my colleagues to do the same.
I now turn to Ranking Member Crapo for his opening statement.
STATEMENT OF SENATOR MIKE CRAPO

Senator CRAPO. Thank you, Mr. Chairman, for holding today’s
hearing on the nomination of Dr. Yellen to be the next Chair of the
Federal Reserve Board. Today’s hearing is an opportunity not only
to examine Governor Yellen’s qualifications but also her views on
the role and direction of the Federal Reserve.
In recent years the Fed has engaged in unprecedented policies,
including purchasing trillions of dollars in Treasuries and mortgage-backed securities. Current Fed purchases total up to $85 billion a month. As a result, the next Fed Chair will inherit a balance
sheet that currently stands at approximately $3.8 trillion, four
times higher than before the financial crisis.
As I think everyone knows, I have been a long-time critic of the
Fed’s quantitative easing purchases. Now that a reduction in asset
purchases finally seems to be on the horizon, I am concerned that
markets have become overly reliant on them. That is why it is essential to know how Dr. Yellen, if confirmed, would manage the
process of normalizing our monetary policy. The Fed has indicated
that it will hold short-term interest rates low for an extended period. In a speech in April, Governor Yellen stated, ‘‘The policy rate
should, under present conditions, be held lower for longer.’’ But
how long is too long?
The extended period of low rates is hurting individuals living on
fixed-income investments and defined benefit pension funds. The
International Monetary Fund cautioned that the actions taken by
central banks are associated with financial risks that are likely to
increase the longer the policies are maintained.
How would the Fed ensure that these risks are avoided under
Dr. Yellen’s chairmanship? In addition to unprecedented monetary
policy, the next Fed Chair will finalize several key financial regulatory reform rules. These rules must balance the financial stability
with the inherent need for markets to take on and accurately price
risk. They must be done without putting the U.S. markets at an
undue competitive disadvantage or harming consumers with unintended consequences.
The Chair of the Federal Reserve must understand how different
rules interact with each other, what impact they have on the affected entities and the economy at large. Just as some worried that
we did not have another regulations on the books to prevent the
economic crisis, some of us worry now that the post-crisis response

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will result in a regulatory regime that stifles growth and job creation.
The Chair of the Federal Reserve must know and understand the
need for that balance and how to carefully manage competing demands without harming the economy. The U.S. banking system
and capital markets must remain the preferred destination for investors throughout the world.
During previous hearings, I have asked Chairman Bernanke
what parts of Dodd-Frank could be revisited on a bipartisan basis.
The Chairman identified the end user and swaps push-out provisions as well as the need for regulatory relief on small banks.
Chairman Bernanke also commented in July that legislation is
needed to allow the Fed flexibility to deal with the Collins amendment and tailor appropriate capital requirements for insurance
companies.
I look forward to hearing Dr. Yellen’s views on what Dodd-Frank
fixes Congress ought to consider and how she intends to achieve an
appropriate balance between the prudential regulation and economic growth, if confirmed.
In addition to the previously mentioned issues, the makeup of
the Board itself will change in the near future. Governor Sarah
Bloom Raskin has been nominated to a position at Treasury, and
Governor Elizabeth Duke resigned in August. If Governor Yellen is
confirmed as Chair, the Fed will need a new Vice Chair. Moreover,
Dodd-Frank created a Vice Chair of Supervision, which has not yet
been officially filled. These appointments will shape the direction
of the Federal Reserve policymaking for years to come.
I look forward to working with the Chairman to see these positions are filled in a way that provides the proper balance and expertise at the Fed.
Thank you, Mr. Chairman.
Chairman JOHNSON. Thank you, Senator Crapo.
Senator Crapo and I have agreed that, to allow for sufficient time
for questions, we are limiting opening statements to the Chair and
Ranking Member. All Senators are welcome to submit an opening
statement for the record.
We will now swear in Dr. Yellen. Please rise and raise your right
hand. Do you swear or affirm that the testimony that you are
about to give is the truth, the whole truth, and nothing but the
truth, so help you God?
Ms. YELLEN. I do.
Chairman JOHNSON. Do you agree to appear and testify before
any duly constituted committee of the Senate?
Ms. YELLEN. I do.
Chairman JOHNSON. Please be seated.
Please be assured that your written statement will be part of the
record. I invite you to introduce your family and friends in attendance before beginning your statement.
Dr. Yellen, please proceed with your testimony.

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STATEMENT OF JANET L. YELLEN, OF CALIFORNIA, TO BE
CHAIRMAN OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM

Ms. YELLEN. Thank you. I would like to introduce my husband,
George Akerlof; and my sister-in-law, Allison Brooks; and my
friend and a former San Francisco Fed Director, Karla Chambers,
who are here with me today.
Chairman Johnson, Senator Crapo, and Members of the Committee, thank you for this opportunity to appear before you today.
It has been a privilege for me to serve the Federal Reserve at different times and in different roles over the past 36 years and an
honor to be nominated by the President to lead the Fed as Chair
of the Board of Governors.
I approach this task with a clear understanding that the Congress has entrusted the Federal Reserve with great responsibilities.
Its decisions affect the well-being of every American and the
strength and prosperity of our Nation. That prosperity depends
most, of course, on the productiveness and enterprise of the American people, but the Federal Reserve plays a role too, promoting
conditions that foster maximum employment, low and stable inflation, and a safe and sound financial system.
The past 6 years have been challenging for our Nation and difficult for many Americans. We endured the worst financial crisis
and deepest recession since the Great Depression. The effects were
severe, but they could have been far worse. Working together, Government leaders confronted these challenges and successfully contained the crisis. Under the wise and skilled leadership of Chairman Bernanke, the Fed helped stabilize the financial system, arrest the steep fall in the economy, and restart growth.
Today the economy is significantly stronger and continues to improve. The private sector has created 7.8 million jobs since the
post-crisis low for employment in 2010. Housing, which was at the
center of the crisis, seems to have turned a corner. Construction,
home prices, and sales are up significantly. The auto industry has
made an impressive comeback, with domestic production and sales
back to near their pre-crisis levels.
We have made good progress, but we have further to go to regain
the ground lost in the crisis and the recession. Unemployment is
down from a peak of 10 percent, but at 7.3 percent in October, it
is still too high, reflecting a labor market and economy performing
far short of their potential. At the same time, inflation is running
below the Federal Reserve’s goal of 2 percent and is expected to
continue to do so for some time.
For these reasons, the Federal Reserve is using its monetary policy tools to promote a more robust recovery. A strong recovery will
ultimately enable the Fed to reduce its monetary accommodation
and its reliance on unconventional policy tools such as asset purchases. I believe that supporting the recovery today is the surest
path to returning to a more normal approach to monetary policy.
In the past two decades, and especially under Chairman
Bernanke, the Federal Reserve has provided more and clearer information about its goals. Like the Chairman, I strongly believe
that monetary policy is most effective when the public understands
what the Fed is trying to do and how it plans to do it. At the re-

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quest of Chairman Bernanke, I led the effort to adopt a statement
of the Federal Open Market Committee’s longer-run objectives, including a 2-percent goal for inflation. I believe this statement has
sent a clear and powerful message about the FOMC’s commitment
to its goals and has helped anchor the public’s expectations that inflation will remain low and stable in the future. In this and many
other ways, the Federal Reserve has become a more open and
transparent institution. I have strongly supported this commitment
to openness and transparency, and I will continue to do so if I am
confirmed and serve as Chair.
The crisis revealed weaknesses in our financial system. I believe
that financial institutions, the Federal Reserve, and our fellow regulators have made considerable progress in addressing those weaknesses. Banks are stronger today, regulatory gaps are being closed,
and the financial system is more stable and more resilient. Safeguarding the United States in a global financial system requires
higher standards both here and abroad, so the Federal Reserve and
other regulators have worked with our counterparts around the
globe to secure improved capital requirements and other reforms
internationally. Today, banks hold more and higher-quality capital
and liquid assets that leave them much better prepared to withstand financial turmoil. Large banks are now subject to annual
‘‘stress tests’’ designed to ensure that they will have enough capital
to continue the vital role they play in the economy, even under
highly adverse circumstances.
We have made progress in promoting a strong and stable financial system, but here, too, important work lies ahead. I am committed to using the Fed’s supervisory and regulatory role to reduce
the threat of another financial crisis. I believe that capital and liquidity rules and strong supervision are important tools for addressing the problem of financial institutions that are regarded as
‘‘too big to fail.’’ In writing new rules, however, the Fed should continue to limit the regulatory burden for community banks and
smaller institutions, taking into account their distinct role and contributions. Overall, the Federal Reserve has sharpened its focus on
financial stability and is taking that goal into consideration when
carrying out its responsibilities for monetary policy. I support these
developments and pledge, if confirmed, to continue them.
Our country has come a long way since the dark days of the financial crisis, but we have farther to go. I believe the Federal Reserve has made significant progress toward its goals but has more
work to do.
Thank you for the opportunity to appear before you today. I
would be happy to respond to your questions.
Chairman JOHNSON. Thank you for your testimony.
Will the clerk please put 5 minutes on the clock for each Member?
Dr. Yellen, you know, as I do, that unemployment is not just
numbers but real men and women who are ready to work if given
the chance. As Chair, how will you lead the Fed to continue reducing unemployment aggressively and improve the prospects of young
Americans and others who are unemployed?
Ms. YELLEN. Thank you, Senator. I would be strongly committed
to working with the FOMC to continue promoting a robust eco-

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nomic recovery. As you noted, unemployment remains high. A disproportionate share of that unemployment takes the form of long
spells of unemployment. Around 36 percent of all those unemployed
have been unemployed for more than 6 months. This is a virtually
unprecedented situation, and we know that those long spells of unemployment are particularly painful for households, impose great
hardship and costs on those without work, on the marriages of
those who suffer these long unemployment spells, on their families.
So I consider it imperative that we do what we can to promote a
very strong recovery.
We are doing that by continuing our asset purchase program
which we put in place with the goal of assuring a substantial improvement in the outlook for the labor market. We are taking account of the costs and efficacy of that program as we go along. At
this point I believe the benefits exceed the costs. As that program
gradually winds down, we have indicated that we expect to maintain a highly accommodative monetary policy for some time to come
thereafter, and the message that we want to send is that we will
do what is in our power to assure a robust recovery in the context
of price stability.
Chairman JOHNSON. What are the dangers of tapering asset purchases too early? If confirmed, how should the FOMC move forward
on an exit strategy?
Ms. YELLEN. Senator, I think there are dangers, frankly, on both
sides of ending the program or ending accommodation too early.
There are also dangers that we have to keep in mind with continuing the program too long or more generally keeping monetary
policy accommodation in place too long. So the objective here is to
assure a strong and robust recovery so that we get back to full employment and that we do so while keeping inflation under control.
It is important not to remove support, especially when the recovery
is fragile and the tools available to monetary policy should the
economy falter are limited, given that short-term interest rates are
at zero. I believe it could be costly to withdraw accommodation or
to fail to provide adequate accommodation.
On the other hand, it will be important for us also, as the recovery proceeds, to make sure that we do withdraw accommodation
when the time is appointed. My colleagues and I are committed to
our longer-run inflation goal of 2 percent, and we will need to ensure that, as the recovery takes hold and progresses, we also exit
or bring monetary policy back to normal in a timely fashion.
I believe we have the tools necessary to do so. We have been very
careful to make sure that we have the tools available at our disposal and we also have the will and commitment, and I look forward to leading, when the time is appropriate, the normalization
of monetary policy.
Chairman JOHNSON. Thank you.
Senator Crapo.
Senator CRAPO. Thank you, Mr. Chairman, and I would like to
follow up on the Chairman’s question with you, Ms. Yellen, with
regard to quantitative easing. You have indicated that you feel that
as long as the economy remains—well, I do not want to put words
in your mouth. But as the economy remains fragile, that we need
to continue the accommodation from the Federal Reserve.

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According to the July quarterly survey of the primary dealers by
the New York Fed, the Fed’s balance sheet will reach almost 24
percent of GDP in the first quarter of 2014. And I am concerned
about the size of the Fed’s balance sheet and its impact on the
economy and the unintended consequences of these accommodations.
It seems to me that there is a disconnect between what the Fed
intended to accomplish and the results. A PIMCO executive recently stated that the $4 trillion in quantitative easing may have
contributed as little as one-quarter of 1 percent to GDP growth.
And even the Fed’s own economists estimates that the QE2 added
only about 0.13 percent to real GDP growth in 2010. And another
expert has indicated that Fed policies contribute to bubble-like
markets.
How do you respond to the concerns that quantitative easing has
limited impact on economic growth and is, in fact, creating very serious risks in our financial markets?
Ms. YELLEN. A number of different studies have been done attempting to assess what the contribution of our asset purchases
have been, and, of course, this is something we can only estimate
and cannot know with certainty. But my personal assessment
would be, based on all of that work, that these purchases have
made a meaningful contribution to economic growth and to improving the outlook.
Certainly long-term interest rates. The purpose of these purchases was to push down longer-term interest rates. We have seen
interest rates fall very substantially. Lower interest rates, lower
mortgage rates particularly, I think have been a positive factor in
generating the recovery of the housing sector. House prices, after
having fallen very substantially, are moving up, and that is helping
substantially many households, including the large fraction of
American households who found themselves underwater on their
mortgages. It is improving their household finances.
We have seen a very meaningful recovery in automobile sales,
spurred in part by low interest rates.
Senator CRAPO. But how long can we artificially hold or operate
monetary policy in what I consider to be such extreme levels of the
quantitative easing?
Ms. YELLEN. Senator, when we initiated this program, the unemployment rate was 8.1 percent, and the committee was somewhat
pessimistic about its expectations for what we would see in the
labor market over the ensuing year. In fact, the committee expected little or no meaningful progress in bringing down unemployment. And when we began this program, we indicated that our goal
was to see a substantial improvement in the outlook for the labor
market.
So the progress of this program, it is not on a set course. It is
data dependent, but we have seen improvement in the labor market.
Senator CRAPO. But can it just continue indefinitely? I mean, if
the labor market does not improve to the point that you reach your
target, how long can this continue? Do you agree that there has to
be some point at which we return to normal monetary policy?

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Ms. YELLEN. I would agree that this program cannot continue
forever, that there are costs and risks associated with the program.
We are monitoring those very carefully. You noted potential risks
to financial stability, and those are risks that we take very seriously.
The committee is focused on a variety of risks and recognizes
that the longer this program continues, the more we will need to
worry about those risks. So I do not see the program as continuing
indefinitely.
Senator CRAPO. Do you have any estimate right now as to when
there may be a beginning of the tapering?
Ms. YELLEN. Well, we at each meeting are attempting to assess
whether we have seen meaningful progress in the labor market,
and what the committee is looking for is signs that we will have
growth that is strong enough to promote continued progress. As the
FOMC indicated in its most recent statement, we do see strength
in the private sector of the economy, and we are expecting continued progress going forward. So while there is no set time that we
will decide to reduce the pace of our purchases, at each meeting we
are attempting to assess whether or not the outlook is meeting the
criterion that we have set out to begin to reduce the pace of purchases.
Senator CRAPO. My time has expired. Thank you.
Chairman JOHNSON. Senator Menendez.
Senator MENENDEZ. Well, thank you, Mr. Chairman. Thank you,
Dr. Yellen. I appreciated our visit together.
Let me ask you, as the Federal Reserve has engaged in measures
to strengthen our economy, some critics have argued that any
growth that results might somehow be artificial—I know we have
heard that here—or that low interest rates and cheaper credit
might lead to financial instability or asset bubbles if investors
make riskier investments in order to ‘‘reach for the yield.’’
In the current environment, though, my question is: Isn’t weak
demand the greater concern? I look at consumers pulling back on
their spending because of high debt burdens, underwater mortgages from the financial crisis, businesses holding off on investing
because of weak consumer demand. Doesn’t that change the relative costs, benefits, and risks of different monetary policy actions?
Ms. YELLEN. Well, Senator, I completely agree that weak demand
for the goods and services that this economy is capable of producing is a major drag holding back the economy. And, of course,
the purpose of our policies, all of them, is to bring down interest
rates in order to spur spending in interest-sensitive sectors, and if
we are capable of doing that, that will help to stimulate a favorable
dynamic in which jobs are created, incomes rise, and more spending takes place, which will create more jobs throughout the economy. So I agree with your diagnosis, and our programs are intended to remedy the situation of weak demand.
On the other hand, it is very important for us to monitor financial risks that could be developing as a consequence of the program
or of low interest rates more generally or even more broadly of developing financial risks in the economy. No one wants to live
through another financial crisis, and the Federal Reserve is devot-

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ing substantial resources and time and effort at monitoring those
risks.
At this stage I do not see risks of financial stability. Although
there is limited evidence of reach for yield, we do not see a broad
buildup in leverage or the development of risks that I think at this
stage poses a risk to financial stability.
Senator MENENDEZ. Well, let me ask you—I appreciate that.
Some commentators have suggested that, in addition to managing
inflation and promoting full employment, the Fed should also monitor an attempt to fight asset bubbles. Do you think it is a feasible
job and something that the Fed should be doing? And if so, how
would you go about it?
Ms. YELLEN. Well, Senator, I think it is important for the Fed,
hard as it is, to attempt to detect asset bubbles when they are
forming. We devote a good deal of time and attention to monitoring
asset prices in different sectors, whether it is house prices or equity
prices or farmland prices, to try to see if there is evidence of price
misalignments that are developing.
By and large, I would say that I do not see evidence at this point
in major sectors of asset price misalignments, at least of the level
that would threaten financial stability. But if we were to detect
such misalignments or other threats to financial stability, as a first
line of defense, we have a variety of supervisory tools, micro and
macro prudential, that we can use to attempt to limit the behavior
that is giving rise to those asset price misalignments.
I would not rule out using monetary policy as a tool to address
asset price misalignments, but because it is a blunt tool and because Congress has asked us to use those tools to achieve the goals
of maximum employment and price stability, which are very important goals in their own right, I would like to see monetary policy
first and foremost directed toward achieving those goals Congress
has given us and to use other tools in the first instance to try to
address potential financial stability threats. But an environment of
low interest rates can induce risky behavior, and I would not rule
out monetary policy conceivably having to play a role.
Senator MENENDEZ. Thank you.
Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Shelby.
Senator SHELBY. Thank you. Welcome, Governor.
Would you describe the portfolio of the Federal Reserve as unprecedented, the size of it today?
Ms. YELLEN. Yes, Senator.
Senator SHELBY. You are an economist, and you have been on
the Fed, and you were also the Chairman of the Economic Advisers
of President Clinton. Looking back in history, recent history, the
last 30, 40, 50 years, have you noticed any portfolio of the Fed approaching what it is today?
Ms. YELLEN. Not of the Federal Reserve, but——
Senator SHELBY. That is what I mean.
Ms. YELLEN. But other central banks——
Senator SHELBY. I am asking about the Federal Reserve of the
United States of America.
Ms. YELLEN. No, I have not, Senator.

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Senator SHELBY. OK. Would you describe what you are doing
here by—you call it ‘‘quantitative easing,’’ a term that has been
made up, I guess. We all make up terms. But is that a stimulus
toward the economy, a tool—you used the word, the term ‘‘monetary tool.’’ Is that what you would call it?—to help augment, to
stimulate the economy?
Ms. YELLEN. It is a tool that is intended to push down longerterm interest rates——
Senator SHELBY. Yes, ma’am. I understand that.
Ms. YELLEN. ——and to stimulate demand and spending in the
economy, yes.
Senator SHELBY. Is this, in the area of economics, something that
Keynes and Tobin and others have espoused over the years at
times when you have got high unemployment, to use a monetary
tool to stimulate the economy?
Ms. YELLEN. Well, Tobin and Friedman and others have——
Senator SHELBY. What about Keynes, too?
Ms. YELLEN. I do not know that Keynes actually thought about
this.
Senator SHELBY. OK.
Ms. YELLEN. But a number of economists have written about
something called the portfolio balance effect that is basically about
supply and demand, that by buying up a class of assets, it may be
possible to push up their prices and push down their yields and
thereby affect financial conditions in the economy.
Senator SHELBY. You know, it was said several years ago that
China was buying our bonds—in other words, we were totally dependent on China to buy our paper, finance our deficits, and so
forth. But isn’t it true that the Federal Reserve in the last—since
you had quantitative easing, is basically the buyer of our bonds,
our paper?
Ms. YELLEN. Well, Senator, we are purchasing——
Senator SHELBY. For the most part.
Ms. YELLEN. We are purchasing a substantial, at this point,
quantity of both Treasury and mortgage-backed, agency mortgagebacked securities. But we are certainly not doing so for the sake
of helping the Government finance the deficit. We are doing so to
achieve the goals that Congress has assigned to the Federal Reserve in circumstances where we have run out of scope for conducting additional normal monetary policy. Once our overnight interest rate target has hit zero, we really have to rely on alternative
techniques, and we are certainly not the only central bank that has
recognized this and undertaken similar programs.
Senator SHELBY. Now, you have alluded to other central banks,
but, of course, you look around the world, and I do not know of any
central bank that I think we should follow myself, and a lot of
economists do not. We should set the example here in the United
States, and the Fed has historically.
I will run out of time in a minute. Unemployment, you mentioned unemployment, stated unemployment is, what, 7.2 or 7.3
percent?
Ms. YELLEN. 7.3 percent.

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Senator SHELBY. What is the real unemployment, that is, people
that have given up looking for a job, working part-time, frustrated
by the whole system? Is it around 13, 14 percent?
Ms. YELLEN. Well, Senator, you are absolutely right that broader
measures of unemployment are much higher. Part-time employment among people who would prefer full-time jobs or more work
are at unprecedented levels, and we have seen a significant decline
in labor force participation. Part of it reflects an aging workforce.
But some of it may be a reflection of very weak labor market conditions where people who have been unemployed for a long time feel
frustrated about their job prospects.
Senator SHELBY. Could you quickly mention your views on Basel
III, how important Basel III is, how important it is for our banks
to make the standards of capital and liquidity, and also the other
banks in Europe? How important is that?
Ms. YELLEN. Senator, it is extremely important for our banks to
have more capital, higher-quality capital. Basel III putting those
rules into effect has been an important step, and there are further
steps that we will be taking with other regulators down the line
to make sure that the most systemically important institutions,
those whose failure could create financial distress, will be asked to
hold more capital and meet higher standards of liquidity and prudential supervision to make sure that they are more resilient.
Senator SHELBY. What have you learned since you were President of the San Francisco Bank? You were there during the housing bubble and the debacle. As a regulator, I hope that you and
others have learned a lot, not just the Federal Reserve but others,
that you cannot let a bubble continue to grow.
Ms. YELLEN. Senator, I think that in the aftermath of the crisis,
all of us have spent a great deal of time attempting to draw the
appropriate lessons. There have been many of them. The Federal
Reserve is very focused on a broad financial stability mandate, both
in terms of our monitoring of the economy, attempting to understand the threats that exist broadly in the financial system, and to
improve our supervision especially of the largest institutions to
make sure that we are identifying those threats that can be risks
to the economy.
Senator SHELBY. Thank you.
Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Brown.
Senator BROWN. Thank you, Mr. Chairman. Welcome, Ms.
Yellen.
When Chairman Bernanke came before this Committee 31⁄2 years
ago, he noted that the two sectors that typically pull us out of recession are housing and manufacturing—the Fed’s monetary policy
through large-scale purchases of mortgage-backed securities clearly
aimed at stimulating and promoting housing. You have spoken
compellingly about the real economy. I hope that that means a real
emphasis on manufacturing, particularly because of its impact rippling through the entire economy.
But one of my concerns is that the Fed’s monetary policy does
not do enough to serve all Americans. Last year, a journalist described the execution of monetary policy as a sort of trickle-down
economics; it boosts the price of assets like stocks and bonds and

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homes and can enrich the wealthy and Wall Street. But it is not
clear to me and, more importantly, it is not clear to the many
Americans who have not seen a raise in a number of years that
this policy increases wages and incomes for workers on Main
Street.
During your time as Chair, tell us how you will ensure that the
Fed’s monetary policy directly benefits families on Main Street in
places like Cleveland and Mansfield, Ohio?
Ms. YELLEN. Well, Senator, the objective of our policy is to broadly benefit all Americans, especially those who were seeing harm
come to them and their families from high unemployment in a recovery that has taken a long time and been, frankly, disappointing.
It is true that in the first instance the policies that the Fed conducts when we implement monetary policy drive down interest
rates, affect asset prices, and you used the term ‘‘trickle down.’’ We
tend to affect interest-sensitive spending—automobiles, housing—
but the ripple effects go through the economy and bring benefits to,
I would say, all Americans, both those who are unemployed and
find it easier to get jobs as the recovery is stronger, and also to
those who have jobs. You mentioned that wage growth has been
weak or nonexistent in real terms over the last several years. As
the economy recovers, my hope and expectation is that would
change, and if we can generate a more robust recovery in the context of price stability, that all Americans will see more meaningful
increases in their well-being.
Senator BROWN. Thank you. I in my role on this committee spend
a lot of time talking to bankers, to community bankers, to the
regionals like bankers at Key and Huntington and PNC and Fifth
Third and some of the largest six or seven or eight banks, which—
and I hear a concern from so many of these bankers across the
board that too big to fail still has not been solved. In March, Chairman Bernanke said too big to fail is not solved and gone, it is still
here. Last Friday, you, I am sure, saw the comments of the President of the New York Fed, Bill Dudley, not exactly a populist firebrand. He said that there are deep-seated cultural and ethical failures at many large financial institutions. ‘‘They have an apparent
lack of respect for law, regulation, and the public trust.’’ He said
our current regulatory efforts may not solve these problems. His
view is reinforced by the fact that DOJ currently has eight separate investigations open against the largest U.S. banks alone.
Do you agree with what I assume you are hearing from bankers,
too, and from others and do you agree with Chairman Bernanke
and Mr. Dudley that a system where too-big-to-fail institutions
have, in Dudley’s words, ‘‘an apparent lack of respect for law, regulation, or the public trust,’’ do you agree we have not solved the
problem? And what do you do as Fed Chair to address too big to
fail?
Ms. YELLEN. Senator, I would agree that addressing too big to
fail has to be among the most important goals of the post-crisis period. That must be the goal that we try to achieve. Too big to fail
is damaging. It creates moral hazard. It corrodes market discipline.
It creates a threat to financial stability, and it does unfairly, in my
view, advantage large banking firms over small ones.

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My assessment would be that we are making progress, that
Dodd-Frank put into place an agenda that, as we complete it,
should make a very meaningful difference in terms of too big to
fail. We have raised capital standards. We will raise capital standards further for the largest institutions that pose the greatest risk
by proposing so-called SIFI capital surcharges. We have on the
drawing boards the possibility of requiring that the largest banking
organizations hold additional unsecured debt at the holding company level to make sure that they are capable of resolution.
Right now the FDIC has the capacity and the legal authority to
resolve, possibly using orderly liquidation authority, a systemically
important firm that finds itself in trouble, and they have designed
an architecture that I think is very promising in terms of being
able to accomplish that.
So we are working with foreign regulators to improve the odds
of a successful resolution and continuing to put in place higher prudential standards, capital and liquidity requirements. We have put
out a proposal for a supplementary leverage requirement for the
largest banks. So I think that this agenda will make a meaningful
difference, and we are hoping to complete this in the months
ahead.
Senator BROWN. You said you look for something potentially—
something maybe to do further. How will you assess the regs put
out, the higher capital standards by the Fed, the OCC, and FDIC?
How will you assess as they go into effect if you need higher capital
requirements, not just—I mean, certainly the surcharges, but how
will you assess the effectiveness of those?
Ms. YELLEN. There are, as you know, studies that attempt to estimate what the too-big-to-fail subsidy is in the market, and while
there are a lot of question marks around those studies, we can look
to see what is happening there.
Senator BROWN. Do you believe there is a subsidy, as——
Chairman JOHNSON. Would the Senator wrap it up?
Senator BROWN. I apologize. OK. That was the last question. Do
you believe there is a subsidy, as Bloomberg and so many others
have pointed out, of tens of billions of dollars a year for the largest
banks?
Ms. YELLEN. I think there are different methodologies that are
used in different studies, and it is hard to be definitive. But, yes,
I would say most studies point to some subsidy that may reflect too
big to fail, although other factors also may account for part of the
reason that larger firms tend to face lower borrowing costs.
Senator BROWN. Thank you. I am sorry, Mr. Chairman.
Chairman JOHNSON. Senator Vitter.
Senator VITTER. Thank you, Mr. Chairman. Thank you, Dr.
Yellen.
I want to pick up where my colleague left off because, as you
know, I share his and many others’ concerns about too big to fail
being alive and well.
As both of you noted, there are many studies that document,
even try to measure too big to fail and the market subsidy or advantage that the megabanks have. Another is coming out today.
GAO is releasing its first study that Senator Brown and I asked
for and again confirms this in general. It focuses on the huge dis-

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count that the Federal Reserve offered the megabanks during the
financial crisis and the huge market advantage that they got. And,
specifically, this GAO report coming out today said—it recommended ‘‘the Federal Reserve Board finalize policies and procedures related to its emergency lending authority and establish internal timelines for developing those procedures to ensure timely
compliance with Dodd-Frank Act requirements.’’
What that means, really, is Dodd-Frank gives you the ability to
wind down that emergency lending authority. The Board has not
acted on that or even established, as far as I know, internal
timelines to do that.
So one obvious question related to this study coming out today:
Will you do that as Chairman? And when will you do it?
Ms. YELLEN. Senator, I think that that guidance is in the works,
and we will try to get it out soon.
Senator VITTER. Do you have a general timeframe in mind?
Ms. YELLEN. I am not certain just what the timeframe is, but I
will try to make sure that that happens.
Senator VITTER. OK. If I could just ask you to supplement the
record following the hearing with more specifics about the Fed’s
plan to act on Dodd-Frank with regard to that.
Ms. YELLEN. Yes.
Senator VITTER. Thank you.
You also mentioned increased leverage ratios for the biggest
banks. I agree that the action you supported in July in terms of
supplementary leverage ratio for larger banks was very positive. I
do not agree that it is enough, and I think even when you consider
the SIFI surcharge and other things, more needs to be done.
Would you support going further in terms of leverage ratios for
the largest banks or not?
Ms. YELLEN. I think we will have a very meaningful improvement in capital standards by going the approach that Dodd-Frank
has recommended, which is higher risk-based capital standards.
There will be a SIFI surcharge. We are contemplating a countercyclical capital surcharge that would add to that. We are contemplating additional ways of dealing with problems of reliance on
short-term wholesale funding that could take the form of a capital
charge that is related to reliance on that kind of funding, or it
could take the role of margin requirements.
I think a belt-and-suspenders kind of approach in which we have
a leverage requirement that serves as a backup because there are
potential issues with risk-based capital requirements. Remember
that we also have stress tests which are yet another approach to
assessing whether or not the largest systemically important institutions have the wherewithal to be able to lend, and——
Senator VITTER. I do not mean to cut you off, but if I can follow
up before my time is up, I understand those other categories, including the SIFI surcharge. But considering all those, including the
SIFI surcharge, I personally, and others, think you should go further with the supplementary leverage ratio. Would you support
that as we speak today or not?
Ms. YELLEN. I would want to see where we are when we have
implemented all of the Dodd-Frank requirements that we need to
put in place.

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Senator VITTER. OK. A final question. You have said in the past,
‘‘Like Chairman Bernanke, I strongly believe that monetary policy
is most effective when the public understands what the Fed is trying to do and how it plans to do it.’’
A lot of us would agree with that, and many of us think the best
way to get there is through true openness and transparency at the
Fed, not just a better sort of managed PR campaign but real openness and transparency.
Would you publicly support S.209? I am sure you are familiar
with that. And if not, what specific changes to that would be required to earn your public support?
Ms. YELLEN. I strongly, as I have indicated, support transparency and openness on the part of the Fed, and I think with respect to monetary policy, in terms of the range of information and
the timeliness of that information, we are one of the most transparent central banks in the world. What I would not support is a
requirement that would diminish the independence of the Federal
Reserve in implementing and deciding on implementing in monetary policy.
For 50 years Congress has recognized that there should be an exception to GAO ability to audit the Fed to avoid any political interference in monetary policy. I believe it is critically important to the
economic performance of this country—and we have seen this
around the world—that allowing a central bank to be independent
in formulating monetary policy is critical to assuring markets and
the public that we will achieve price stability. And I would be very
concerned about legislation that would subject the Federal Reserve
to short-term political pressures that could interfere with that independence.
Senator VITTER. Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Tester.
Senator TESTER. Yes, thank you, Mr. Chairman. I want to thank
you for being here, Vice Chair Yellen.
At the end of October, the Federal Reserve formally applied for
application in the—International Association of Insurance Supervisors for membership. The United States already has membership
on that through the Federal Insurance Office created by DoddFrank. Can you tell me why the Fed should have its own membership on that board and, furthermore, why there should be a focus
on that when domestic oversight challenges seem to be a much
higher priority?
Ms. YELLEN. Well, my understanding, Senator, is that now that
the Federal Reserve has been charged with supervising some of the
largest insurance companies that have been designated by FSOC
as systemic, that we want to be in a position to work with regulators in other countries, as we have in the case of banking rules,
to make sure that we have internationally compatible——
Senator TESTER. And the FIO——
Ms. YELLEN. ——appropriate standards.
Senator TESTER. Excuse me, but the FIO cannot fill that need for
you?
Ms. YELLEN. I am not certain. I think we felt it would be beneficial to participate in that group.

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Senator TESTER. OK. In our conversations about ensuring capital
standards are appropriately tailored to insurers, I raised concern in
this same vein with the FSOC, who I have encouraged to develop
industry-specific guidance and metrics for systemically important
financial institutions.
Do you agree that the FSOC has and should exercise its authority to develop industry-specific guidance and metrics rather than
forcing insurers or asset managing firms, for example, into a bankcentric regulatory model?
Ms. YELLEN. Senator, I do believe that one size fits all should not
be the model for regulation and that we need to develop appropriate models for regulation and supervision of different kinds of
institutions. Insurance certainly has some very unique features
that make them very different from banks, and we are taking the
time to try to study what the best way is to craft regulations that
would be appropriate for those organizations.
Senator TESTER. So what I am hearing you saying is that a bankcentric regulatory model would not work for insurance companies
in this country?
Ms. YELLEN. Well, there certainly are critical differences in
terms of their business models that we want to understand and respond to.
Senator TESTER. OK. I want to express a serious disappointment
with a recent decision by FSOC not to release for public comment
a study produced by the Office of Financial Research regarding the
asset management industry. While the Council has publicly indicated that it would release any metrics or guidance on this industry for public comment, it has declined to release this study, which
will presumably provide formal basis for future consideration.
If you are confirmed as Chairman of the Fed and a member of
the FSOC, will you ensure that the Council lives up to its commitment of transparency? And will the Fed support efforts to make
any potential evaluation metrics and studies on which they may
based available for public comment?
Ms. YELLEN. Senator, I have not participated in FSOC, but if I
do so, I will try to take those concerns seriously.
Senator TESTER. If you are confirmed, you will be participating
in FSOC.
Ms. YELLEN. I will.
Senator TESTER. And the question is about transparency, and it
is the transparency of metrics that are going to be used that people
need to have the ability to comment on before they are applied.
And I guess my question to you is: Will you be willing to make that
commitment to transparency as it applies to the FSOC?
Ms. YELLEN. I will need to study this issue more closely in terms
of what FSOC’s procedures are, but I feel it should be clear why
a particular firm has been designated if that occurs.
Senator TESTER. And the metrics that they are using for that
designation. OK.
In closing, I just want to say thank you for your willingness to
work on the end user issue that we discussed last week. I very
much appreciate it.
Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Kirk.

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Senator KIRK. Dr. Yellen, I would like to ask you a technical
question on behalf of large insurance employers in Illinois, to extract a commitment from you to do a cost-benefit analysis if we are
to require them to switch from SAP to GAAP accounting, which
they have warned me could cost a couple hundred million dollars.
Ms. YELLEN. Senator, I am aware that there is an issue around
different accounting standards in insurance companies. I have not
had a chance to study that myself, but I would certainly agree that
this is something that we need to look into and to consider very
carefully, and pledge to do so.
Senator KIRK. Thank you, Dr. Yellen.
Mr. Chairman, thank you.
Chairman JOHNSON. Senator Warner.
Senator WARNER. Thank you, Mr. Chairman, and thank you, Dr.
Yellen, for being here. I have a series of quick questions.
One, I guess I would like to make a comment. I understand some
of our colleagues’ concerns about, you know, some of the extraordinary measures the Fed has had to take on quantitative easing.
I guess I would simply make a comment and ask for a short response on this. Part of our political dysfunction in this town in
terms of the ability to actually grapple with getting our country’s
balance sheet right in terms of a so-called grand bargain or even
an actual budget in place, if we were able to actually perform our
functions, wouldn’t that allow you to move out of these extraordinary measures in a quicker manner?
Ms. YELLEN. Well, Senator, it is certainly the case that the economy has suffered over the last year a substantial drag from fiscal
policy. The CBO estimates that the drag amounts to something like
1.5 percent on growth, and as we commented in our FOMC statement most recently, taking account of that large amount of fiscal
drag, the economy, even though it has only been growing around
2 percent, is showing greater momentum. So I think it is fair to
say and I would expect that if there were less fiscal drag—and I
hope there will be less going forward—that the economy’s growth
rate is going to pick up.
So certainly that has been a headwind on the economy and something that we have tried to offset, but obviously our tools to do so—
it is not perfect, not——
Senator WARNER. Right. And, obviously, Government shutdowns,
which cost, the latest estimate, $24 billion or potential default
threats, which result in spikes of interest rates, sure as heck do not
provide that predictability.
I want to actually follow up as well where Senator Tester left off.
I have to say, as someone, along with my friend Senator Corker,
we are very involved in Title I and Title II, I have been personally
disappointed in the FSOC’s ability to kind of be that interagency
arbiter around regulatory conflicts. I have also been somewhat disappointed with the actions so far of the OFR, and I simply would
say I think it is a—I hope as you move into this role on the FSOC
there will be financial institutions, nonbank financial institutions
that will be SIFIs. Senator Tester mentioned asset management
firms. It did seem to me as well that the OFR’s report did not have
a lot of collaboration, did not have a lot of clarity, and I would hope
that in your role on the FSOC—and, again, I think one of the rea-

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sons why I wish we ended up with an independent chair on the
FSOC, but you will clearly have an outsized role as the Fed representative—that we try to give some clarity that we do not think
we are going to view everything through a bank-centric regulatory
prism, that we realize as we look at nonbank institutions that
maybe require that SIFI designation, that we give some clarity
about how we are going to evaluate those nonbank institutions.
Ms. YELLEN. I think that is completely fair and a very reasonable
and logical objective for FSOC to have. Our staff have been working very closely with FSOC and the OFR, trying to participate constructively and facilitate the works of those groups.
Senator WARNER. Well, I would just add my voice to Senator
Tester’s that we would like to see that transparency as we start to
evaluate nonbank institutions for SIFI designation so we kind of all
know the rules going forward. I think that would be helpful.
One of the things—as we think about balance sheets and stimulation or getting more private capital lent, one of the things I know
that the Fed pays interest on excess reserves of the banks, but I
believe now you are holding about $2.4 trillion of those banking excess reserves, and I think we pay 25 basis points. We have seen
other central banks, I think Denmark and others, start to lower
those payments. Would you consider that possibility of, in effect,
incenting the banks to get this capital not on your balance sheet
but back out into the marketplace to stimulate more loans and
more private capital into the market?
Ms. YELLEN. Senator, that is something that the FOMC has discussed and the Board has considered on past occasions, and it is
something we could consider going forward.
We have worried that if we were to lower that rate too close to
zero, we would begin to impair money market function, and that
has been a consideration on the other side. But it certainly is a possibility, Senator.
Senator WARNER. I would just say that I would ask you to look
at this as well because it is one of the ways, without necessarily
growing your balance sheet, that some of my colleagues have expressed a concern with.
Thank you.
Ms. YELLEN. Thank you, Senator.
Chairman JOHNSON. Senator Heller.
Senator HELLER. Thank you, Mr. Chairman, and, Dr. Yellen,
thank you very much for being here today. And I also want to
thank your family for taking time and showing their support. I
think that makes a real difference.
Question: Do you follow gold prices?
Ms. YELLEN. To some extent.
Senator HELLER. Do you believe there is any economic indicator
behind the rise and fall of gold prices?
Ms. YELLEN. Well, I do not think anybody has a very good model
of what makes gold prices go up or down, but certainly it is an
asset that people want to hold when they are very fearful about potential financial market catastrophe or economic troubles entail
risks. And when there is financial market turbulence, often we see
gold prices rise as people flee into them.

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Senator HELLER. Well, that was a better than I got from Chairman Bernanke last July. I asked him the same question, and he
said that nobody really understands gold prices, and he went on to
say, ‘‘And I do not pretend to really understand them either.’’ Do
you share that view, clearly with the few extra tidbits that you just
shared with us?
Ms. YELLEN. Beyond what I shared, I do not have strong views
on what drives them. I have not seen a lot of models that have
been successful in predicting them.
Senator HELLER. Thank you. You talked in your general statement at the beginning about the role of the Federal Reserve: promoting conditions that foster maximum employment, low and stable inflation, safe and sound financial system. Do you believe we
have a safe and sound financial system today?
Ms. YELLEN. I think we have a much safer and sounder financial
system than we had pre-crisis, but as I indicated, we need to do
more. We are not at the end of the road in terms of putting in place
regulations and enhanced supervision that will make the system as
safe and sound as it needs to be to contain systemic risk.
Senator HELLER. The reason I raise the question is we had this
discussion when you were in my office about community banks, and
sitting as Chairwoman of the San Francisco Federal Board, you
have a pretty good understanding of what is going on out West—
California, Nevada. And as you are aware, and as I shared with
you, we have lost half of the community banks and credit unions
in our communities, making it very, very difficult for choices, making it very difficult for housing recovery, getting loans for small
businesses. I guess the question is: What steps will you take to
avert a culture of consolidation of these major banks and the loss
of the small community banks?
Ms. YELLEN. Well, Senator, in the first place, to the extent that
the large banks have an advantage because they benefit from a toobig-to-fail subsidy, I think our objective in regulation should be to
put in place tough enough regulations and capital and liquidity
standards that would level the playing field. Since those firms do
pose systemic risk to the financial system, we should be making it
tougher for them to compete and encouraging them to be smaller
and less systemic.
And with respect to the community banks, we need a model for
supervision of them that is different and much less onerous and
has much less regulatory burden and is appropriate to their business model. We are obviously imposing on the largest systemic institutions much higher and more onerous prudential standards.
Senator HELLER. And I appreciate your comments, because I do
believe the one size fits all is what is really at a disadvantage for
the community banks and these smaller banks.
A quick question about quantitative easing. Do you see it causing
an equity bubble in today’s stock market?
Ms. YELLEN. Stock prices have risen pretty robustly, but I think
that if you look at traditional valuation measures, the kind of
things that we monitor akin to price equity ratios, you would not
see stock prices in territory that suggests bubble-like conditions.
When we look at a measure of what is called the ‘‘equity risk premium,’’ which is the differential between the expected return on

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stocks and safe assets like bonds, that premium is somewhat elevated historically, which again suggests valuations that are not in
bubble territory.
Senator HELLER. Do you believe there is a Federal role to support the stock market?
Ms. YELLEN. A Federal role to support the stock market?
Senator HELLER. A Federal role.
Ms. YELLEN. No.
Senator HELLER. Thank you.
Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Merkley.
Senator MERKLEY. Well, thank you, Mr. Chair, and thank you,
Dr. Yellen. And I do not believe any nominee for this position has
come with such an extensive set of qualifications, and it is fascinating to read the diversity of your writings over the last four
decades.
I wanted to give a special welcome to Karla Chambers, who represented Oregon very well on the Board of Directors of the Federal
Reserve Bank of San Francisco.
A number of issues have arisen in the international banking
community just since the meltdown in 2008, including LIBOR rate
manipulation, energy market manipulation, the London Whale,
massive issues related to money laundering, robo-signing fraud on
foreclosure documents. The Fed plays an important role in regulation and supervision. Can the Fed under your leadership help restore public faith in our regulatory system?
Ms. YELLEN. Senator, I feel that that is an exceptionally important goal and one that I am happy to espouse and work toward.
I absolutely feel that that is essential and appropriate, yes.
Senator MERKLEY. Thank you very much. And, second, I wanted
to ask you to address the rules that are being completed on the
Volcker Rule or firewall, which creates a wall between hedge funds
that make risky bets with funds from private investors and commercial banks that have insured deposits and access to the discount window and play an essential role in providing loans to individuals and businesses.
There has been a lot of concern that this firewall will be compromised with loopholes related to liquidity management, portfolio
hedging, and market making. Can we count on the Fed under your
leadership to work with the other regulators to produce a strong
Volcker Rule? And perhaps it will be completed before you are
there because they are in the final stages. But if so, to implement
it in a fashion that keeps faith with this goal of reducing systemic
risk by keeping the commercial banking world in the commercial
banking sphere?
Ms. YELLEN. Yes, Senator, we are working very closely and I believe constructively on this rulemaking with the other agencies. We
are certainly trying to be faithful to the intent of this rule, which
is to eliminate short-term financial speculation in institutions that
enjoy the protection of the safety net. The devil here is in the details. The rule does permit appropriate hedging in market-making
activities, and we are trying to devise a rule that will permit those
activities but absolutely be faithful to the intent that Congress had
here.

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Senator MERKLEY. Thank you. And, third, I wanted to ask you
to ponder an issue that received considerable attention regarding
commodities and the concern that under a certain situation, large
banks will be able to put their thumb on the scale through their
ownership of electric power generation facilities, pipelines, oil tankers, warehouses for key metals. And there is certainly a history in
terms of Gramm-Leach-Bliley, in terms of grandfathered commodity investments, and in terms of related activities.
But there is concern that the ability to influence supply and demand and affect price while at the same time as having the ability
to make bets on the price creates a conflict of interest that provides
essentially a hidden tax on the American economy. And the Fed
does have regulatory powers related to this, and can you maybe
chew on this a little bit in terms of your perspectives?
Ms. YELLEN. Senator, we are involved in a very comprehensive
review of commodities activities in financial holding companies. As
you indicated, we allowed some activities that we deemed to be
complementary to financial activities, and we are reviewing what
is appropriate there. In addition, Congress, as you noted, grandfathered certain activities in firms that later become financial holding companies. We want to make sure that these are conducted in
a safe and sound manner, and we may be involved in additional
rulemaking as we complete this review.
With respect to market manipulation, I would just note, though,
that it is the role and responsibility of market regulators, particularly the CFTC here, to be looking into possibilities of market manipulation and we would certainly cooperate in any look there. Our
main role is prudential and safety and soundness.
Senator MERKLEY. Well, thank you so much for being willing to
consider taking on this role at the Fed and bringing your expertise
to bear and your past public service, and I certainly wish you well.
Thank you.
Ms. YELLEN. Thank you, Senator.
Chairman JOHNSON. Senator Corker.
Senator CORKER. Thank you, Mr. Chairman. And, Dr. Yellen,
thank you for being here, and I appreciate the time in our office
and your transparency here today.
Just for the Committee’s record, if you would, share with all of
us how many rate increases you have voted for during your term
on the Federal Reserve.
Ms. YELLEN. I served as a Governor from 1994 to 1997, and we
had a cycle of rate increases during that time.
Senator CORKER. If you could just give me the number so I
can——
Ms. YELLEN. I believe 20 or more.
Senator CORKER. Twenty or more. I think it was maybe 27 or so.
Ms. YELLEN. It could be.
Senator CORKER. And how many have you voted against?
Ms. YELLEN. None.
Senator CORKER. OK. I thought that was just good to get into the
record, and I appreciate——
Ms. YELLEN. I appreciate that.
Senator CORKER. ——you very much for being here. We talked
a little bit about monetary policy, maybe more than a little bit in

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the office, and I think one of the things that we discussed was my
concern—and I think yours, too—that in many ways easy money is
an elitist policy. It is the ultimate trickle-down, and that, you
know, it is based on the premise that you are going to have this
wealth creation. And what we have seen, obviously, is the largest
Wall Street institutions have done the best and that fund managers have made a lot of money, but it generally has not trickled
down to the economy. And as you were mentioning earlier, it is a
blunt object.
Would you agree that while it has been an attempt to stimulate
the economy, the more well off have benefited much better than
those at the lower end of the spectrum?
Ms. YELLEN. Well, to the extent that low interest rates do have
an impact on asset prices, these policies have probably to some extent boosted the stock market, which may be an example of what
you are talking about. But it has also played an important role, I
think, in helping the housing sector and boosting housing prices.
And I think this is something that has been broadly beneficial to
all those Americans who own homes and has improved their sense
of financial well-being, and that is broad based.
Senator CORKER. We talked a little bit about the Fed in the early
summer began to talk about moderating the pace at which it was
going to be making purchases. And the market had a pretty stringent reaction, and the Federal Reserve appeared as if it had
touched a hot stove and that this policy was going to greatly affect,
if you will, the wealth effect that you were trying to create the policy of moderating. And so the Fed jumped back, and it seemed to
me—and I think you discussed this a little bit in the office—that
the Fed had become a prisoner to its own policy, that to really try
to step away from QE3 was really going to shatter possibly the
markets and, therefore, take away from the wealth effect.
I wonder if you could talk a little bit about some of the discussions that were taking place during that time.
Ms. YELLEN. Well, Senator, I do not think that the Fed ever can
be or should be a prisoner of the markets. Our job——
Senator CORKER. But to a degree in this case, it did affect the
Fed, did it not?
Ms. YELLEN. Well, we do have to take account of what is happening in the markets, what impact market conditions are likely to
have on spending and the economic outlook.
So it is the case—and we highlighted this in our statement—
when we saw a big jump in rates, a jump that was greater than
we would have anticipated from the statements that we made in
May and June, and particularly saw mortgage interest rates rise
in the space of a few months by over 100 basis points, we had to
ask ourselves whether or not that tightening of conditions in a sector where we were seeing a recovery, and a recovery in housing
that could drive a broader recovery in the economy, we did have
to ask ourselves whether or not that could potentially threaten
what we were trying to achieve.
But overall we are not a prisoner of the markets. I continue to
feel that we are seeing an improvement in the labor market, which
was the goal of the program, and we will continue to evaluate in-

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coming data and to make decisions on the program in that light
going forward.
Senator CORKER. Thank you. I am just a little bit of a prisoner,
maybe not fully. I understand. I would just—my last question is:
You talked a little bit about monitoring sort of the financial markets, and I know that it is—again, monetary policy is a blunt instrument. I know that you have been credited with, back in 2005,
signaling that the housing market was bubbling, if you will, in that
part of the country.
I guess my question is: Do you believe that under your leadership the Fed would have the courage to, when it saw asset bubbles,
even though you only have blunt instruments—and I realize that—
would it have the courage to actually prick those bubbles and ensure that we did not create another crisis?
Ms. YELLEN. Senator, no one who lived through that financial
crisis would ever want to risk another one that could subject the
economy to what we are painfully going through and recovering
from. And we have a variety of different tools that we could use
if we saw something like that occur. They include tools of supervision and monetary policy is a possibility——
Senator CORKER. And you would have the courage to do that?
Ms. YELLEN. I believe that I would, and I believe that this is the
most important lessons learned from the financial crisis, Senator.
Senator CORKER. Mr. Chairman, thank you for having this hearing, and, Dr. Yellen, I do want to tell you I very much appreciate
your candor and transparency. I really do. I appreciate the conversation both in the office—and I want to thank you for giving the
same answers to questioners here today that you gave in the office,
so thank you very much.
Ms. YELLEN. Thank you very much, Senator. I appreciate that.
Chairman JOHNSON. Senator Hagan.
Senator HAGAN. Thank you, Mr. Chairman. Thank you, Ranking
Member Crapo. I want to echo what I am sure everybody has stated. I have been impressed by the depth of your background, your
experience, and your expertise. We are very honored to have you
here and thank you for your testimony.
I wanted to talk about Section 716 of the Dodd-Frank Wall
Street Reform and Consumer Protection Act. Section 716 requires
that banks with access to deposit insurance or the Federal Reserve
discount window to push out certain derivatives such as equity and
commodity-based swaps in to separately capitalized affiliates.
This move would raise cost to the end users without significantly
reducing risk to the financial system. Chairman Bernanke has consistently stated that the Federal Reserve had concerns about the
swaps push-out rule prior to the enactment of Dodd-Frank and that
they still have concerns about it today.
Are your views on this issue consistent with Chairman
Bernanke’s? Would you share the view that it is a good idea to repeal parts of the swaps push-out rule?
Ms. YELLEN. Senator, as you indicated, the Federal Reserve and
other agencies did have concerns about this rule and they expressed them when Dodd-Frank was being considered. We are
working very hard to address some of the concerns around this
rule, and we think that we are likely to be able to do so. I certainly

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hope that in the final rule we will be able to effectively address
some of the concerns that people had. That is my hope. We are certainly trying to do that.
Senator HAGAN. What is your timeframe on that?
Ms. YELLEN. I believe this is something we hope to get out, hopefully, later this year.
Senator HAGAN. You could address some concerns, but not all,
without changing Section 716?
Ms. YELLEN. I believe that that is the case. We are hopeful that
we will be able to find ways to address the concerns.
Senator HAGAN. OK.
Ms. YELLEN. We understand the concerns and we are trying very
hard to——
Senator HAGAN. Do you share Chairman Bernanke’s viewpoint?
Ms. YELLEN. I believe so. About the concerns that are there and
the need to address them, I am hopeful that we will be able to do
so in the rule.
Senator HAGAN. OK. Thank you. Since the start of QE the financial markets have responded to pronouncements by the Federal
Open Markets Committee. Are you at all concerned that markets
are too driven by speeches and official pronouncements from central banks around the world? If the suggestion of tapering can contribute to volatility in asset prices, can we expect more volatility
in the future?
Ms. YELLEN. Well, at the Federal Reserve, and I think this is
true of other central banks, we are trying as hard as we can to
communicate clearly about monetary policy, both our goals and our
intentions in terms of how we carry out programs. Now, this is
challenging. We are in unprecedented circumstances. We are using
policies that have never really been tried before, and multiple policies, and we are trying to explain to the public how we intend to
conduct these policies.
So it is a work in progress, and sometimes miscommunication is
possible. But I think my own view would be we certainly want to
diminish any unnecessary volatility. Sometimes there is volatility
because we all learn news about the economy that changes our
views about the course of the economy and the course of policy, and
there it is natural to see a response.
But to diminish unnecessary volatility, I think we have to redouble our efforts to communicate as clearly as we possibly can, and
that will be my emphasis.
Senator HAGAN. Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Toomey.
Senator TOOMEY. Thank you, Mr. Chairman, and Dr. Yellen,
thank you for being here. Thanks for our chat earlier this week. I
appreciate that.
I want to get back to where—some of the issues Senator Corker
was raising regarding monetary policy. But first, I just think it is
important to stress, and I know you are very well aware of these,
but the adverse consequences that we are already experiencing directly as a result of the extraordinary monetary policy is really
problematic, I think.
We continue to have this artificially suppressed cost of funding
these excessively large deficits that we run. It contributes to, I

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would argue, fiscal imbalances. We are punishing middle class savers for years now, people who spent an entire working lifetime
choosing to forego consumption because they decided they would
save and they would have a little sum, a little bit of income in their
retirement and now they have no income because they earn nothing on their savings, but they do watch as it gradually gets eroded,
even by a low level of inflation, when they have no income from
it.
We have exacerbated the problems of under-funded pension
plans and we have got distortions in financial markets. So these
are all the things that have been occurring, I would argue, and continue to occur. And yet, what worries me perhaps even more is the
point that Senator Corker was getting to, I think, which is, what
happens when this morphine drip starts to end?
At some point, some time, this is going to be—we are going to
move away from this, I assume. I think everybody believes that.
And the assumption seems to be that the markets will behave very
benignly when that occurs. And yet, we have seen, I think, some
worry, some glimpses that maybe that is not a safe assumption.
Back in June, the mere suggestion that some of the members of
the Fed might be contemplating stepping back a little earlier, and
10-year Treasury backs up 100 basis points. Yesterday, the release
of your testimony and the equity markets rally.
Does this not feel like there is something a little artificial here,
and is it not possible that while you have many tools available to
begin and unwind, to retreat from this, that the markets may not
respond very well and that we could end up creating a real problem
as we try to exit from this?
Ms. YELLEN. Senator, you made a number of different points and
I think the first point you mentioned is that low rates, in a way,
give rise to fiscal irresponsibility, that it takes the pressure off
Congress.
Senator TOOMEY. Make it easy.
Ms. YELLEN. You know, we have established low rates in order
to get the economy moving, which is Congress’s mandate to us. I
think it is important for Congress to recognize that as the economy
recovers and both short- and long-term rates move up, a situation
in which the Government’s funding costs remain as low as they
are, if we are successful in achieving our goal of getting the economy back on track, this is a very temporary situation.
And so, I believe Members of Congress should be looking out a
few years to a time when rates are going to be higher. Low interest
rates harm savers; it is absolutely true. And this is a burden on
people who were trying to survive on the income from a CD. There
is not much they can get.
But if you think about, how can we get rates back up to normal,
I would argue that we cannot have normal rates unless the economy is normal. At the moment, we have a lot of saving and not
very much investment, and there are fundamental reasons here
why rates are low.
So pursuing a policy of low rates to get the economy moving will
be enable us to normalize policy and to get rates back to normal
levels over time.

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In terms of jumps in rates, we will, as the economy recovers,
need to withdraw the monetary accommodation we have put in
place, and we will make every effort to do so at a pace that is appropriate to continue the recovery and to maintain price stability,
and to communicate that plan to markets.
But as we have seen, and as you indicated, it is possible for rates
to jump. It is not just true now, but in previous tightening cycles
like the one we had from 1994 to 1995, where long rates moved up
over the span of 6 months over 100 basis points. We have tried to
make sure the financial system is more resilient.
In our stress tests, we have tested and continue to do so in this
round to make sure that banks are appropriately managing interest rate risk. And that is a risk that we will try to mitigate. But
it is inherent in any tightening cycle.
Senator TOOMEY. Mr. Chairman, I know I am running out of
time. Just two quick points I would like to make. One is, I would
like to express my concern, which is the exact opposite of the concern that was raised by Senator Merkley, which is, I think, the
danger of the implementation of the Volcker rule is actually—it
could be too restrictive and increase the cost of especially corporate
bond issuers.
I think the decision by Congress to exempt U.S. Treasuries was
an implicit acknowledgment that when you ban proprietary trading
in those instruments, you make them less liquid and more expensive for issuers. I am told that the next rule might very well also
exempt other sovereign issuers, which is another implicit acknowledgment of this problem.
This is a problem for corporate issuers in America and I am very
concerned that we not unnecessarily raise their cost of borrowing.
And the last point I would make is, I am deeply concerned about
the consolidation that is happening in small banks, the lack of new
small banks. As you know, we used to routinely launch sometimes
hundreds of new community banks. I am told by the FDIC there
is not a single new community bank that has been launched since
2010.
The regulatory compliance for institutions that have no systemic
risk to the economy is way overboard, and I hope you will make
an effort to diminish that burden.
Ms. YELLEN. I promise to do so, Senator.
Senator TOOMEY. All right. Thank you.
Chairman JOHNSON. Senator Warren.
Senator WARREN. Thank you, Mr. Chairman. Thank you, Dr.
Yellen.
There has been a lot of talk today about the Fed’s use of quantitative easing to try to help the economy get back on its feet. But
the truth is, if the regulators had done their jobs and reigned in
the banks, we would not need to be talking about quantitative easing because we could have avoided the 2008 crisis altogether.
So I want to focus on the Fed’s regulatory and supervisory responsibilities to keep the big banks in check. Now, I am concerned
that those responsibilities just are not a top priority for the Board
of Governors. Earlier this year, the Fed and the OCC reached a
settlement with 13 mortgage servicers that engaged in a long list
of illegal foreclosure activities, and the settlement was for over $9

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billion. It directly affected more than four million families. But the
Fed’s Board of Governors never voted on whether to accept the settlement.
Instead, this decision was just left to the staff. Now, the Fed has
smart, hardworking staff, but the Board of Governors would never
delegate critical monetary policy to them. And yet, even now, after
the biggest financial crisis in generations, the Board seems all too
willing to delegate critical regulatory and supervisory decisions.
So I think we need to make reigning in the banks a top priority
for the Board. So I know the Board meets regularly to discuss monetary policy. Do you think the Board should have regular meetings
on supervisory and regulatory issues as well, making it clear that
both of those are important to the Fed?
Ms. YELLEN. Well, Senator, I absolutely believe that our supervisory responsibilities are critical and they are just as important as
monetary policy, and we need to take them just as seriously and
devote just as much time and attention to them as we do to monetary policy.
The Board operates under a variety of restrictions. You may
know about the Government in the Sunshine Rule, and so when
you suggest that the Board meet to discuss regulatory matters, our
ability to do so outside of open meetings is very limited.
And so, we tend to handle those by meeting individually with
staff or meeting in small groups. We have a committee system
where committees are put in charge of managing particular areas
and making recommendations to the Board.
I remember in the 1990s that the Board did regularly meet to
discuss supervisory issues because there is confidential supervisory
information and it is easier for us to have a meeting. I did consider
those very valuable. And so, I think that is a very worthwhile idea.
I should just say, when there are delegations to staff and the
Board of Governors does not vote, that does not mean that Board
members are not consulted, and maybe those with expertise may
have played a critical role and had very important input, even
when there is no formal vote by the Board of Governors.
Senator WARREN. Fair enough. But I think it is an important signal here and I am glad to hear that you are thinking about this
and thinking about the question of the appropriate delegation to
staff and when it is appropriate to delegate to staff.
Could I ask you just to say something briefly about that, about
when it is appropriate to staff and when you have to retain for the
Board itself? Just very briefly, if you could, because I want to get
on to one other question.
Ms. YELLEN. I believe there are certain matters that, under law,
the Board must vote on, supervisory findings, mergers, and so
forth, or rule changes. Typically, we delegate enforcement matters
to the staff in the area of supervision.
Senator WARREN. And I am glad to hear, though, that you want
to continue to think about that, particularly when we are talking
about something this important.
Ms. YELLEN. Yes.
Senator WARREN. I want to ask you one other fundamental question here, and that is, do you think that the Fed’s lack of attention

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to regulatory and supervisory responsibilities helped lead to the
crash of 2008?
Ms. YELLEN. In the aftermath of the crisis, we have gone back
and tried to look carefully at what we should have done differently,
and there have been important lessons learned. We have massively
revamped our supervision, particularly of the largest institutions,
where we are simultaneously reviewing all of the largest institutions, and the Federal Reserve system works jointly on these reviews. We no longer delegate to individual Reserve banks the supervision of, say, one or two of these large institutions.
It has also become an interdisciplinary matter that the economists and lawyers and others are involved in. So we have learned
a lot there about supervision. I would say, one of our top priorities
now is ramping up our monitoring of the financial system as a
whole to detect financial stability risks. I think that is something
that we were not doing in an adequate basis before the crisis.
And so, we missed some of the important linkages whereby problems in mortgages would rebound through the financial system.
Senator WARREN. Thank you very much. Thank you, Mr. Chairman. I just want to say, Dr. Yellen, when you are confirmed, and
I very much hope you are confirmed, that I am glad to hear you
will make it a top priority for the Federal Reserve to engage in the
supervisory and regulatory responsibilities that help keep our financial system safe, and that cannot be something that is merely
an afterthought, but has to be a primary effort on your part.
Ms. YELLEN. Thank you, Senator. I completely agree with that.
Senator WARREN. Good. Thank you. Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Reed.
Senator REED. Well, thank you very much, Mr. Chairman, and
Governor, you demonstrated your wisdom early by going to Brown
University in Providence, Rhode Island.
Ms. YELLEN. Thank you, Senator.
Senator REED. Everything else after that is, I know, anticlimactic, but when you are confirmed as the Chairman of the Federal Reserve, it will be consistent with your record of wise selections and wise choices.
Chairman Bernanke has indicated that many times our fiscal
policy and our monetary policy have been working at cross purposes. The Federal Reserve has been quantitative easing. They
have been trying to get an expansive policy in place and we have
been contracting, shutting the Government down. We anticipate—
I hope we can avoid this—but we are going to end unemployment—
mercy unemployment insurance abruptly at December 31st.
How would your job and, obviously, the size and scope of your
portfolio and everything else, maybe the question has been asked
today, be affected if our fiscal policy was complementary to your
monetary policy?
Ms. YELLEN. Well, Senator, I agree that fiscal policy has been
working at cross purposes to monetary policy. I certainly recognize
the importance of the objective of putting the U.S. deficit and debt
on a sustainable path. Congress has worried about that and I think
it is important to do so.
But some of the near-term reductions in spending that we have
seen have certainly detracted from the momentum of the economy

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and from demand, making it harder for the Fed to get the economy
moving, making our task more difficult. And it certainly would be
helpful, going forward, if it were possible for deficit reduction efforts to focus on achieving gains in the medium term horizon and
addressing those aspects of fiscal policy that give rise to concerns
about debt sustainability over the medium term while not subtracting from the impetus that we need to keep a fragile recovery
moving forward.
Senator REED. And such a policy, a fiscal policy, would help you
in terms of what we all anticipate is the point at which you have
to begin your tapering, because basically this balance would allow
you more flexibility and more confidence that when you start to
taper it, it would not lead to a reverse to a poor economy. Is that
fair?
Ms. YELLEN. I think that is fair, Senator, because we are worried
about a fragile recovery and a more supportive fiscal policy or one
that, at least, had less drag that did no harm would make life easier.
Senator REED. Let me switch gears slightly, and that is that we
were a few weeks ago discussing the possibility of default on our
debt and the markets were beginning to react. And given the central role that Treasury securities play, not just in funding the Government, but also the tri-party repurchase markets, the collateral
markets across the globe. Were you beginning to see at the Fed
sort of ominous signs of a potential catastrophic impact of the default?
Ms. YELLEN. Well, Senator, I do believe that a default on the
U.S. debt would be catastrophic, and we did see some signs in the
run-up to the debt ceiling that suggested that financial markets
were taking notice and that there were preemptive protective actions that market participants were beginning to do to protect
themselves from what could have been catastrophic consequences.
More generally, I think we did see an impact on consumer and
business confidence that is not helpful to a general willingness to
make investments in the economy.
Senator REED. And just a final point. We have been talking a lot
about the size of your portfolio, but essentially—and I do not want
to over-simplify it—the benchmarks that typically you are looking
at is inflation and deflation and unemployment.
Ms. YELLEN. Correct.
Senator REED. And I think for a while under Chairman
Bernanke there was a real fear, particularly in 2009 and 2010, of
deflation, which would have had adverse consequences. We have
avoided that. We have avoided inflation pressures.
Ms. YELLEN. We have.
Senator REED. And what we have not yet done is got the employment numbers at a suitable level. So I think the focus, the traditional and appropriate focus is on those measures, rather than just
the absolute size of your portfolio. Is that sensible?
Ms. YELLEN. I think that is sensible, Senator. We are very focused on achieving our dual mandate, which is, we absolutely want
to avoid deflation. We have a 2 percent price stability objective. We
are trying to get the economy back to full employment. I do think
we have made progress, but we are not there yet.

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On the other hand, as we recognized from the outset of the asset
purchase program, there are costs and risks associated with a large
balance sheet.
Senator REED. Thank you. Thank you, Mr. Chairman.
Chairman JOHNSON. Senator Johanns.
Senator JOHANNS. Mr. Chairman, thank you. It is good to see you
again and thanks so much for stopping by the office the other day.
Ms. YELLEN. It is my pleasure.
Senator JOHANNS. I felt like we had a good conversation and I
would like to continue, if I could, with a few questions along the
lines of what we talked about in my office.
I found your testimony about asset bubbles to be interesting.
Just before the Chairman turned to me, I looked at where the dollar is at. It is about 15,850, an economy that, quite honestly, most
everybody would recognize as too much unemployment, an economy
where people continue to struggle, an economy where it is kind of
hard to see where the growth is going to be.
We are now starting to see real estate bidding wars, just like the
old days. Now, that is confined to cities in certain areas of the
country. We are now starting to see private equity firms, who I
think are very good at looking where the economy is headed, and
lo and behold, they are buying single family houses.
That was a shocker to me, having owned a few rentals in the
past. I was kind of amazed that they would do that. But obviously,
they see something there. And so, Dr. Yellen, I kind of look at
these factors and I think I could go on and on with some other
items, and I must admit, what am I missing here?
I see asset bubbles. And I think if you were to announce today
that over the next 24 months you are going to bring that balance
sheet down from $4 trillion to zero, or $1 trillion, I think if you
even said over the next 4 years we are going to bring it down from
$4 trillion to zero, I think we would see how big those asset bubbles are. Would you not agree with me on that?
Ms. YELLEN. With respect to real estate, we certainly are seeing,
as you mentioned, private investors come in to invest and often use
all cash in certain markets in the country. Is that evidence of an
asset bubble?
If you look at the markets where that is occurring, it is in some
of the hardest hit, the markets where prices went up the most like
Las Vegas or Phoenix. In my part of the country that had the biggest crashes where you have the largest number of foreclosures
with houses being put on the market and many of these housing
markets where these investments are taking place are ones where
you have a substantial fraction of underwater borrowers and individuals who have lost houses, whose credit is impaired, who are
not in a position to be buying houses, and these investors are purchasing these houses often at very low prices for cash and appear
to be in the business of renting them out over a reasonably long
period of time.
I would say, we have to watch this very carefully, but I do not
see that as an asset bubble. I see that as a very logical response
of the market to generate a recovery in very hard-hit areas.
Senator JOHANNS. Dr. Yellen, I do not want to be rude and interrupt you, but I am also running out of time. Here is what I would

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offer, and I think you would agree with me, although you probably
will not want to agree with me in a public hearing setting.
But I think if I were to say to you, Why do you not announce
today that you are going to draw this down over the next 24
months from $4 trillion to zero? I think you would see the impact
of your policies on the value of real estate all across the United
States, not just in the hardest hit areas. I think the real estate
that I own and others own would go down in value.
I also think that the stock market would have the same sort of
reaction that it has had when Chairman Bernanke just suggested
that there might be a phase-down here. Here is what I am saying,
because now I am out of time. I think the economy has gotten used
to the sugar you have put out there and I just worry that we are
on a sugar high.
That is a very dangerous thing for the little person out there who
is just trying to pay the bills and maybe put a buck away for retirement. The last thing I will say, the flip side of your policies that
you are advocating for are very, very hard on certain segments of
our society.
You know, explain to the senior citizen who is just hoping that
CD will earn some money so they do not have to dig into the principal, what impact you are having on a policy that says we are
going to, for as far as the eye can see or foreseeable future, keep
interest rates low. They are hurt by that policy.
Ms. YELLEN. Senator, I agree and I understand that savers are
hurt by this policy, but, if we want to get back to business as usual
and a normal monetary policy and normal interest rates, I would
say we need to do that by getting the economy back to normal. And
that is what this policy, I hope, will succeed in doing.
The other thing I think is important is to recognize that savers
wear a lot of different hats. They play many different roles in the
economy. They may be retirees who were hoping to get part-time
work in order to supplement their income. They may be people who
have children who were out of work and who were suffering because of that, or grandchildren who were going to college and coming out of college and hoped to be able to put their skills to work,
finding good jobs and entering the job market when it is strong.
I think when those people who worry about our policy, thinking
about themselves as savers, take into account the broader array of
interest they have in a strong economy, they would see that these
policies, even though they may harm them in one respect, are
broadly beneficial to them as I believe they are to all Americans.
Senator JOHANNS. My time has expired. Thank you, Mr. Chairman.
Chairman JOHNSON. Thank you. Senator Heitkamp.
Senator HEITKAMP. Thank you, Mr. Chairman. And thank you,
Dr. Yellen, for hanging in there with us. Those of us at the end of
the desk will love an opportunity to ask you some questions, as
well.
I want to get back to the Fed goal of full employment, and I want
to ask you just some quick questions. Give me a number on what
you consider full employment?
Ms. YELLEN. We do not have a precise estimate, but every 3
months all of the participants in the FOMC indicate what they

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think the normal, longer-run level of unemployment is. And in our
most recent survey, in September, the range of opinion was 5 to 6
percent.
Senator HEITKAMP. OK. And tell me, what do you believe the
real unemployment rate is today?
Ms. YELLEN. Well, the measured unemployment rate is 7.3 percent——
Senator HEITKAMP. I know what the measured unemployment
rate is. That was not the question.
Ms. YELLEN. ——but as we have discussed previously, we have
very high incidents of involuntary part-time employment. We have
all too many people who appear to have dropped out of the labor
force because they are discouraged——
Senator HEITKAMP. I do not want to belabor this Committee
hearing any longer than what I have to but would you agree that
it is at least close to or probably over 10 percent?
Ms. YELLEN. Well, certainly by broader measures, it is that high.
Senator HEITKAMP. And would you also agree that right now in
America we have the greatest income disparity that we have had
since the Great Depression, right before the Great Depression?
Ms. YELLEN. We have had widening wage inequality and income
inequality in this country going back to the mid- to late-1980s, and
that continues.
Senator HEITKAMP. So I just want to take a moment to speak for
maybe those folks who are on the lower end who look at the Fed
policy and look at the stock market, do not have a stake as they
see it—as you just explained to Senator Johanns. We all have a
stake in this economy, but they are day-to-day. They do not see a
stake. They do not see their economic condition getting any better.
And certainly, they do not see their employment opportunities getting any better, especially for those with low job skills. I will not
say low education but low job skills.
So what can you do or what you done to address income disparity, unemployment disparity in this country? And what would
you suggest that the Fed pursue to avoid the consequences longterm of that income disparity?
Ms. YELLEN. Senator, I think that you are asking about something that is a very deep problem that has afflicted the U.S. economy and other advanced economies. Economists have spent a lot of
time trying to understand what is responsible for widening inequality.
Many of the underlying factors are things that are outside of the
Federal Reserve’s ability to address.
Senator HEITKAMP. Do you believe your policies have added to
the problem?
Ms. YELLEN. I believe that the policies we have undertaken have
been meant to generate a robust recovery. I would like to see the
U.S. economy and the job market recovering more rapidly than
they are, but I believe our policies have helped.
I think, as we saw during the 1990s, when we still had trends
toward widening inequality, we did have real wage gains and we
did have a reduction in inequality when we had an exceptionally
strong and getting ever stronger job market.

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So faster growth in the United States is going to help, a stronger
job market. And you know, when the economy recovers, we are
going to see firms be more willing to undertake training when they
cannot find workers. They are going to be willing more to invest
in people, to hire, to make capital investments that will make
workers more productive when they are on the job, and we will see
greater wage gains.
Senator HEITKAMP. Just a final comment. I would suggest that
those at the bottom are not feeling the effects of these policies. The
trickle down has not happened for them. And so they struggle
every day and they may not see their wealth grow because they do
not hold a lot of assets.
And so anything that you can do, taking a look at this broader
issue—because this is an issue that will affect the American economy for years to come and affect our competitiveness in years to
come. They are the consuming class. When you look at why consumers are not consuming, because we are not getting resources to
those who do consume.
And so I thank you for your willingness to serve and look forward to a long relationship with you.
Ms. YELLEN. Thank you, Senator.
Chairman JOHNSON. Senator Manchin.
Senator MANCHIN. Thank you, Mr. Chairman. And thank you,
Ms. Yellen. I enjoyed our visit and you have done a great job today.
Let me just say this, that I look at you and think if there is a
person who involved the last time we had a balanced budget, the
last time that we would have been on track to be debt free, if you
go back to those days I am sure there was naysayers then said we
could not do it, it will never happen. But you all did it.
And then we went off the tracks. What I am asking is how we
get back on the tracks.
I know quantitative easing, you and I have a little difference of
opinion on this, or concern. I have a concern but you have a concern. You have a little, I think, broader view of what has worked
or not worked around the world. I think we spoke about Japan and
why you believe that what we are doing needs to be done.
I would only say this, if $85 billion a month in quantitative easing has not really given us the results that we desired, why would
you not recommend doing $200 billion a month? Why just $85 billion? We know that has not worked.
Of course, I have concerns with continuing it because I do not
think—as I think that Senator Johanns had said—we are on a
sugar high. The bottom line is you all have done your job. You have
done everything possible to prop up this economy. We have failed
miserably, as Congress, to do our job.
And to me, to get even a budget—we do not even have a budget—and then to say that we could have a balanced budget where
people think we are crazy, it cannot happen, it will be too harmful,
a balanced budget.
Those of us who were Governors and come from the executive
branch, that is all we understand. We had to, by law.
And then to even thing that we could be debt free in the next
generation or beyond. Do you think those are impossible or
unreachable goals?

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Ms. YELLEN. Well, Senator, I feel achieving debt sustainability
over the medium term for this country is an exceptionally important goal.
Senator MANCHIN. Could we balance a budget again?
Ms. YELLEN. It requires very tough decisions, as you know——
Senator MANCHIN. Well, you all made decisions back in the
1990s. I remember the dialog, it could not be done.
Ms. YELLEN. Well, we did make tough decisions. Congress and
the Administration made very tough decisions in the 1990s. They
did it in a way that I would think would set a model, in a sense,
for this Congress. When President Clinton was elected, the economy had high unemployment. It was just beginning to recover. The
Administration and Congress wanted to achieve deficit reduction
but to do so in a way that would not harm the economic recovery.
And so they agreed on a set of tax increases and spending cuts,
not all of which came into effect immediately but were phased in
over time.
There has been, at that time, a lot of uncertainty among businesses and in the markets, among households, about whether or
not the Government would ever balance its budget. And the response was very positive. Long-term interest rates came down.
Now the Fed had scope to use monetary policy to offset any adverse
impact on the economy. But we really did not see a lot of adverse
impact because of the fiscal tightness was phased in over a period
of years and the economy enjoyed a long and robust boom.
Senator MANCHIN. Let me just say this, that you having that experience and lived through it, worked through it, and was successful with it. And we have the utmost respect for the Reserve, yourself, and I am sure that you see the Committee has that much respect for you.
We just need you to speak out and help us a little bit more and
challenge us to do our job. If people like yourself, who are in the
know, are unwilling to challenge us I will guarantee you we do not
have the political will, it seems like, to do what needs to be done.
We have got to get our financial house in order. Every citizen in
America has to face a budget. Every one of them has to live within
that budget. And we are unwilling to make that difficult decision.
We are on not only a sugar high, we are going to go into sugar
shock pretty soon. That is what I have been talking—but unless we
hear the unbridled truth from people in the know, people who have
been there. They said you could not do it and you did it.
So it is not like it is the impossible dream. We have had budgets—we have not had one for five, going on 6 years. We have balanced budgets. And we have had surpluses. I would like to get back
to that again, and I think people like yourself can help us be
steered in that direction.
So be bold.
Ms. YELLEN. Thank you, Senator.
Senator MANCHIN. Be bold.
Ms. YELLEN. Thanks, I appreciate that.
Chairman JOHNSON. Senator Schumer.
Senator SCHUMER. Hi, thank you, Madame Chair, and thank everybody.

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I just want to follow up first on a question that Heidi Heitkamp
talked about. And I agree with Senator Manchin that the deficit is
a serious problem. It is less of a problem than it was a year or two
ago, and I know you acknowledge that. But it is not our greatest
problem.
Our greatest problem is that middle class incomes are declining
in America for the first time in American history, in my judgment,
in terms of our political economy. And the amazing thing is they
declined not just because of the recession but they actually declined
between 2001 and 2007. And serendipitously, if that is a word, the
person who alerted me to this tension was a professor at Harvard
Law School named Elizabeth Warren, who wrote articles about this
long before being a Senator was a gleam in her eye.
But it is our most serious problem. And if middle class incomes
continue to decline, they declined close to 10 percent between 2001
and today, this is going to be a different America. I tell this particularly to business executives I meet. I get in New York, ‘‘what
is all of this populism about?’’
Well, I say you know, the American people are a generous people.
And they do not mind if the people at the top income goes up 20
percent if theirs goes up 3 or 4 percent. When theirs starts going
down, it is a different story. We have never had that in America.
So my question to you is how concerned are you about this?
What impact will it have on growth and our economic potential?
And does the Fed have tools to do this? I understand this relates
to some of my Republican colleagues’ skittishness about continuing
some policies that maintain growth, but I do think—given the seriousness, at least, which I regard this problem—that the Fed has
really a dual mandate which I know you observe, which is not simply keeping inflation down and not simply monitoring the budget
deficit and its effects on our economy, but in trying to get jobs and
middle class incomes back up again.
It is so serious, and frankly no one gives it the attention that it
needs.
Ms. YELLEN. Well, Senator, I want to echo my agreement with
you that this is a very serious problem. It is not a new problem.
It is a problem that really goes back to the 1980s, in which we
have seen a huge rise in income inequality with, as you said, for
many, many years the middle and those below the middle actually
losing absolutely. And frankly, a disproportionate share of the
gains. It is not that we have not had pretty strong productivity
growth for much of this time in the country. But a disproportionate
share of those gains have gone to the top 10 percent, and even to
the top 1 percent. So this is an extremely difficult and, to my mind,
very worrisome problem.
There is a lot of research, a lot of debate about exactly what the
causes of this problem are, perhaps having to do in part with the
nature of technological change with globalization, with institutional
changes in the United States including the decline of unions. But
there are many things that are involved in this problem.
What can the Fed do? We cannot change all of those trends. The
solutions involve a multitude of things, including education, maybe
early childhood education, job training, other things.

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But what we can do is try to achieve, as we are, a robust recovery so that we create jobs, we have a stronger job market. And in
a stronger job market people who are having a lot of trouble getting jobs will be drawn into jobs. They will get better jobs. There
will be more training. People will move up job ladders and opportunities will increase.
It is not going to put an end to the problems, these long-term
structural problems that are driving this. But it will be helpful.
And I think it is the contribution the Federal Reserve can try to
make.
Senator SCHUMER. Just related to that, but in a specific, some of
my colleagues have criticized for keeping rates ‘‘artificially low.’’
But is not the zero lower bound on the short-term interest rates in
some way also artificial? So let us say rates were 5 percent today
but we had high unemployment, very low inflation. Would you not
lower rates? And is not QE2 just another way to influence interest
rates when you get close to the zero mark?
So if you did not do QE, would not real interest rates be artificially high, so to speak?
Ms. YELLEN. I think that is fair, if you judge what is high or low
by the needs of the economy. People sometimes talk about a concept called the equilibrium real rate, it is what is natural given the
levels of saving and investment in the economy. When there is a
lot of saving and not very much investment, which is where we are
now in a weak economy, the natural forces of the economy are
pushing interest rates down. And it is these forces that we are trying to go with to—if we were to try to push rates up when the economy has that much saving and such weak investment, we would
truly harm the recovery.
And of course, having pushed rates to zero, according to many estimates we would ideally have negative short-term interest rates.
Of course, we cannot achieve that. And as you indicate, that is why
we are trying to push down longer term interest rates.
Senator SCHUMER. I think you will—I think you will make a
great Chair and your Brooklyn wisdom shines through.
[Laughter.]
Ms. YELLEN. Thank you, very much. I never forget my roots and
I appreciate that.
Chairman JOHNSON. Thank you, Dr. Yellen, for your excellent
testimony.
I ask the Members of this Committee to submit any written
questions for the record for Dr. Yellen by close of business tomorrow. Dr. Yellen, please respond promptly so that the Committee
may proceed to a markup as soon as possible.
This hearing is adjourned.
[Whereupon, at 12:16 p.m., the hearing was adjourned.]
[Prepared statement, biographical sketch of nominee, and responses to written questions supplied for the record follow:]

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TO

BE

PREPARED STATEMENT OF JANET L. YELLEN
CHAIRMAN OF THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
NOVEMBER 14, 2013

Chairman Johnson, Senator Crapo, and Members of the Committee, thank you for
this opportunity to appear before you today. It has been a privilege for me to serve
the Federal Reserve at different times and in different roles over the past 36 years,
and an honor to be nominated by the President to lead the Fed as Chair of the
Board of Governors.
I approach this task with a clear understanding that the Congress has entrusted
the Federal Reserve with great responsibilities. Its decisions affect the well-being
of every American and the strength and prosperity of our Nation. That prosperity
depends most, of course, on the productiveness and enterprise of the American people, but the Federal Reserve plays a role too, promoting conditions that foster maximum employment, low and stable inflation, and a safe and sound financial system.
The past 6 years have been challenging for our Nation and difficult for many
Americans. We endured the worst financial crisis and deepest recession since the
Great Depression. The effects were severe, but they could have been far worse.
Working together, Government leaders confronted these challenges and successfully
contained the crisis. Under the wise and skillful leadership of Chairman Bernanke,
the Fed helped stabilize the financial system, arrest the steep fall in the economy,
and restart growth.
Today the economy is significantly stronger and continues to improve. The private
sector has created 7.8 million jobs since the post-crisis low for employment in 2010.
Housing, which was at the center of the crisis, seems to have turned a corner—construction, home prices, and sales are up significantly. The auto industry has made
an impressive comeback, with domestic production and sales back to near their precrisis levels.
We have made good progress, but we have farther to go to regain the ground lost
in the crisis and the recession. Unemployment is down from a peak of 10 percent,
but at 7.3 percent in October, it is still too high, reflecting a labor market and economy performing far short of their potential. At the same time, inflation has been
running below the Federal Reserve’s goal of 2 percent and is expected to continue
to do so for some time.
For these reasons, the Federal Reserve is using its monetary policy tools to promote a more robust recovery. A strong recovery will ultimately enable the Fed to
reduce its monetary accommodation and reliance on unconventional policy tools such
as asset purchases. I believe that supporting the recovery today is the surest path
to returning to a more normal approach to monetary policy.
In the past two decades, and especially under Chairman Bernanke, the Federal
Reserve has provided more and clearer information about its goals. Like the Chairman, I strongly believe that monetary policy is most effective when the public understands what the Fed is trying to do and how it plans to do it. At the request
of Chairman Bernanke, I led the effort to adopt a statement of the Federal Open
Market Committee’s (FOMC) longer-run objectives, including a 2 percent goal for inflation. I believe this statement has sent a clear and powerful message about the
FOMC’s commitment to its goals and has helped anchor the public’s expectations
that inflation will remain low and stable in the future. In this and many other
ways, the Federal Reserve has become a more open and transparent institution. I
have strongly supported this commitment to openness and transparency, and will
continue to do so if I am confirmed and serve as Chair.
The crisis revealed weaknesses in our financial system. I believe that financial institutions, the Federal Reserve, and our fellow regulators have made considerable
progress in addressing those weaknesses. Banks are stronger today, regulatory gaps
are being closed, and the financial system is more stable and more resilient. Safeguarding the United States in a global financial system requires higher standards
both here and abroad, so the Federal Reserve and other regulators have worked
with our counterparts around the globe to secure improved capital requirements and
other reforms internationally. Today, banks hold more and higher-quality capital
and liquid assets that leave them much better prepared to withstand financial turmoil. Large banks are now subject to annual ‘‘stress tests’’ designed to ensure that
they will have enough capital to continue the vital role they play in the economy,
even under highly adverse circumstances.
We have made progress in promoting a strong and stable financial system, but
here, too, important work lies ahead. I am committed to using the Fed’s supervisory
and regulatory role to reduce the threat of another financial crisis. I believe that
capital and liquidity rules and strong supervision are important tools for addressing

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the problem of financial institutions that are regarded as ‘‘too big to fail.’’ In writing
new rules, however, the Fed should continue to limit the regulatory burden for community banks and smaller institutions, taking into account their distinct role and
contributions. Overall, the Federal Reserve has sharpened its focus on financial stability and is taking that goal into consideration when carrying out its responsibilities for monetary policy. I support these developments and pledge, if confirmed, to
continue them.
Our country has come a long way since the dark days of the financial crisis, but
we have farther to go. Likewise, I believe the Federal Reserve has made significant
progress toward its goals but has more work to do.
Thank you for the opportunity to appear before you today. I would be happy to
respond to your questions.

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STATEMENT FOR COMPLETION BY PRESIDENTIAL NOMINEES
Name:

Yellen

Janet

Louise

(Last)

(First)

(Other)

Chainnan of the Board of Governors of the Federal Reserve System

Position to which nominated:
Date ofnomination:
Date of birth:

13

08

1946

(Day)

(Month)

(Year)

Place of birth: Brooklyn, New York

Marital Status: Married

Full name of spouse: George Arthur Akerlof

Name and ages of children: Robert Joseph Akerlof, 32.

Institution

Dates
attended

Brown University
Yale University

1963-67
1967-71

Education:

Honors
and awards:

Degrees
received
B.A
Ph.D.

Dates of
degrees
6/67
12171

List below all scholarships, fellowships, honorary degrees, military medals, honorary
society memberships and any other special recognitions for outstanding service or
achievement.

Phi Beta'Kappa, 1966
B.A. summa cum laude with highest honors in economics, Brown University, 1967
__ National Science Foundation Graduate Fellowship, 1967"71 Honorary Woodrow Wilson Fellowship, 1967
Guggenheim Fellow, 1986-87
Maria and Sidney Rolfe Award for National Economic Service, Women's Economic Round Table,
October 1997
Wilbur Lucius Cross Medal, Yale University, May 1997
Honorary Doctor of Laws degree, Brown University, May 1998
Honorary Doctor of Humane Letters degree, Bard College, May 2000
Fellow, American Academy of Arts and Sciences, 2001
Berkeley Fellow, 2012
Distinguished Fellow, American Economic Association, 2012

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List below all memberships and offices held in professional, fraternal, business, scholarly,
civic, charitable and other organizations.

Organization

Office held (if any)

Dates

Group of Thirty
Children's Hospital of Oakland

Member
Honorary Member, Board
ofDirectors

2009-2010

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2008-2010

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Memberships:

JASON

40

University of California
Council on Foreign Relations
National Science Foundation
American Economic Association

Pacific Council on International Policy
Western Economics Association
Macroeconomic Advisers
Delta Dental of California
California Assembly Select Committee on
Asian Trade
Jerome Levy Economics Institute
Economists for Peace and Security
American Academy of Arts and Sciences
Yale University
National Academy of Sciences
The Faculty Club, University of California
At Berkeley

Member of the Executive
Committee
Professor Emeritus
Member
Term Member
Committee of Visitors
Economics Advisory Panel
Vice President
Nominating Committee
Advisory Committee to Pres.
Member
Board ofDirectors
President
Senior Adviser
Member Bd ofDirectors

2007-2010
2006-present
2005-present
1976-1981
2004, 1996
1977-78, 1991-92
2004-2005
1988-1990
1986-1987
1971-present
2004-2008
2003-2004
2003-2004
2003-2004

Advisory Board
Board of Advisers
Trustee
Member
Fellow of the Corporation
Panel Member

2003
2002-2004
2002-2010
200 I-present
2000-2006
2000

Director
Member
Member
Yale Club of San Francisco
National Bureau of Economic Research
Research Associate
Center for International Political Economy Advisory Board
Advisory Board
Brookings Panel on Economic Activity
Senior Advisor
Member
Advisory Board
Women's Economic Roundtable
OECD High Level Sustainable
Development Group
Member
Adviser
Barter Trust
OECD Economic Policy Committee
Chair
President's Interagency Committee on
Women's Business Enterprise
Chair
British Ambassador's Advisory Committee
For the Marshall Fellowships
Member
Rollingwood Citizens Assn.
Member
Chevy Chase Recreation Assn
Member
Congressional Budget Office
Panel of Economic Advisers
International Trade and Finance Assn.
Member
Journal ofEconomic Perspectives
Associate Editor
Hadassah
Member
Committee on the Status of Women
Member
In the Economics Profession
Member
Congregation Beth EI

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2000-2002
1982-present
2000-2004; 1993-1996
1999-2010
1999-2004
1999-2004
1989-1994
1987-88,1990-91
1999-2004
1999-2001
1999-2000
1997-1999
1997-1999
1996-1997
1996-1999
1994-1999
1993-1994
1990-1994
1987-1991
1987-present
1985-1996
1983-1994

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Bay Area Council

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41

Hiller Highlands Country Club
YIjo Jahnsson Foundation

Employment record:

Member
1978-present
Lecturer on Macroeconomics 1977-1978

List below all positions held since college, including the title or description of job, name
of employment, location of work, and inclusive dates of employment.

2010 - present Vice Chainnan, Board of Governors of the Federal Reserve System, Washington, D.C.
President and Chief Executive Officer, Federal Reserve Bank of San Francisco, San
2004-2010
Francisco, California
Eugene E. and Catherine M. Trefethen Professor of Business and Professor of Economics,
1999-2004
University of California, Berkeley
Chairman, Council of Economic Advisers, The White House, Washington, D.C.
1997·1999
Member, Board of Governors of the Federal Reserve System, Washington, D.C.
1994·1997
Bernard T. Rocca Jr. Professor of International Business and Trade, Walter A. Haas School of
1992·1994
Business, University of California, Berkeley
Professor, Walter A. Haas School of Business, University of California, Berkeley
1985·1992
1982·1985
Associate Professor, School of Business Administration, University of California, Berkeley
1980·1982
Assistant Professor, School of Business Administration, University of California, Berkeley
Lecturer, London School of Economics and Political Science, London, England
1978·1980
1977·1978
Economist, Division of International Finance, Trade and Financial Studies Section, Board of
Governors of the Federal Reserve System, Washington, D.C.
1971-1976
Assistant Professor of Economics, Harvard University, Cambridge, MA.
Consultant, Division of International Finance, Board of Governors of the Federal Reserve
1974·1975
System, Washington, D.C.
19q9-1971
Teaching Fellow and Research Assistant"Yale University, New Haven, Connecticut
1967
Summer Intern, Women's Bureau, U.S. Department of Labor, Washington, D.C.

Government
Experience:

2003
2000
1997·1999
1994-1997
1993
1977-2004

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Vice Chairman, Board of Governors of the Federal Reserve System
President and CEO, Federal Reserve Bank of San Francisco (The Federal Reserve Banks
were chartered by Congress to fulfill a public purpose and are part of the Federal Reserve
System. The Federal Reserve Banks are not, however, considered Federal government
agencies and are usually not deemed to be part of the Federal government.)
California Assembly Select Committee on Asian Trade, Advisory Board, 2003
National Academy of Sciences, member of a panel on Ensuring the Best Presidential
Science and Technology Appointments
Chainnan, Council of Economic Advisers, the White House
Member, Board of Governors of the Federal Reserve System
Congressional Budget Office - Panel of Economic Advisers
National Science Foundation Committee of Visitors, Advisory Panel in Economics,
Visiting Committee and other NSF review panels

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2010·present
2004·2010

List any experience in or direct association with Federal, State, or local governments,
including any advisory, consultative, honorary or other part time service or positions.

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1977-1978
1974-1975
1974-1975
1967
Published
Writings:

Economist, Division ofIntemational Finance, Trade and Financial Studies Section, Board
of Governors of the Federal Reserve System, Washington, D.C.
Consultant, Division ofInternational Finance, Board of Governors of the Federal Reserve
System, Washington, D.C.
Consultant, Congressional Budget Office
Summer Intern, Women's Bureau, U.S. Department of Labor, Washington, D.C.

List the titles, publishers and dates of books, articles, reports or other published materials
you have written.

I have done my best to identify titles, publishers and dates of books, articles, reports or other published
materials, including a thorough review of personal files and searches of publicly available electronic databases.
Despite my searches, there may be other materials I have been unable to identify, find or remember. I have
located the following:
"Consequences of a Tax on the Brain Drain for Unemployment and Income Inequality in Less Developed
Countries," (with Rachel McCulloch), Journal ojDevelopment Economics, September 1975; reprinted
in J. Bhagwati, editor, The Brain Drain and Taxation: Theory and Empirical AnalYSis, North Holland,
1976.
"Commodity Bundling and the Burden of Monopoly," (with William James Adams), Quarterly Journal oj
Economics, August 1976.

The Limits oJthe Market in Resource Allocation (with Kenneth Arrow and Steven Shavell), Japan Trade
Council, monograph, 1977.
"FactorMobility,RegiEilai Development and the Distribution of Income," (with Rachel McCulloch), Journal oj
Political Economy, February 1977.
"What Makes Advertising Profitable?" (with William James Adams), The Economic Journal, September 1977.
"Factor Market Monopsony and the Allocation of Resources," (with Rachel McCulloch), Journal oj
International Economics, January 1980.
"On Keynesian Economics and the Economics of the Post-Keynesians," American Economic Review, Papers
and Proceedings, May 1980; reprinted in John Maynard Keynes: Critical Assessments, Vol. 4, John
Wood, editor, Croom Helm Ltd., 1983.
"Can Capital Movements Eliminate the Need for Technology Transfer?' (with Rachel McCulloch), Journal oj
International Economics, May 1982.
"Technology Transfer and the National Interest," (with Rachel McCulloch), International Economic Review,
May 1982.
".Efficiency Wage Models ofUnemp!oyment," American.Economic Review, Papers and Proceedings, May
1984; reprinted in New Keynesian Economics, Vol. 2, Coordination Failure and Real Rigidites, N.
Gregory Mankiw and David Romer, editors, MIT Press, 1991.

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"Unemployment through the Filter of Memory," (with George Akerlof), Quarterly Journal ofEconomics,
August 1985.
"A Near-Rational Model of the Business Cycle with Wage and Price Inertia," (with George Akerlof), Quarterly
Journal ofEconomics, September 1985; reprinted in New Keynesian Economics, Vol. 1, Imperfect
Competition and Sticky Prices, N. Gregory Mankiw and David Romer, editors, MIT Press, 1991.
"Can Small Deviations from Rationality Make Significant Differences to Economic Equilibria?" (With George
Akerlof), American Economic Review, September 1985.

Efficiency Wage Models ofthe Labor Market (with George Akerlof), an edited collection of papers with an
introduction by the authors, Cambridge University Press, 1986.
"Rational Models ofIrrational Behavior," (with George Akerlof) American Economic Review, Papers and
Proceedings, May 1987.
"Fairness and Unemployment," (with George Akerlof), American Economic Review, Papers and Proceedings,
May 1988.
"Discussion" of "The New Keynesian Economics and the Output-Inflation Trade-off," (with George Akerlof
and Andrew Rose) Brookings Papers on Economic Activity, 1988: 1.
"Job Switching and Job Satisfaction in the u.S. Labor Market," (with George Akerlof and Andrew Rose),
Brookings Papers on Economic Activity, 1988:2.
"Is There a J-Curve?" (with Andrew Rose), Journal
, ofMonetary Economics, July 1989.
"Introduction" to "Symposium on the Budget Deficit," Journal ofEconomic Perspectives,
Summer 1989.
"Discussion" of "The Beveridge Curve," (with George Akerlof), Brookings Papers on Economic Activity,
1989:1.
"The Fair WagelEffort Hypothesis and Unemployment," (with George Akerlof), Quarterly Journal of
Economies, May 1990.
"How Large are the Losses from Rule of Thumb Behavior in Models of the Business Cycle?" (with George
Akerlof) in William Brainard, William Nordhaus and Harold Watts, eds., Money, Macroeconomics and
Economic Policy: Essays in Honor ofJames Tobin, Cambridge, Mass: M.I.T. Press, 1991.
"East Germany In From the Cold: The Economic Aftermath of Currency Union," (with George Akerlof,
Andrew Rose and Helga Hessenius), Brookings Papers on Economic Activity, 1991:1.
"Discussion" of "Unemployment, Non-Employment and Wages: Why Has the Natural Rate Increased through
Time?" (with George Akerlof) Brookings Papers on Economic Activity, 1991 :2.

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Comment on "East German Economic Reconstruction," by Rudiger Dornbusch and Holger C. Wolf, in The
Transition in Eastern Europe, Olivier Jean Blanchard, Kenneth A. Froot and Jeffrey Sachs, editors,
NBER and University of Chicago Press, 1994.

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"Gang Behavior, Law Enforcement and Community Values," (with George Akerlof), in Henry Aaron, Thomas
Mann and Timothy Taylor, eds., Values and Public Policy, Brookings Institution, 1994.
"An Analysis of Out-of-Wedlock Childbearing in the United States," (with George Akerlof and Michael Katz),
Quarterly Journal of Economics, May 1996.
"Technology Shock, Demise of Shotgun Marriage, and the Increase in Out-of-Wedlock Births", (with George
Akerlof) Brookings Review, Fall 1996.
"An Analysis of Out-Of-Wedlock Births in the United States," (with George Akerlof) Brookings Policy Brief,
August 1996, No.5.
"Why Kids Have Kids: Don't Blame Welfare, Blame 'Technology Shock'," (with George Akerlof) Slate,
November 15, 1996, http:/www.slate.com/Features fTeenPregnancyfTeenPregnancy.asp
"Monetary Policy: Goals and Strategy," Business Economics, July 1996.
"The 'new' science of credit risk management," The Region, Federal Reserve Bank of Minneapolis, September
1996.
"Plan Helps Families, Nation," USA Today, July 30, 1997 at 12A.
"Trends in Income Inequality and Policy Responses," Looking Ahead, October 1997 and James Auerbach and
Richard Belous eds., The Inequality Paradox: Growth ofIncome Disparity, National Policy Association, 1998.
"The Continuing Importance ofTrade Liberalization," Business Economics, January 1998.

Economic Report ofthe President, February 1998. (with Jeffrey Frankel and Rebecca Blank)
Economic Report ofthe President, February 1999. (with Jeffrey Frankel and Rebecca Blank).
The Fabulous Decade: Macroeconomic Lessonsfrom the 1990s (with Alan Blinder), The Century Foundation
Press, New York, 2001. Reprinted in The Roaring Nineties: Can Full Employment be Sustained? Edited
by Alan B. Krueger and Robert Solow, Russell Sage Foundation and Century Foundation, New York,
2001. Korean translation published by the Korea Institute of Public Finance, 2003.
"Is He Making the Grade?" The International Economy, 15(5),21 (2001).
"Overview Panel Commentary," in Economic Policy for the Information Economy, Proceedings of a
Symposium Sponsored by the Federal Reserve Bank of Kansas City, Jackson Hole, Wyoming -- August 30September 1,2001.
"Discussion" of "Capital and Migration Constraints on the Economic Integration of Eastern Germany" by
Michael Burda and Jennifer Hunt, Brookings Papers on Economic Activity, 2001 :2.
"Yale Economics in Washington," Foreword to James Tobin, World Finance and Economic Stability, Edward
Elgar, London, 2002.
"The Binge Mentality in the Federal Budget," The New York Times, July 22, 2002.

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"Government Needs a Return to Fiscal Discipline," The Times Union (Albany, NY), October 27, 2002, at BI.
"Discussion" of "Robust Monetary Policy Rules," by Athanasios Orphanides and John Williams, Brookings
Papers on Economic Activity, 2002:2.
"Waiting for Worle," with George Akerlof and Andrew Rose, in Economics for an Imperfect World: Essays in
Honor ofJoseph Stiglitz, edited by Richard Arnott, Bruce Greenwald, Ravi Kanbur, and Barry Nalebuff,
M.I.T. Press, 2003.
Comments on Daniel Benjamin and David Laibson, "Good Policies for Bad Governments: Behavioral Political
Economy," Federal Reserve Bank of Boston Conference: "How Humans Behave: Implications for
Economics and Economic Policy," June 8-10,2003.
"Putting State's Budget Conundrum in Perspective," with George Akerlof and Alan Auerbach, Sacramento Bee,
July 23, 2003 at B7.
"Overview Panel Cornmentary," in Monetary Policy and Uncertainty: Adapting to a Changing Economy;
Proceedings of a Symposium Sponsored by the Federal Reserve Bank of Kansas City, Jackson Hole,
Wyoming - August 28-30, 2003.
"Coordinating Monetary and Fiscal Policies," .in Stabilizing the Economy" edited by Adam S. Posen and Benn
Steil, Blackwell Publishers, 2004.
"Foreword," to Painting the White House Green: Environmental Policy inside the Executive Office ofthe
President," edited by Randy Lutter and Jason Shogren, Resources for the Future, 2004.
"Discipline and Judgment in Monetary Policy: The Greenspan Years," presented at AEA session on
"Innovations and Issues in Monetary Policy: The Last 15 Years," January 3, 2004; American Economic
Review: Papers and Proceedings, May 2004.
"Stabilization Policy: A Reconsideration," (with George AkerJof), Presidential Address to the Western
Economic Association, Economic Inquiry, 2006 (44)1: pp. 1-22.
"Enhancing Fed Credibility," Business Economics, April 2006, pp. 45-51.
"Reflections on China's Economy," Economic Letter, Federal Reserve Bank of San Francisco, Nov. 5,2004.
"Productivity and Inflation," Economic Letter, Federal Reserve Bank of San Francisco, February 18,2005.
"Policymaking on the FOMC: Transparency and Continuity," Economic Letter, Federal Reserve Bank of San
Francisco, September 2,2005.
"2006: AYear ofTransition at the Federal Reserve," Economic Letter, Federal Reserve Bank of San Francisco,
January 27, 2006.
"Enhancing Fed Credibility," Economic Letter, Federal Reserve Bank of San Francisco, March 172006.

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"Prospects for the Economy," Economic Letter, Federal Reserve Bank of San Francisco, April 28, 2006.

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"Monetary Policy in a Global Economy," Economic Letter, Federal Reserve Bank of San Francisco, June 2,
2006.
"A Monetary Policymaker's Passage to India," Economic Letter, Federal Reserve Bank of San Francisco, July
7,2006.
"Economic Inequality in the United States," Economic Letter, Federal Reserve Bank of San Francisco,
December 1, 2006.
"Update on China: AMonetary Policymaker's Report," Economic Letter, Federal Reserve Bank of San
Francisco, March 9, 2007.
"The U.S. Economy and Monetary Policy," Economic Letter, Federal Reserve Bank of San Francisco, July 13,
2007.
"Recent Financial Developments and the U.S. Economic Outlook," Economic Letter, September 13,2007.
"The U.S. Economy and Monetary Policy," Economic Letter, Federal Reserve Bank of San Francisco,
December 7, 2007.
"Prospects for the Economy in 2008," Economic Letter, Federal Reserve Bank of San Francisco, February 8,
2008.
"Economic Conditions in Singapore and Vietnam: A Monetary Policymaker's Report," Economic Letter,
Federal Reserve Bank of San Francisco, February 22, 2008.
"The Financial Markets, Housing and the Economy," Economic Letter, Federal Reserve Bank of San Francisco,
April 18, 2008.
"The U.S. Economic Situation and the Challenges for Monetary Policy," Economic Letter, Federal Reserve
Bank of San Francisco, September 19,2008
"The Mortgage Meltdown, Financial Markets, and the Economy," Economic Letter, Federal Reserve Bank of
San Francisco, November 7, 2008.
"The Path to Recovery," Origination News, 17(12),4 (September 2008).
"Economic Conditions in Korea and Japan: A Monetary Policymaker's Report," Economic Letter, Federal
Reserve Bank of San Francisco, December 19,2008.
"U.S. Monetary Policy Objectives in the Short and Long Run," Economic Letter, Federal Reserve Bank of San
Francisco, January 9, 2009.
"A Minsky Meltdown: Lessons for Central Bankers," Economic Letter, Federal Reserve Bank of San Francisco,
May 1,2009.

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"A View of the Economic Crisis 'and the Federal Reserve's Response," Economic Letter; Federal Reserve Bank
of San Francisco, July 6, 2009.

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"Linkages between Monetary and Regulatory Policy: Lessons from the Crisis," Economic Letter, Federal
Reserve Bank of San Francisco, November 23, 2009.
"Hong Kong and China and the Global Recession," Economic Letter, Federal Reserve Bank of San Francisco,
February 8, 2010.

Political
AffIliations
and activities:

List memberships and offices held in and services rendered to all political parties or
election committees during the last 10 years.
None.

Political
Contributions:

Itemize all political contributions of $500 or more to any individual, campaign
organization, political party, political action committee or similar entity during the last
eight years and identify specific amounts, dates, and names of recipients.
None.
State fully your qualifications to serve in the position to which you have been named.

QualifIcations:

I have served as Vice Chairman of the Board of Governors of the Federal Reserve System since October
2010, as President and Chief Executive Officer of the Federal Reserve Bank of San Francisco from 2004
to 2010 and Governor of the Federal Reserve System between AugUst 1994 and February 1997.
Through this service, I have acquired experience in every area of responsibility of the Federal Reserve
System including monetary policy, fmancial stability, banking supervision and regulation, consumer and
community affairs, and the operation of the payments system.

as

With respect to monetary policy, I have participated both as a Governor and as a Reserve Bank President
in the deliberations of the the Federal Open Market Committee. During the last three years, I have
chaired the Communications subcommittee of the FOMC, which is committed to enhancing the
transparency and clarity of monetary policy communications concerning the FOMC's forecasts,
objectives and monetary policy strategy. My goal in the FOMC is to bring a thoughtful and independent
view to the FOMC's deliberations on monetary policy. My views on policy are informed by economic
analysis of macroeconomic trends relevant to assessing the economic outlook and risks to the forecast.
As a Reserve Bank President, I shared the insights that I gained through my many contacts with business
and community leaders in the Twelfth District. I have been committed to insuring that policy fosters the
attainment of the dual goals assigned to the Federal Reserve by Congress-price stability and maximum
employment.
During the last three years, I have overseen the Federal Reserve's work on financial stability, particularly
its new Office of Financial Stability, Policy and Research. In addition, I've headed the Board's
Payments System Committee, which oversees our supervision ofDesignated Financial Market Utilities
as well as regulatory policy issues pertaining to the payments system. I also chair the Board's Bank
Activities Committee, through which the Board exercises its oversight of the Reserve Banks. And I
have represented the Board in a number of international fora, including the BIS, G7 and G20. In the

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area of banking supervision, I acquired first hand experience in its conduct through my oversight of the
Federal Reserve Bank of San Francisco's banking supervision and regulation division. This division,
which operated under delegated authority from the Board of Governors and subject to the Board's
oversight and policy guidance, is responsible for supervising state member banks and bank holding
companies in the nine district states comprising the Fed's Twelfth District. As President and CEO, I
participated directly in this important supervisory work and oversaw its conduct. I believe this
experience greatly enhanced my understanding of the challenges facing supervisors in both complex
financial holding companies and smaller community banks and it has informed my thinking about the
changes that are needed in supervision and regulation to enhance the safety and soundness of the
banking system and the financial system more broadly to promote financial stability.
My training is as a professional economist with a specialty in macroeconomics and international
economics. I have published original research on a wide variety of topics in international and
macroeconomics. I am best known for my work exploring the causes of price and wage rigidity. This
work provides a basic rationale for the use of monetary policy to stabilize the economy. My research
has also focused on the causes and consequences of unemployment.
From 1980 until I joined the Federal Reserve Board as a Governor, and for five years after leaving the
Council of Economic Advisers, I served on the faculty of the Walter A. Haas School of Business at the
University of California, Berkeley where I taught international and macroeconomics in the MBA and
executive education programs of the School. Beginning in 1999, I also held a faculty appointment in
the Department of Economics.
I received my B.A. summa cum laude from Brown University in 1967 and my Ph. D. in economics from
Yale University in 1971. From 1971 to 1976 I served on the faculty of the Economics Department at
Harvard University, after which I served as an economist in the International Finance Division of the
Federal Reserve Board. I was a faculty member at the London School of Economics and Political
Science before moving to Berkeley.

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Future employment
relationships:
1. Indicate whether you will sever all connections with your present employer, business
firm, association or organization if you are confirmed by the Senate.

If I am confmned by the Senate for this position, I will remain with the same employer-the Board of Governors of the Federal Reserve System.
2. As far as can be foreseen, state whether you have any plans after completing
government service to resume employment, affiliation or practice with your previous
employer, business firm, association or organization.
I have no such plans.
3. Has anybody made you a commitment to a job after you leave government?

No.
4. Do you expect to serve the full term for which you have been appointed?

Yes.
Potential conflicts
1. Describe any fmancial arrangements or deferred compensation agreements or other
of interest:
continuing dealings with business associates, clients or customers who will be
affected by policies which you will influence in the position to which you have been
nominated.

I have accrued pension and retiree medical benefits due to my employment at the San
Francisco Fed, in which I now have a vested interest. After moving to the Board of
Governors in 2010, I have not accrued any additional benefits fmanced by the Federal
Reserve Bank of San Francisco. The Board of Governors, which I will Chair, if
confirmed, has oversight responsibility for the Federal Reserve Banks, including the
Federal Reserve Bank of San Francisco.
2. List any investments, obligations, liabilities, or other relationships which might involve
potential conflicts of interest with the position to which you have been nominated.
In connection with the nomination process, I have consulted with the Office of
Government Ethics and the Federal Reserve Board's Designated Agency Ethics Official
(DAEO) to identify potential conflicts of interest. Any potential conflicts of interest will
be resolved in accordance with the terms of an ethics agreement that I have entered into
with the Board's DAEO and that has been provided to this Committee. I am not aware of
any other potential conflicts of interest.
3. Describe any business relationship, dealing or financial transaction (other than tax

paying) which you have had during the last 10 years with the Federal Government,
whether for yourself, on behalf of a client, or acting as an agent, that might in any
way constitute or result in a possible conflict of interest with the position to which
you have been nominated.

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In connection with the nomination process, I have consulted with the Office of
Government Ethics and the Federal Reserve Board's Designated Agency Ethics Official
(DAEO) to identify potential conflicts of interest. Any potential conflicts of interest will
be resolved in accordance with the terms of an ethics agreement that I have entered into
with the Board's DAEO and that has been provided to this Committee. I am not aware of
any other potential conflicts of interest.
4. List any lobbying activity during the past ten years in which you have engaged in for
the purpose of directly or indirectly influencing the passage, defeat or modification
of any legislation at the national level of government or affecting the administration
and execution of national law or public policy.
None.

5. Explain how you will resolve any conflict of interest that may be disclosed by your
responses to the items above.
In connection with the nomination process, I have consulted with the Office of
Government Ethics and the Federal Reserve Board's Designated Agency Ethics Official
(DAEO) to identify any potential conflicts of interest. Any potential conflicts of interest
will be resolved in accordance with the terms of an ethics agreement that I have entered
into with the Board's DAEO and that has been provided to this Committee. I am not
aware of any other potential conflicts of interest.

Civil, criminal and
investigatory
1. Give the full details of any civil or criminal proceeding in which you were a defendant
actions:
or any inquiry or investigation by a Federal, State, or local agency in which you were
the subject of the inquiry or investigation.
None.
2. Give the full details of any proceeding, inquiry or investigation by any professional
association including any bar association in which you were the subject of the
proceeding, inquiry or investigation.
None.

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2. List sources, amounts and dates of all anticipated receipts from deferred income arrangements, stock options,
uncompleted contracts and other future benefits which you expect to derive from previous business relationships,
professional services and fllTll memberships or from former employers, clients, and customers.

Signed:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Date: October 24, 2013

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RESPONSES TO WRITTEN QUESTIONS OF SENATOR CRAPO
FROM JANET L. YELLEN

Q.1. The Federal Reserve is currently developing the regulatory
framework for the first nonbank financial institutions designated
by the Financial Stability Oversight Council. Chairman Bernanke
and Governor Tarullo have stated that the Collins Amendment limits the Fed’s ability to regulate insurance companies differently
than bank holding companies. Do you agree that the Fed is constrained by the Collins Amendment? If the Fed is required to apply
bank-like capital requirements to insurers, would you support bipartisan legislation to address that?
A.1. Section 171 of the Dodd-Frank Act, by its terms, requires the
appropriate Federal banking agencies to establish minimum riskbased and leverage capital requirements for bank holding companies (BHCs), savings and loan holding companies (SLHCs), and
nonbank financial companies supervised by the Board (supervised
nonbank companies) on a consolidated basis. This statutory provision further provides that these minimum capital requirements
‘‘shall not be less than’’ the generally applicable capital requirements for insured depository institutions. In addition, the minimum capital requirements cannot be ‘‘quantitatively lower than’’
the generally applicable capital requirements for insured depository
institutions that were in effect in July 2010. Section 171 does not
contain an exception from these requirements for an insurance
company (or any other type of company) that is a BHC, SLHC, or
supervised nonbank company (Board-regulated company), or for a
Board-regulated company that has an insurance company subsidiary. This requirement constrains the scope of the Board’s discretion in establishing minimum capital requirements for Boardregulated companies.
The final capital rule approved by the Board earlier this year, 1
did, however, take into consideration differences between the banking and insurance business within these constraints. The final capital rule included specific capital treatment for policy loans and
separate accounts, which are assets typically held by insurance
companies but not by banks. Additionally, the Board determined to
defer application of the final capital rule to SLHCs with significant
insurance activities (i.e., those with more than 25 percent of their
assets derived from insurance underwriting activities other than
credit insurance) and to SLHCs that are themselves State regulated insurance companies.
To the extent permitted by law, the Board continues to carefully
consider how to design capital rules for Board-regulated companies
that are insurance companies or that have subsidiaries engaged in
insurance underwriting in determining how to design an appropriate capital framework for these companies.
Q.2. The Dodd-Frank Act created an expanded regulatory structure
in which the Fed plays a significant role. Dodd-Frank significantly
expanded the Board’s regulatory authority over banking institutions, financial firms, and their subsidiaries, and new authority
over several types of other institutions, as well as to monitor finan1 See,

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cial system risk. How will you balance these expanded responsibilities with the Fed’s traditional mandate and political independence?
A.2. The Dodd-Frank Act instituted substantial changes to financial sector supervision and regulation. For instance, the Act established the multiagency Financial Stability Oversight Council
(Council), of which the Chairman of the Board is a member, in
order to promote a more comprehensive approach to monitoring
and mitigating systemic risk. In addition to the Board’s role as a
member of the Council, the Dodd-Frank Act gives the Board other
new important responsibilities. These responsibilities include supervising nonbank financial firms that are designated as systemically important by the Council, supervising thrift holding companies, and developing enhanced prudential standards—including
those for capital, liquidity, stress tests, single-counterparty credit
limits, and living will requirements—for large bank holding companies and systemically important nonbank financial firms designated by the Council. In addition, the Dodd-Frank Act expanded
the supervisory responsibilities of the Board and the other Federal
banking agencies to include consideration of the effects on financial
stability in the United States of the operations of banking organizations that we each supervise.
The Board’s duty to supervise financial institutions for safety
and soundness and financial stability is complementary to the
Board’s monetary policy mandate to pursue maximum employment,
stable prices, and moderate long-term interest rates. While the
Dodd-Frank Act expanded the Board’s supervisory and financial
stability duties, the Federal Reserve’s role as a supervisor of banking organizations is longstanding and dates from the founding of
the Federal Reserve System a century ago. The Federal Reserve
has long operated in the role of a banking supervisor as an independent agency.
The Board has made a number of internal changes to better
carry out its responsibilities. Prior to the enactment of the DoddFrank Act, we had begun to reorient our supervisory structure to
strengthen supervision of the largest, most complex financial firms,
through the creation of the Large Institution Supervision Coordinating Committee, a centralized, multidisciplinary body. Relative
to previous practices, this body makes greater use of horizontal, or
cross-firm, evaluations of the practices and portfolios of firms. It relies more on additional and improved quantitative methods for
evaluating the performance of firms, and it employs the broad
range of skills of the Federal Reserve staff more efficiently.
In addition, we have reorganized to more effectively coordinate
and integrate policy development for and supervision of systemically important financial market utilities. As the Dodd-Frank Act
recognizes, supervision should take into account the overall financial stability of the United States, in addition to the safety and
soundness of each individual firm. Our revised internal organizational structure facilitates our implementation of this
macroprudential approach to oversight.
Q.3. In December of 2012, the GAO issued a report on Dodd-Frank
implementation and found deficiencies with most agencies’ cost

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benefit analyses. One concern is that agencies are not considering
the cumulative burden of the new rules. The Board does not have
an express mandate to conduct economic analysis in connection
with its rulemakings. However, economic analysis is a useful tool
for tracking the impacts of all of these new rules. Are you willing
to perform economic and regulatory analysis for new Fed rules?
A.3. I agree that economic analysis is a useful tool for evaluating
the potential impacts of rulemakings and support the Federal Reserve’s continued use of this tool.
The Federal Reserve takes quite seriously the importance of evaluating the burdens imposed by our rulemaking efforts. To become
informed about these benefits and costs, before we develop a regulatory proposal we often collect information directly from parties
that we expect will be affected by the rulemaking through surveys
of affected parties and meetings with interested parties and their
representatives. This helps us craft a proposal that is both effective
and minimizes regulatory burden. In the rulemaking process, we
also generally seek comment from the public on the costs and benefits of our proposed approach as well as on a variety of alternative
approaches to the proposal. In adopting the final rule, we consider
a variety of alternatives and seek to adopt a regulatory alternative
that faithfully reflects the statutory provisions and the intent of
Congress while minimizing regulatory burden. We also provide an
analysis of the costs to small depository organizations of our rulemaking consistent with the Regulatory Flexibility Act and compute
the anticipated cost of paperwork consistent with the Paperwork
Reduction Act.
Q.4. With several rulemakings affecting foreign banking organizations, including under Section 165 of Dodd-Frank and the Volcker
rule, some have argued that these proposals could risk a protectionist backlash from foreign Governments that could make it more
difficult and costly for U.S. banks to operate abroad. What would
you do differently to encourage and foster international cooperation?
A.4. Since the financial crisis, the Federal Reserve has consistently
worked with its international counterparts to increase the stability
of the global financial system and to promote economic growth.
U.S. and global financial stability and the preservation of competitive equity among U.S. and foreign banks can be best achieved by
reaching global agreements on the core financial sector reforms. In
the core reform areas, our efforts have led to a number of internationally agreed regulatory approaches, such as the Basel III capital and liquidity frameworks for global banks. In some instances,
however, it has been appropriate for countries to develop different
solutions that are tailored to their unique risks, institutional situations, and industry structures.
The Board’s foreign bank proposal under section 165 of the DoddFrank Act was designed to provide a consistent platform for the supervision and regulation of the U.S. operations of foreign banks
and to help ensure that the U.S. operations of foreign banks have
sufficient capital and liquidity. The proposal was responsive to the
evolution of the foreign banking sector in the United States over
the past couple decades and to lessons learned in the financial cri-

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sis. Although the impact of potential reciprocal actions in other
markets on U.S. banking firms is difficult to forecast with precision, we do not expect the impact of such potential actions on U.S.
banking firms to be significant—principally because most of the
material foreign subsidiaries of U.S. banking firms are already subject to local, bank-like risk-based capital and other prudential requirements.
Q.5. In late 2011 the regulators issued a highly complex and
lengthy proposal to implement the Volcker rule. Because of the size
and complexity, it is essential that the regulators get this right.
Otherwise, there will be significant unintended consequences for
our financial system and economy. Some regulators are in favor or
reproposing the rule if it differs significantly from the initial proposal. Are you in favor of reproposing the Volcker rule? How would
you distinguish hedging from proprietary trading? Would you allow
portfolio-wide hedging limit risks? How would you propose that financial firms comply by 2014?
A.5. The Federal Reserve is committed to getting the rules implementing section 619 of the Dodd-Frank Act right and has been
working for some time with the FDIC, OCC, SEC, and CFTC to develop a final rule that effectively implements that section in a manner faithful to the words and purpose of the statute. We are striving to consider this rule before year-end in order to provide clarity
and certainty to the affected members of the industry and to the
public more broadly about the requirements of section 619. In developing the rule, the Federal Reserve has met with numerous
members of the public about a wide variety of issues raised by the
statute and the original agency proposal and has considered more
than 18,000 comments on the proposal.
As you note, section 619 of the DFA provides an exception from
the prohibition on proprietary trading for ‘‘risk-mitigating hedging
activities in connection with and related to individual or aggregated positions, contracts, or other holdings of the banking entity
that are designed to reduce the specific risks to the banking entity
in connection with and related to such positions, contracts and
other holdings.’’ 12 U.S.C. 1851(d)(1)(C). By its terms, the statute
permits risk-mitigating hedging of individual positions or aggregated positions of the banking entity. Risk-mitigating hedging focuses on reducing risk associated with individual or aggregated positions of the banking entity as distinguished from proprietary
trading, which focuses on attempting to achieve short-term profits
or gains. The agencies are working hard to ensure this exception
is implemented as written.
By its terms, section 619 became effective on July 21, 2012. Section 619 provides banking entities an additional 2 year period following the statute’s effective date to conform activities and investments to the prohibitions and restrictions of that section and any
final implementing regulation. 2 Under the statute, the Board may,
by rule or order, extend the 2-year conformance period for up to
three, 1-year periods, if in the judgment of the Board, an extension
is consistent with the purposes of section 619 and would not be detrimental to the public interest. The statute provides that the Board
2 See,

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may grant these extensions for not more than 1 year at a time. As
it considers the merits of adopting a final rule, the Board will also
consider the public interest in granting an extension of the conformance period.
Q.6. With a number of Fed rulemakings affecting capital in a proposed or final stage, much emphasis has been placed on increasing
the quantity of capital. Is it possible that we can end up with a
higher capital ratio but lower quality of capital? If so, what would
be the implication of that scenario on financial stability? Liquidity
and capital rules work in concert but also serve overlapping ends.
How do you view the trade-offs between higher capital and liquidity rules and, in that light, how do you view progress in both of
these areas to date?
A.6. Higher capital and liquidity standards work in concert to bolster the stability of individual institutions and the financial system, and the Federal Reserve has made significant progress in both
of these areas. We believe that it is important that large banking
firms have both sufficient capital to absorb losses and a sufficiently
strong liquidity risk profile to prevent creditor and counterparty
runs. The financial crisis demonstrated that preventing the insolvency or material financial distress of large banking firms requires
regulating both their capital adequacy and liquidity risk.
Our final Basel III capital rule strengthens the quantity and
quality of banking organizations’ capital, thus enhancing their ability to continue functioning as financial intermediaries, particularly
during stressful periods. Accordingly, the Basel III capital rule
should reduce risks to the deposit insurance fund and the chances
of taxpayer bailouts and improve the overall resilience of the U.S.
financial system. The capital requirements in the final Basel III
rule would serve as the foundation for other key initiatives designed to strengthen financial stability, including the capital plan
rule, Dodd-Frank Act stress testing, and capital surcharges for systemically important financial institutions. The Basel III capital reforms are a very important part of the global regulatory community’s effort to improve financial stability.
Our recent Basel III liquidity coverage ratio (LCR) proposal is
also a core element in our effort to strengthen the resiliency of
large banking firms. The LCR would impose standardized minimum liquidity requirements on large banking firms for the first
time. The LCR would require large banking firms to hold an
amount of high-quality liquid assets that is sufficient to meet expected net cash outflows over a 30-day time horizon in a standardized supervisory stress scenario.
There is more to be done on both the capital and liquidity fronts,
however. In particular, the Board intends to supplement the new
Basel III capital rules with a proposal to implement a risk-based
capital surcharge for the largest global systemically important
banking institutions, and is working with the Basel Committee to
develop a longer-term structural liquidity requirement.
Q.7. In the recent Basel III rule the Fed adhered to the standard
set by the Basel Committee for banks. With regard to the capital
standards for insurers, the Fed said that it is limited by the Collins
amendment in Dodd-Frank. In the recently proposed liquidity cov-

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erage ratio rule, the Fed went beyond the criteria set forth by the
Basel Committee. Can you explain when is it appropriate for the
Fed to adhere to the Basel Committee, Dodd-Frank or go beyond
the requirements set by either the Basel Committee or DoddFrank?
A.7. The Federal Reserve is bound by the applicable statutes in all
cases; accordingly, our Basel III capital rules for bank holding companies and savings and loan holding companies reflect the requirements of section 171 of the Dodd-Frank Act (the Collins amendment) and section 939A of the Dodd-Frank Act, which prohibits references to credit ratings in Federal regulations. Future capital
rules for such companies and nonbank SIFIs with substantial insurance activities will also reflect the requirements of the Collins
amendment and section 939A.
We work with our international colleagues on the Basel Committee on Banking Supervision to develop global regulatory and supervisory standards for internationally active banks. However, the
baseline standards developed by the Basel Committee do not always reflect the unique legal, supervisory, and market conditions
present in the United States and do not always provide sufficient
protection for the safety and soundness of U.S. banking firms or
U.S. financial stability. Therefore, when drafting U.S. banking
rules, we analyze the provisions of the relevant Basel standards
and in cases where it is warranted, we decide to apply different requirements in the United States. When analyzing whether to go beyond the requirements of the Basel Committee in a particular regulatory regime, we weigh the safety and soundness and financial
stability benefits of implementing stricter provisions against the
competitive equity and other potential adverse effects of the stricter provisions.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR BROWN
FROM JANET L. YELLEN

Q.1. On October 9th, the IAIS announced its plan to develop a
‘‘risk based global insurance capital standard’’ by 2016. These
bank-like capital standards would be imposed on U.S. insurers that
have not been designated nonbank systemically important financial
institutions (SIFIs) under U.S. law and were not among the insurance groups designated as Global Systemically Important Insurers
(G–SIIs) in July by the FSB. The IAIS stated in its announcement
that the development and testing in 2014 of new capital requirements for the G–SIIs will be used to inform the development of the
insurance capital standard for other internationally active insurers.
Does the Fed support this development? If not, did it voice its
concerns? If so, why are we allowing the imposition of Europeanbased, bank-centric capital standards on U.S. insurance companies
that (a) were not responsible for the financial crisis, and (b) have
not been designated as nonbank SIFIs under Dodd-Frank or among
the insurance groups designated as G–SIIs in July by the FSB?
A.1. The Federal Reserve participated in, and supported, the FSB’s
July decision to endorse the enhanced policy measures promulgated
by the IAIS for G–SIIs, including the plan to develop capital requirements for G–SIIs. As a new member of the IAIS, we plan to

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work in a coordinated manner with the other U.S. members on current IAIS initiatives, including development of international capital
standards for G–SIIs and other internationally active insurance
groups. The IAIS is comprised of insurance regulators, supervisors
and central banks from more than 130 countries around the world,
including the United States. The Federal Reserve recently became
a member of the IAIS. The Federal Insurance Office, the National
Association of Insurance Commissioners and the State insurance
departments are also members of the IAIS. The IAIS works in a
collaborative way to develop supervisory and regulatory standards
to address the solvency and financial stability risks inherent in
global insurance firms. Participation by the Federal Reserve and
other U.S. members in the IAIS helps us to better understand the
global insurance industry and to influence the development of global insurance supervisory and regulatory standards.
The IAIS is undertaking work to develop international capital requirements for G–SIIs and other internationally active insurance
groups. The work of the IAIS is conducted principally by insurance
supervisors—supervisory agencies with substantial insurance expertise and responsibility for the supervision of insurance firms. It
is my understanding the capital requirements under development
by the IAIS will be insurance-based and will address the types of
assets held and liabilities incurred by insurance firms.
Q.2. What will the Federal Reserve’s process be for developing capital standards for insurance savings and loan holding companies
and insurance SIFIs? Will the Federal Reserve propose rules that
are specific to insurance companies, and will there be a notice and
comment period and opportunity for public input? How will the Fed
ensure that these companies have a sufficient transition period to
adjust to a new capital regime?
A.2. The Board is taking additional time to evaluate the appropriate capital framework for insurance nonbank SIFIs and savings
and loan holding companies (SLHCs) that are significantly engaged
in insurance activities. We have been carefully evaluating public
comments (including industry feedback) on how to design such a
capital framework. The business model and associated risk profile
of insurance companies can differ materially from those of banking
organizations, and the Board is taking these differences into account. The Board is committed to taking the necessary amount of
time to develop workable capital requirements for insurance-related firms. To the extent permitted by law, the Board continues
to carefully consider how to design capital rules for Board-regulated companies that are insurance companies or that have subsidiaries engaged in insurance underwriting in determining how to design an appropriate capital framework for these companies.
We do not have a specific deadline for issuing a proposal, but
once we have developed a proposal, we will issue it for public notice
and comment.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR HAGAN
FROM JANET L. YELLEN

Q.1. In today’s hearing you indicated that the Federal Reserve
Board was taking steps to address certain concerns about Section

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716 of the Dodd-Frank Act through rulemaking and that a final
rule could be completed as early as this year.
As a clarification of your comments, were you referring to the
Federal Reserve Board’s interim final rule issued on June 5, 2013,
regarding the treatment of uninsured U.S. branches and agencies
of foreign banks under Section 716, or were you referring to some
other regulatory effort to interpret or address concerns about Section 716?
A.1. I was referring in my testimony to the interim final rule
issued by the Federal Reserve to address the problem created by
section 716 for U.S. branches and agencies of foreign banks. As you
know, U.S. branches and agencies of foreign banks, by statute,
have access to the Federal Reserve discount window in the same
manner as insured depository institutions. It is this treatment of
U.S. branches and agencies of foreign banks that causes them to
become subject to section 716. Consequently, the Federal Reserve
proposed to treat these branches and agencies as insured depository institutions for all purposes under section 716. We have received a few comments on this interim rule and, as I mentioned at
the hearing, we expect to consider final action on it by year-end.
Q.2. In today’s hearing you discussed the Financial Stability Oversight Council’s process for the consideration and designation of
nonbank systemically important financial institutions with Senator
Tester.
Senator Tester: If you’re confirmed, you will be participating in FSOC. And the question is about transparency
and it’s the transparency of metrics that will be used that
people need to have the ability to comment on before they
are applied. And I guess my question to you is will you be
willing to make that commitment to transparency as it applied to FSOC?
Governor Yellen: I will need to study this issue more closely in terms of what FSOC’s procedures are, but I feel it
should be clear why a particular firm has been designated
if that occurs.
As a clarification, if you are confirmed, will you support a transparent process for the consideration and designation of nonbank
systemically important financial institutions that includes the release of any determination metrics for asset managers before those
metrics are applied—as Senator Tester stated and regulators have
indicated—and not after the designation has occurred, as your answer suggests.
A.2. Designation has significant implications for a company, so it
is important that the designation framework and process is careful
and deliberative. To implement this authority, the FSOC developed
a framework and criteria and sought public comments twice on the
designation framework. After publishing guidance, FSOC began the
process of assessing individual companies from a list of companies
that met the quantitative criteria set out in the guidance. The
guidance is available at: http://www.treasury.gov/initiatives/fsoc/
documents/nonbank%20designations%20-%20final%20rule%
20and%20guidance.pdf.

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The OFR study on Asset Management and Financial Stability did
not propose any metrics for the FSOC to use to consider asset management firms for designation. If the FSOC develops metrics for
asset manager firms beyond the metrics in the current guidance,
if confirmed, I would support that it provide the public an opportunity to review and comment on any proposed metrics.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR WARREN
FROM JANET L. YELLEN

Q.1. As you know, Congress has mandated that the Federal Reserve use monetary policy to achieve maximum employment while
maintaining price stability and moderate long-term interest rates.
At its December 2012 meeting, the Federal Reserve stated that it
would continue to keep interest rates low until the unemployment
rate reached 6.5 percent. Yet a 6.5 percent unemployment rate does
not reflect maximum employment. As you testified, members of the
Federal Open Market Committee stated in response to a September
2013 survey that an unemployment rate of between 5 percent and
6 percent would more accurately represent maximum employment.
The difference between a 6.5 percent unemployment rate and an
unemployment rate between 5 percent and 6 percent is hundreds
of thousands of jobs. Do you think the Federal Reserve must lower
its unemployment rate target to fulfill its statutory mandate of
pursuing maximum employment?
A.1. In December of 2012, the FOMC established economic thresholds to provide greater clarity to the public about the period over
which short-term interest rates could be expected to remain at current exceptionally low levels. In particular, the committee indicated
that an exceptionally low range for the Federal funds rate would
remain appropriate at least as long as the unemployment rate remained above 6.5 percent and projected inflation between 1 and 2
years ahead remains below 2.5 percent. It is important to note that
these economic thresholds for the Federal funds rate are not our
long-run goals for monetary policy. Rather, they are intended as
useful benchmarks for the public in understanding how the level
of the Federal funds rate may evolve over time.
Indeed, in its September economic projections, FOMC participants’ estimates of the longer-run normal rate of unemployment
had a central tendency of 5.2 percent to 5.8 percent. In essence,
this is the unemployment range that the committee believes that
the economy can achieve over the longer run.
It is also important to note that the thresholds are not triggers—
that is, once a threshold has been crossed, the committee will not
necessarily raise the Federal funds rate target immediately. Instead, crossing a threshold will lead the committee to consider
whether an increase in rates would be appropriate, with the FOMC
determining the appropriate stance of monetary policy based on its
assessment of the economic outlook. We will, as always, follow a
balanced approach in fostering our objectives of maximum employment and stable prices. Under that approach, as Chairman
Bernanke has said, monetary policy is likely to remain highly accommodative long after one of the economic thresholds for the Federal funds rate has been crossed. For example, in their economic

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and policy projections prepared for the September FOMC meeting,
many FOMC participants anticipated that the Federal funds rate
at the end of 2016 would be at or below a level of about 2 percent,
well below the anticipated long-run level of the Federal funds rate
of about 4 percent. These FOMC participants judged that continued
highly accommodative policy over an extended period would likely
be appropriate to achieve and maintain our congressionally mandated objectives of maximum employment and stable prices.
Q.2. I am interested in your views on the following question, which
I asked Governor Tarullo on July 11, 2013. Under 12 U.S.C.
§1818(e), Federal banking agencies may remove ‘‘institution-affiliated parties’’ from participation in the affairs of an insured depository when they directly or indirectly violate banking laws or regulations. Were officers or directors of any bank that was party to the
mortgage servicer settlements removed because they directly or indirectly participated in the violations that led to the settlements?
If no officer or director was removed, can you explain why?
A.2. I fully support the use of the full range of the Federal Reserve’s enforcement tools, including actions to bar insiders of banking organizations from the banking business, where appropriate.
The statutory requirements to bring a removal or prohibition action
are rigorous. Under 12 U.S.C. §1818(e), the Board must initially
find that the insider engaged in a violation of law, unsafe or unsound practice, or a breach of fiduciary duty that resulted in a benefit to the insider, a loss to the institution, or prejudice to the
bank’s depositors. In addition, the Board must determine that the
conduct involved personal dishonesty or willful or continuing disregard for the safety and soundness of the institution. This standard does not permit an action against an insider whose conduct
only involved poor, or even negligent, business decisions that resulted in losses to an institution. There must be additional evidence showing heightened culpability, such as personal dishonesty
or reckless or willful disregard for safety and soundness.
Applying these standards, the Federal Reserve has not, to date,
taken any actions removing or prohibiting insiders of the mortgage
servicing organizations that were subject to the 2011 and 2012
mortgage servicing enforcement actions for their conduct in connection with servicing or foreclosure activities. We are, however, continuing to investigate whether such removal or prohibition actions
are appropriate.
In the past 5 years, the Federal Reserve has issued 68 prohibition orders, including several orders that also assessed a civil
money penalty. Also in the past 5 years, the Federal Reserve has
notified more than 200 individuals that they are banned by statute
from banking under section 19 of the Federal Deposit Insurance
Act (12 U.S.C. §1829). Section 19 prohibits a person convicted of a
criminal offense involving dishonesty or a breach of trust from directly or indirectly owning, controlling, or participating in the affairs of any insured depository institution, or a bank or savings and
loan holding company without the consent of the FDIC in the case
of an insured depository institution, or of the Federal Reserve in
the case of a holding company. The Federal Reserve has worked
with the Department of Justice as it determines whether to bring

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criminal actions against individuals, including in connection with
mortgage servicing and foreclosure activities.
Q.3. You testified that the Federal Reserve’s supervisory responsibilities should be just as important as its monetary policy responsibilities. If that is to be the case, the Federal Reserve needs to
dedicate enough staff to supervision—particularly for the largest,
most complex financial institutions. Otherwise, significant problems will likely remain undetected until it is too late.
According to the Federal Reserve System’s 2013 Budget, there
are 412 staff budgeted for Bank Supervision and Regulation at the
Board of Governors, and another 3,904 staff budgeted for Supervision and Regulation at the Federal Reserve Banks. How many of
these staff are assigned full-time to supervision of the six largest
bank holding companies (JPMorgan Chase & Co., Bank of America
Corporation, Citigroup, Inc., Wells Fargo & Company, The Goldman Sachs Group, and Morgan Stanley), which collectively hold far
more than half of the total banking assets in the country? Given
that a bank holding company like Citigroup dedicates several thousand of its employees to risk management and internal auditing,
do you think the Federal Reserve needs to significantly increase
the number of staff dedicated to supervising the largest financial
institutions in order to carry out its supervisory responsibilities?
A.3. As a result of lessons learned from the financial crisis, the
Federal Reserve has taken a number of steps to strengthen its ongoing supervision of the largest, most complex banking firms. Most
importantly, we established the Large Institution Supervision Coordinating Committee (LISCC) to ensure that oversight and supervision of the largest firms incorporates a broader range of internal
perspectives and expertise; involves regular, simultaneous, horizontal (cross-firm) supervisory exercises; and is overseen through a
centralized process to facilitate consistent supervision and the resolution of issues that may be present at more than one firm.
The LISCC is chaired by the Director of the Board’s Division of
Banking Supervision and Regulation and includes senior bank supervisors from the Board and relevant Reserve Banks as well as
senior Federal Reserve staff from the financial stability, research
and legal divisions, as well as from each of the other divisions at
the Board and from the Markets and payment systems groups at
the Federal Reserve Bank of New York. The LISCC provides strategic and policy direction for supervisory activities at the largest
bank holding companies (BHCs) across the Federal Reserve System
and, to date, has developed and administered important new supervisory exercises focused on the largest firms, most notably including the Federal Reserve’s annual supervisory stress tests and the
related annual reviews of capital adequacy and internal capital
planning practices at the Nation’s largest BHCs.
At the largest BHCs, the Federal Reserve has on-site teams in
place full time. At the six firms mentioned in your question, there
are approximately 215 Federal Reserve staff members on the onsite teams. The work of these teams, however, is just one piece of
the supervision program for these firms. The work of the on-site
teams is supported and complemented by System-wide teams of
specialists, including those focused on credit, market and oper-

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ational risk management, compliance, capital adequacy and capital
planning assessments, liquidity and funding, and stress testing
practices. All of these System-wide teams participate in the supervision of the firms in the LISCC portfolio.
In addition to the on-site teams, we have approximately 200 experts from across the Federal Reserve involved in the annual comprehensive capital analysis and review (CCAR) that focus on assessments of the risk measurement, stress testing and internal capital planning practices supporting the 8 largest firms’ capital planning processes. Also, there are approximately 100 economists, supervisors, and other specialists that carry out the annual supervisory stress testing, which is applied to the 30 largest domestic
BHCs, including those mentioned in your question. Furthermore,
the Office of the Comptroller of the Currency also has supervisory
staff that supervise large national banks, including Wells Fargo,
JPMorgan Chase, Citigroup, Inc., and Bank of America Corporation. We coordinate with the OCC in supervisory planning and the
execution of supervisory activities of these firms.
We are still adding more personnel that will be devoted to supervision of systemically important firms. Staffing needs are being
driven by further focus on and enhancements to the supervision
program for the largest U.S. banking firms, FSOC-designated
nonbank SIFIs, and the U.S. operations of large foreign banking organizations.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR VITTER
FROM JANET L. YELLEN

Q.1. The GAO reports that ‘‘Although the Dodd-Frank Act requires
the Federal Reserve Board to promulgate regulations that establish
policies and procedures governing any future lending under section
13(3) authority, Federal Reserve Board officials told us that they
have not yet drafted these policies and procedures and have not set
timeframes for doing so.’’ At the hearing, I asked you to submit for
the record the Federal Reserve’s detailed plans for how the it will
implement the Dodd-Frank requirements to limit the Federal Reserve’s bailout including a time line for drafting and implementing
these rules along with how the Fed proposes to implement these
rules. Please submit those details here for the record.
A.1. The Dodd-Frank Act made several major changes to the statutory text of section 13(3). The Federal Reserve believes that the
provisions enacted in the Dodd-Frank Act governing its emergency
lending authority have governed the use of that authority since enactment of that act. The Federal Reserve has undertaken substantial work both internally and with other agencies on the policies
and procedures intended to implement the Dodd-Frank Act amendments to section 13(3). The Board expects to issue a proposal for
public comment on the section 13(3) policies and procedures shortly.
Q.2. I have heard from many, including Senator Collins and a
number of lawyers, that the minimum capital requirements of Section 171 of Dodd-Frank, commonly referred to as the Collins
amendment, that the Federal Reserve Board of Governors has sufficient flexibility as to how it will apply the minimum capital

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standards to nonbank financial companies primarily engaged in the
insurance business that are designated as SIFIs by FSOC. It seems
that the Federal Reserve lawyers are the only ones who believe the
Fed needs additional legislation passed to give them flexibility in
how to apply this capital requirement to insurance companies. Are
you aware of the issue?
• Do you believe that insurance companies should have banklike capital standards or is that a different industry, holding
different assets and needing a different set of requirements?
• Some attorneys of insurance companies have argued that the
Board could determine the application of bank-centric capital
requirements under the Collins amendment would be duplicative of the Risk-Based Capital framework and that the Board
could take appropriate action to avoid that duplication. Or,
since section 171 does not provide proscriptive capital standards the Board has the ability to tailor standards for insurance
companies differently. Have you looked at that issue and do
you think that argument has merit?
• Has the Federal Reserve fully taken into consideration the
clear congressional intent embodied in Section 165 of the DoddFrank Act that requires the Board to ‘‘tailor’’ prudential rules,
including capital requirements, that are applied to nonbank
SIFIs? Why exactly do you believe the Collins Amendment
overrides the clear statutory language in Section 165?
• In addition to the clear directive to the Board in Section 165
to ‘‘tailor’’ the rules for insurer nonbank SIFIs, Section 616 of
Dodd-Frank includes a general directive that gives the Board
sufficient discretion to ensure that capital standards for insurers—both nonbank SIFI and thrift insurers—are appropriately
aligned with insurance risk, rather than bank risk. It is clear
that Congress did not intend for bank-centric capital rules to
be applied to insurers. And no one seems to be arguing that
a bank capital regime is appropriate for insurers. So what is
the Board’s plan for addressing this issue? Will you issue a
proposed rule specifically for insurance capital requirements,
and if so, when?
A.2. Section 171 of the Dodd-Frank Act, by its terms, requires the
appropriate Federal banking agencies to establish minimum riskbased and leverage capital requirements for bank holding companies (BHCs), savings and loan holding companies (SLHCs), and
nonbank financial companies supervised by the Board (supervised
nonbank companies) on a consolidated basis. This statutory provision further provides that these minimum capital requirements
‘‘shall not be less than’’ the generally applicable capital requirements for insured depository institutions. In addition, the minimum capital requirements cannot be ‘‘quantitatively lower than’’
the generally applicable capital requirements for insured depository
institutions that were in effect in July 2010. Section 171 does not
contain an exception from these requirements for an insurance
company (or any other type of company) that is a BHC, SLHC, or
supervised nonbank company (Board-regulated company), or for a
Board-regulated company that has an insurance company subsidiary. This requirement constrains the scope of the Board’s dis-

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cretion in establishing minimum capital requirements for Boardregulated companies.
The final capital rule approved by the Board earlier this year, 1
did, however, take into consideration differences between the banking and insurance business within these constraints. The final capital rule included specific capital treatment for policy loans and
separate accounts, which are assets typically held by insurance
companies but not by banks. Additionally, the Board determined to
defer application of the final capital rule to SLHCs with significant
insurance activities (i.e., those with more than 25 percent of their
assets derived from insurance underwriting activities other than
credit insurance) and to SLHCs that are themselves State regulated insurance companies.
To the extent permitted by law, the Board continues to carefully
consider how to design capital rules for Board-regulated companies
that are insurance companies or that have subsidiaries engaged in
insurance underwriting in determining how to design an appropriate capital framework for these companies.
Q.3. On Tuesday, Andrew Huszar published a piece in the Wall
Street Journal entitled ‘‘Confessions of a Quantitative Easer’’. It is
a significant piece because of the job that Mr. Huszar used to hold.
In 2009–10, he managed the Federal Reserve’s $1.25 trillion agency
mortgage-backed security purchase program. As the person responsible for executing the Fed’s experimental and risky monetary policy known as ‘‘quantitative easing’’ he had a simple message, ‘‘I’m
sorry, America.’’ And, that the Fed ‘‘has allowed QE to become Wall
Street’s new ‘too big to fail’ policy.’’
Mr. Huszar described the primary goal in rolling the dice with
QE was to ‘‘to drive down the cost of credit so that more Americans
hurting from the tanking economy could use it to weather the
downturn.’’ And he laments that when the trading for the first
round of QE ended on March 31, 2010, ‘‘[t]he final results confirmed that, while there had been only trivial relief for Main
Street, the U.S. central bank’s bond purchases had been an absolute coup for Wall Street. The banks hadn’t just benefited from the
lower cost of making loans. They’d also enjoyed huge capital gains
on the rising values of their securities holdings and fat commissions from brokering most of the Fed’s QE transactions. Wall
Street had experienced its most profitable year ever in 2009, and
2010 was starting off in much the same way.’’ However, more than
31⁄2 years later the Fed continues to purchase about $85 billion in
bonds each month and delaying any reduction in its purchases. Do
you disagree with Mr. Hauser’s assertion that QE is Wall Street’s
new ‘‘Too Big to Fail’’ policy, if so, why?
A.3. The FOMC’s asset purchases are aimed at promoting the Federal Reserve’s statutory objectives of maximum employment and
stable prices. By putting downward pressure on longer-term interest rates and helping to make financial conditions more accommodative, the Federal Reserve’s asset purchases have supported a
stronger economic recovery, improved labor market conditions, and
helped keep inflation closer to its 2 percent objective. In particular,
lower interest rates have allowed many homeowners to refinance
1 See,

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their mortgages at lower rates and thus supported growth in consumer spending. Lower mortgage rates also have helped to
strengthen home sales and housing construction. In addition, lower
interest rates have boosted auto sales. Through these channels, our
asset purchases have helped strengthen growth and employment.
Moreover, the Federal Reserve’s asset purchases have helped to
guard against disinflationary pressures that could otherwise have
exacerbated the debt burdens faced by some households and businesses. In all of these ways, our asset purchases have benefited
American families and Main Street businesses.
It is important to emphasize our asset purchases have been conducted in the open market and have followed a competitive process.
The changes in overall financial conditions spurred by our asset
purchases have not been directed toward benefiting any particular
institution or class of institutions. Rather, by strengthening the
economic recovery, fostering improved labor market conditions, and
maintaining stable inflation and inflation expectations, the Federal
Reserve’s asset purchase programs have benefited all Americans.
Q.4. At Jackson Hole speech Chairman Bernanke talked about the
tradeoffs associated with this experimental monetary policy—
namely higher liquidity premiums on Treasury securities, lack of
confidence in the Fed’s ability to exit smoothly from its extremely
accommodative policies, and risk to financial stability by driving
longer-term yields lower incentivizing risky behavior in the markets. It seems to me that Mr. Huszer and Mohammed El Erian at
the PIMCO investment firm are right when they point out—‘‘that
the Fed may have created and spent over $4 trillion for a total return as little as 0.25 percent of GDP, that QE really isn’t working.’’
As someone who is viewed as very dovish, in favor of continuing
or being more aggressive with these accommodative monetary policies, why haven’t we reached the tipping point where the costs and
risks associated with this experiment outweigh the benefits?
A.4. A growing body of research by economists at central banks
and academic institutions has found that asset purchases by central banks help to lower longer-term interest rates and ease financial conditions. These developments, in turn, help to foster a
stronger economic recovery, improved labor market conditions, and
stable inflation and inflation expectations. While monetary policy is
not a panacea for all of the Nation’s economic difficulties, our economic situation would almost certainly be far worse had the Federal Reserve not acted aggressively to address the severe economic
shock stemming from the financial crisis and the continuing
headwinds that have slowed the economic recovery. The historical
precedents of the United States in the 1930s and Japan since the
1990s provide sobering examples of the potential costs when central banks fail to adequately address severe economic and financial
shocks.
While a strong majority of the FOMC judges that asset purchases have been effective in fostering its macroeconomic objectives, the committee is aware of the potential costs and risks associated with asset purchases. As noted in the minutes of recent
FOMC meetings, policy makers have noted various potential risks
of asset purchases, including possible challenges in removing policy

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accommodation at the appropriate time and the possibility of encouraging imprudent risk-taking in the financial sector. Regarding
challenges associated with exit, the Federal Reserve has developed,
and is continuing to refine, a range of tools that will allow the Federal Reserve to remove policy accommodation at the appropriate
time. Regarding excessive risk-taking in financial markets, there
are few signs to date of the types of financial imbalances and excessive reliance on leverage that were evident in the runup to the financial crisis. That said, the Federal Reserve is monitoring financial markets very carefully for signs of excessive risk-taking and is
prepared to take supervisory and other policy actions as appropriate to address developments that could pose a threat to financial
stability.
On balance, the FOMC has judged that the economic benefits of
continued asset purchases outweigh the potential costs. However,
asset purchases are not on a preset course and the pace of asset
purchase will remain contingent on the economic outlook and the
FOMC’s ongoing assessment of their likely efficacy and costs.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR JOHANNS
FROM JANET L. YELLEN

Q.1. How active is the Federal Reserve with the Financial Stability
Board (FSB) on insurance issues? How does the Fed coordinate its
insurance-related work within the FSB with Treasury and State
regulators?
A.1. As a member of the FSB, the Federal Reserve participates actively in discussions and decisions with respect to insurance-related
issues. The Federal Reserve recently joined the International Association of Insurance Supervisors (IAIS), the international standard
setting body for insurance. The Federal Reserve is working with
the other U.S. members of the IAIS to provide a coordinated U.S.
perspective in the development of standards by the IAIS.
The FSB was established to coordinate at the international level
the work of national financial authorities and international standard setting bodies and to develop and promote the implementation
of effective regulatory, supervisory and other financial sector policies to promote financial stability. The U.S. Treasury, the Federal
Reserve, and the SEC are the U.S. members of the FSB. Governor
Daniel Tarullo serves as the Federal Reserve’s representative to
the FSB Plenary and is the chairman of the FSB’s standing committee on Supervisory and Regulatory Cooperation (SRC).
As the international standard-setting body for insurance, the
IAIS reports to the FSB through the SRC with respect to supervisory and regulatory matters. The IAIS includes insurance regulators, supervisors, and central banks from around the world, including the United States. The U.S. members of the IAIS include
the Federal Insurance Office, the Federal Reserve, the National Association of Insurance Commissioners, and the State insurance departments.
Q.2. The bank-centric Basel 3 framework was developed by banking regulators for banks, not for insurers. Do you think it is appropriate for insurers to be subject to bank-centric Basel 3 capital

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rules that were never intended for them, or does it make more
sense to have an insurance-based framework for insurers?
A.2. The Board’s final revised capital framework for bank holding
companies and savings and loan holding companies from summer
2013 does not apply to savings and loan holding companies that are
engaged substantially in insurance activities. The Board decided to
take more time to develop appropriate capital requirements for insurance holding companies, including insurance nonbank SIFIs. We
want to get this right—it is important that we have strong consistent capital requirements for all depository institution holding
companies and that we have a treatment for insurance risks that
is economically sensible.
Q.3. Will you work with Congress to ensure that an insurancebased framework is applied to the insurance companies under Fed
supervision? If you are confirmed, will you revisit the Fed’s interpretation of the statute to determine if the Fed has the authority,
as many in the Senate believe that it does, to avoid the negative
impact of bank rules applied to insurance companies, and instead
apply a more appropriate insurance framework? Do you support bipartisan legislation that my colleague Senator Brown and I drafted
that clarifies that the Fed does have the flexibility to distinguish
capital standards between banks and insurance companies?
A.3. The Board recognizes that insurance companies that are savings and loan holding companies (SLHCs) or are designated by the
Council as nonbank financial companies may present different
business models and risks than bank holding companies. Section
171 of the Dodd-Frank Act, by its terms, requires the appropriate
Federal banking agencies to establish minimum risk-based and leverage capital requirements for bank holding companies (BHCs),
savings and loan holding companies, and nonbank financial companies supervised by the Board on a consolidated basis. This statutory provision further provides that these minimum capital requirements ‘‘shall not be less than’’ the generally applicable capital requirements for insured depository institutions. In addition, the
minimum—capital requirements cannot be ‘‘quantitatively lower
than’’ the generally applicable capital requirements for insured depository institutions that were in effect in July 2010. Section 171
does not contain an exception from these requirements for an insurance company (or any other type of company) that is a BHC,
SLHC, or supervised nonbank financial company (Board-regulated
company), or for a Board-regulated company that has an insurance
company subsidiary. This requirement therefore constrains the
scope of the Board’s discretion in establishing minimum capital requirements for Board-regulated companies.
The final capital rule approved by the Board earlier this year 1
took into consideration differences between the banking and insurance business within these constraints. The final capital rule included specific capital treatment for policy loans and separate accounts, which are assets typically held by insurance companies but
not by banks. Additionally, the Board determined to defer application of the final capital rule to SLHCs with significant insurance
1 See,

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activities (i.e., those with more than 25 percent of their assets derived from insurance underwriting activities other than credit insurance) and to SLHCs that are themselves State regulated insurance companies.
To the extent permitted by law, the Board continues to carefully
consider how to design capital rules for Board-regulated companies
that are insurance companies or that have subsidiaries engaged in
insurance underwriting in determining how to design an appropriate capital framework for these companies. The Board remains
willing to work with Congress on this important matter.
Q.4. The Federal Reserve has oversight for nonbank financial institutions that are designated as systemically important by the Financial Stability Oversight Council (FSOC). How will you ensure that
the Fed does not apply a one-size-fits-all approach to regulating
these entities? Is the Fed limited in its ability to tailor requirements by the Collins Amendment or any other provision of DoddFrank?
A.4. The Dodd-Frank Act directs the Board to apply prudential
standards to nonbank financial companies that have been designated by the FSOC for supervision by the Board that are more
stringent than the standards applied to banking organizations that
do not pose such significant risks to financial stability. The prudential standards must include enhanced risk-based capital, leverage,
liquidity, stress test, resolution planning, and risk management requirements as well as single-counterparty credit limits, and a debtto-equity limit for companies that pose a grave threat to the financial stability of the United States.
In establishing enhanced prudential standards for BHCs and
nonbank financial companies under section 165 of the Dodd-Frank
Act, section 165(a)(2) provides that the Board may tailor application of the standards imposed under that section on an individual
basis or by category. The Board intends, in prescribing prudential
standards for a particular nonbank financial company under section 165, to thoroughly assess the business model, capital structure, and risk profile of the designated company to determine how
the proposed enhanced prudential standards should apply, and if
appropriate, would tailor application of the standards by order or
regulation to that nonbank financial company or a category of
nonbank financial companies.
The Board recognizes that insurance companies that are SLHCs
or are designated by the Council as nonbank financial companies
may present different business models and risks than bank holding
companies. The final capital rule the Board issued this summer implementing the Basel III capital standards included specific capital
treatment for policy loans and separate accounts held by insurance
companies, which are assets not held by banks. Additionally, the
Board determined to defer application of the final capital rule to
SLHCs with significant insurance activities (i.e., those with more
than 25 percent of their assets derived from insurance underwriting activities other than credit insurance) and to SLHCs that
are themselves State regulated insurance companies.
To the extent permitted by law, the Board continues to carefully
consider how to design capital rules for Board-regulated companies

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that are insurance companies or that have subsidiaries engaged in
insurance underwriting in determining how to design an appropriate capital framework for these companies.
Q.5. The U.S. Department of the Treasury’s Office of Financial Research (OFR) recently delivered a report to the FSOC on ways that
activities in the asset management industry may create, amplify,
or transmit systemic risk. While the OFR report stops short of calling for SIFI designations for asset managers, it does lay out potential factors that could be used to determine if an asset manager
poses systemic risk. Many have commented publicly that the process for the OFR study and FSOC’s review of asset managers is
flawed and lacks transparency.
As a voting member of FSOC, if the FSOC undertakes to designate asset managers as systemically important, would you support the metrics for designation being put out for public comment?
If the FSOC ultimately designates asset managers as systemically important, do you agree that asset managers should be regulated differently than bank holding companies and that a one-sizefits-all approach is not appropriate?
A.5. The study on Asset Management and Financial Stability was
written by the OFR in response to a request by the FSOC to identify data gaps and provide analysis to better inform the FSOC’s
analysis of how to consider asset management firms for enhanced
prudential standards and supervision under Section 113 of the
Dodd-Frank Act. The study is not an FSOC publication. The OFR
study did not propose any metrics for the FSOC to use to consider
asset management firms for designation. If the FSOC develops
metrics for asset manager firms beyond the metrics in the current
guidance (available at: http://www.treasury.gov/initiatives/fsoc/
documents/nonbank%20designations%20-%20final%20rule%
20and%20guidance.pdf), if confirmed, I would support that it provide the public an opportunity to review and comment on any proposed metrics.
Section 165 of the Dodd-Frank Act requires the Federal Reserve
to establish enhanced prudential standards both for bank holding
companies with total consolidated assets of $50 billion of more and
for nonbank financial companies designated by the Council. In the
Federal Reserve’s proposed rule, we may tailor the application of
the enhanced standards to different companies on an individual
basis or by category, taking into consideration each company’s capital structure, riskiness, complexity, financial activities, size, and
any other risk-related factors that the Federal Reserve deems are
appropriate. This commitment to tailoring is reflected in the recently finalized capital rules in which the Federal Reserve excluded
savings and loan holding companies that are predominantly engaged in insurance activities in order to allow for the development
of more appropriate capital standards. Still, our ability to tailor the
enhanced standards may be limited by the Collins Amendment and
other provisions of the Dodd-Frank Act.
Q.6. As chairman of the Fed, what specifically will you do to increase the transparency of the Fed with regard to insurance regulators and the insurance industry? How will you consult with State
insurance regulators before taking a position on insurance regu-

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latory matters and will that position be consistent with the advice
you receive from State insurance regulators?
A.6. The Federal Reserve has a long history of cooperation, consultation, and engagement with Federal and State regulators, key
stakeholders, and other interested parties.
To raise transparency with respect to the development of our supervisory programs and regulations for the insurers under Federal
Reserve supervision, Federal Reserve staff regularly meets with
the Federal Insurance Office, insurance industry groups and company representatives, the National Association of Insurance Commissioners, State insurance regulators, and others regarding issues
related to insurance capital requirements, supervision, risk management, and other insurance matters.
The Federal Reserve considers and assesses the views of industry
groups and State regulators and has made adjustments in our approach to supervising and regulating insurers to reflect such input.
The Federal Reserve recognizes the differences between banking
and insurance, and is committed to tailoring its supervisory and
regulatory regime for insurance holding companies to reflect the
unique business lines and risks of insurance—to the extent permitted by law. We will continue to engage the industry and State
regulators to further expand the Board’s expertise and gain additional perspectives regarding the regulation and supervision of insurance companies, with the goal of continuing to promote a financially safe and sound financial system.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR KIRK
FROM JANET L. YELLEN

Capital Rules for Insurance Companies
Q.1. While many of us believe that the Dodd-Frank Act already
gives the Federal Reserve the authority to distinguish between insurance companies and banks when promulgating capital standards under the Collins Amendment, the Federal Reserve has made
statements publicly that it does not believe it has the statutory authority to do so. Therefore, a number of Senators on this Committee introduced legislation, S.1369 to codify and clarify that the
Federal Reserve can and should make distinctions between insurance companies and banks when setting capital standards. Is it
your interpretation that this authority currently exists?
A.1. Section 171 of the Dodd-Frank Act, by its terms, requires the
appropriate Federal banking agencies to establish minimum riskbased and leverage capital requirements for bank holding companies (BHCs), savings and loan holding companies (SLHCs), and
nonbank financial companies supervised by the Board (supervised
nonbank companies) on a consolidated basis. This statutory provision further provides that these minimum capital requirements
‘‘shall not be less than’’ the generally applicable capital requirements for insured depository institutions. In addition, the minimum capital requirements cannot be ‘‘quantitatively lower than’’
the generally applicable capital requirements for insured depository
institutions that were in effect in July 2010. Section 171 does not
contain an exception from these requirements for an insurance

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company (or any other type of company) that is a BHC, SLHC, or
supervised nonbank company (Board-regulated company), or for a
Board-regulated company that has an insurance company subsidiary. This requirement therefore constrains the scope of the
Board’s discretion in establishing minimum capital requirements
for Board-regulated companies.
The final capital rule approved by the Board earlier this year, 1
did, however, take into consideration differences between the banking and insurance business within these constraints. The final capital rule included specific capital treatment for policy loans and
separate accounts, which are assets typically held by insurance
companies but not by banks. Additionally, the Board determined to
defer application of the final capital rule to SLHCs with significant
insurance activities (i.e., those with more than 25 percent of their
assets derived from insurance underwriting activities other than
credit insurance) and to SLHCs that are themselves State regulated insurance companies.
The Board continues to carefully consider how to design capital
rules for Board-regulated companies that are insurance companies
or that have subsidiaries engaged in insurance underwriting in determining how to design an appropriate capital framework for
these companies.
Q.2. This ability for distinction should also transfer to the Fed’s
ability to distinguish between insurance companies and banks for
purposes of accounting practices. I have at least two insurance
companies in my State that are supervised by the Fed as savings
and loan holding companies. These companies are not publicly
traded and do not prepare financial statements in accordance with
GAAP—but rather, in accordance with GAAP-based insurance accounting known as Statutory Accounting Principles (SAP). Every
person I consult tells me that SAP is the most effective and prudential way to supervise the finances of an insurance company. It
is my understanding that the Federal Reserve may want to force
these insurance companies that have used SAP reporting for many
decades to spend hundreds of millions of dollars preparing GAAP
statements—primarily because the Fed is comfortable with GAAP
and understands it since it’s what banks use. Is this is true? If it
is true, is it simply because the Fed is so accustomed to bank regulation and not insurance regulation that it simply wants to make
things easier for itself? Do you agree with this one-size-fits-all approach to regulation? Can you provide a cost benefit analysis to
this as it seems to not add any additional supervisory value and
only adds astronomic costs to these companies?
A.2. The Federal Reserve is still considering regulatory capital and
financial reporting requirements for companies with significant insurance activities in light of the Collins amendment requirement
that we institute consolidated capital requirements for all bank
holding companies (BHCs), savings and loan holding companies
(SLHCs), and nonbank SIFIs. SLHCs with significant insurance activities are not covered by the new regulatory capital rules published this summer.
1 See,

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Our willingness to take more time to develop a capital rule for
insurance holding companies is an acknowledgement that the business model and associated risk profile of insurance companies can
differ materially from those of banking organizations and that further evaluation of the appropriate capital framework for these entities is warranted.
Because the calculation of insured depository institution capital
requirements begins with consolidated GAAP measurements, and
because statutory accounting has a legal entity rather than a consolidated basis, the Collins amendment is an impediment to use of
statutory accounting as the basis for consolidated capital requirements for BHCs, SLHCs, and nonbank SIFIs with insurance operations.
Q.3. Each Chairman of the Federal Reserve can appoint other Governors to specific posts and issues—such as representation to the
Financial Stability Oversight Council, representing the Federal Reserve to the Financial Stability Board (FSB), etc. Do you have a
written list of any changes in Fed governors you will make to these
posts that you can provide in writing?
A.3. No, I do not have a list at this point. If confirmed as Chairman, I look forward to working with my fellow governors to fulfill
the important responsibilities of the Federal Reserve.
FSOC
Q.4. FSOC has been in existence for more than 3 years. Since that
time, three companies have been deemed systemically significant
and a second round of companies appear to be under consideration.
There have been a number of calls, supported by a 2012 GAO report, on the FSOC to provide greater transparency about the process used for designation and the criteria followed. Can you provide
greater details on why more transparency has not been achieved?
A.4. Although I have not participated in the Financial Stability
Oversight Council (Council) matters, I understand it is firmly committed to promoting transparency and accountability in connection
with its activities. In November 2012, the Council and the Office
of Financial Research jointly provided a response to Congress and
the GAO with a description of the actions planned and taken in response to each of the recommendations in the report. The report
made a number of recommendations on ways in which the Council
could further enhance its transparency, including improving the
Council’s Web site.
Subsequently, the Council’s Web site was reintroduced, in December 2012, to improve transparency and usability, to improve access to Council documents, and to allow users to receive email updates when new content is added. The Council is firmly committed
to holding open meetings and closes its meetings only when necessary. However, the Council must continue to find the appropriate
balance between its responsibility to be transparent and its central
mission to monitor emerging threats to the financial system. Council members frequently discuss supervisory and other market-sensitive data during Council meetings, including information about
individual firms, transactions, and markets that require confidentiality. In many instances, regulators or firms themselves provide

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nonpublic information that is discussed by the Council. Continued
protection of this information, even after a period of time, is often
necessary to prevent destabilizing market speculation or other adverse consequences that could occur if that information were to be
disclosed.
Congress authorized the FSOC to designate nonbank financial
companies whose material financial distress could threaten U.S. financial stability. Congress provided the FSOC with a list of 10 factors for consideration but left it to FSOC to determine how these
factors, such as interconnectedness, size, leverage, and activities,
should be considered in determining whether a company posed a
threat to financial stability.
Designation has significant implications for a company, so it is
important that the designation framework and process is careful
and deliberative. To implement this authority, FSOC developed a
framework and criteria and sought public comments twice on the
framework. After publishing guidance, FSOC began the process of
assessing individual companies from a list of companies that met
the quantitative criteria set out in the guidance. The guidance is
available at: http://www.treasury.gov/initiatives/fsoc/documents/
nonbank%20designations%20-%20final%?0rule%
20and%20guidance.pdf.
As described in the guidance, FSOC screens companies through
a three-stage process which provides a company with more due
process than set forth in the enabling provisions of Dodd-Frank.
This authority is focused on individual companies, not categories of
activities or industries. Because being considered for designation is
an important event for a firm, and the process may involve evaluation of proprietary information, there may be some costs to providing too much information to the public.
Q.5. The methodology and blanket statements made in the OFR
Study on Asset Management and Financial Stability have been
highly criticized as making broad assumptions, blanket statements,
and for a misuse/misstatement and misunderstanding of data to
analyze the industry. Can you speak to the reports’ accuracies and/
or if there are errors how best to address these since these reports
are presumably part of the basis for designation?
A.5. The study on Asset Management and Financial Stability was
written by the OFR in response to a request by the FSOC to identify data gaps and provide analysis to better inform the FSOC’s
analysis of how to consider asset management firms for enhanced
prudential standards and supervision under Section 113 of the
Dodd-Frank Act. The study is not an FSOC publication. In addition, because the designation authority is focused on individual
companies rather than industries, it will be only one of many inputs used by the FSOC in its analysis.
Q.6. In terms of Asset Management companies, the Council has
previously stated that in any additional metrics are developed ‘‘it
intends to provide the public with an opportunity to review and
comment on any such metrics and thresholds.’’ Why was it the SEC
then and not the FSOC that released these for public comment?
Can you speak to other reports/studies that the OFR may do and
if there will be some kind of open/regular process that will be fol-

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lowed for the public to review and comment? In terms of the OFR’s
Study on Asset Management and Financial Stability, do you know
how many comments were received and the general nature/issues
raised in these comments?
A.6. The study on Asset Management and Financial Stability was
written by the OFR in response to a request by the FSOC to provide data and analysis to better inform the FSOC’s analysis of how
to consider asset management firms for enhanced prudential standards and supervision under Section 113 of the Dodd-Frank Act. The
OFR study did not propose any metrics for the FSOC to use to consider asset management firms for designation. If the FSOC develops metrics for asset manager firms beyond the metrics in the current guidance (available at: http://www.treasury.gov/initiatives/
fsoc/documents/nonbank%20designations%20-%20final%20rule%
20and%20guidance.pdf, I would support that it provide the public
an opportunity to review and comment on any proposed metrics.
Volcker
Q.7. Can you update me on the timing of the rule and will the conformance period be extended for firms to implement it?
A.7. The Federal Reserve is committed to getting the rules implementing section 619 of the Dodd-Frank Act right and has been
working for some time with the FDIC, OCC, SEC, and CFTC to develop a final rule that effectively implements that section in a manner faithful to the words and purpose of the statute. We are striving to consider this rule before year-end in order to provide clarity
and certainty to the affected members of the industry and to the
public more broadly about the requirements of section 619.
By its terms, section 619 became effective on July 21, 2012. Section 619 provides banking entities an additional 2-year period following the statute’s effective date to conform activities and investments to the prohibitions and restrictions of that section and any
final implementing regulation. 2 Under the statute, the Board may,
by rule or order, extend the 2-year conformance period for up to
three, 1-year periods, if in the judgment of the Board, an extension
is consistent with the purposes of section 619 and would not be detrimental to the public interest. The statute provides that the Board
may grant these extensions for not more than 1 year at a time. As
it considers the merits of adopting a final rule, the Board will also
consider the public interest in granting an extension of the conformance period.
Q.8. Can you assure me that the rule will be structured so it
doesn’t negatively impact small issuers?
A.8. Among other things, section 619 of the Dodd-Frank Act prohibits banking entities from engaging in proprietary trading, which
is defined by the statute to be trading in financial instruments for
the purpose of selling in the near term or the intent to resell in
order to profit from short-term price movements. Section 619 also
provides an exception from this prohibition for underwriting activities and for market-making activities that are designed not to exceed the reasonably expected near term demands of clients, cus2 See,

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tomers, and counterparties. Underwriting activities and marketmaking activities serve a very important role in providing capital
to businesses and liquidity to markets.
The Federal Reserve has been working for some time with the
FDIC, OCC, SEC, and CFTC to develop a final rule that effectively
implements section 619, including the exceptions for underwriting
and market-making activities and the other activities permitted by
the statute, in a manner faithful to the words and purpose of the
statute. In developing the rule, the Federal Reserve has met with
numerous members of the public about a wide variety of issues
raised by the statute and the original agency proposal, including
the issues you have raised, and has considered more than 18,000
comments on the proposal. We are striving to consider this rule before year-end in order to provide clarity and certainty to the affected members of the industry and to the public more broadly
about the requirements of section 619.
Enhanced Banking System: Ending Too Big to Fail and Protecting Against Future Collapses
Q.9. It is safe to say that in 2008 the U.S. Government did not
have the tools to wind down a large failing financial institution.
This inability is one of the primary reasons behind the Orderly Liquidation Authority (OLA) enacted in the Dodd-Frank Act. Recently,
Bank of England’s Paul Tucker stated, ‘‘ . . . the U.S. authorities
have the technology—via Title II of Dodd-Frank; and just as important, most U.S. bank and dealer groups are, through an accident
of history, organized in a way that lends them to top–down resolution on a group-wide basis. I don’t mean to it would be completely
smooth right now; it would be smoother in a year or so as more
progress is made, but in extremis, it should be done now. That
surely is a massive signal to bankers and markets.’’ Do you agree
with Mr. Tucker’s statement and what does progress on this front
mean for those arguing large banks benefit from an implicit subsidy?
A.9. The Dodd-Frank Act and Basel III approach to addressing systemically important financial institutions (SIFIs) involves much
stricter regulation of SIFIs and improving the resolvability of
SIFIs. This is a sensible path that will lower the probability of failure of SIFIs, improve market discipline of SIFIs, and reduce the
damage to the system if a SIFI does fail. The Board, the FDIC, and
other regulators have made much progress on this path. Market
participants and some rating agency actions for large bank holding
companies have recognized this progress.
The FDIC’s orderly liquidation authority (OLA) is effective today
and its core regulatory implementation architecture is in place. The
FDIC’s single-point-of-entry approach to implementing Title II of
the Dodd-Frank Act is a big step forward in this regard. More work
remains to be done around the world to maximize the prospects for
an orderly SIFI resolution, but the basic framework has been established in the United States.
Potential impediments to an orderly SIFI resolution remain—including the need for other countries to adopt workable statutory
resolution regimes for SIFIs, the need to ensure that SIFIs have

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sufficient gone concern loss absorption capacity and resolutionfriendly internal organizational structures, the need to provide host
regulators of SIFIs with credible assurances that local operations
will be protected in a resolution, and the need to address the potential disorderly unwind of cross-border derivative contracts. The
Federal Reserve is committed to working with the FDIC and our
supervised firms to remove these impediments.
The Fed, in consultation with the FDIC, has been developing a
regulatory proposal that would require the largest, most complex
U.S. banking firms to maintain a minimum amount of outstanding
long-term unsecured debt that could be converted to equity in resolution. Such a requirement would increase the prospects for an orderly resolution under OLA by ensuring that shareholders and
long-term debt holders of a systemic financial firm can bear potential future losses at the firm and sufficiently capitalize a bridge
holding company in resolution. In addition, by increasing the credibility of OLA, a minimum long-term debt requirement should help
counteract the moral hazard arising from taxpayer bailouts and improve market discipline of systemic firms.
U.S. regulators are in active discussions with their foreign counterparts with respect to crisis planning around potential future
SIFI failures. In particular, the U.S. and U.K. resolution authorities—the FDIC and the Bank of England—together with the Federal Reserve Board, the Federal Reserve Bank of New York and the
U.K. Financial Services Authority, have been working closely to develop contingency plans for the failure of global SIFIs with significant operations on both sides of the Atlantic.
Q.10. There have been some that have expressed concerns that
winding down a large bank is impossible because of cross border
problems. One solution offered has been the Single Point of Entry
(SPOE) approach. Does this approach significantly mitigate the
challenge posed by winding down a firm that has operations in
multiple jurisdictions?
A.10. The FDIC’s single-point-of-entry approach to resolution of a
systemic financial firm does mitigate the challenges posed by winding down a large, cross-border banking firm. Under the singlepoint-of-entry approach, the FDIC will be appointed receiver of only
the top-tier parent holding company of the failed firm. After the
parent holding company is placed into receivership, the FDIC will
transfer assets of the parent company to a bridge holding company.
The firm’s operating subsidiaries (foreign and domestic) will remain open for business as usual. To the extent necessary, the FDIC
will then use available parent holding company assets to recapitalize the firm’s critical operating subsidiaries. Equity claims of the
failed parent company’s shareholders will effectively be wiped out,
and claims of its unsecured debt holders will be written down as
necessary to reflect any losses or other resolution costs in the receivership. The FDIC will ultimately exchange the remaining
claims of unsecured creditors of the parent for equity or debt
claims of the bridge holding company and return the restructured
firm back to private sector control.
This conceptual approach to resolution under Title II of the
Dodd-Frank Act represents an important step toward addressing

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the market perception that any U.S. financial firm is too big or too
complex to be allowed to fail. The aim of the single-point-of-entry
approach is to stabilize the failed firm quickly, in order to mitigate
the negative impact on the U.S. financial system, and to do so
without supporting the firm’s equity holders and other capital liability holders or exposing U.S. taxpayers to losses. The singlepoint-of-entry approach offers the best potential for the orderly resolution of a systemic financial firm under Title II, in part because
of its potential to mitigate run risks and credibly impose losses on
parent holding company creditors and, thereby, to enhance market
discipline.
As noted in my previous answer, although use of the singlepoint-of-entry resolution approach materially improves the prospects for the orderly resolution of a cross-border banking firm as
compared to alternative implementation paths, impediments to
such an orderly resolution remain. The Federal Reserve is committed to working with the FDIC in the coming months and years
to mitigate those residual impediments.
Q.11. Liquidity and capital rules work in concert, but also serve
overlapping ends. How do you view the trade-offs between higher
capital and liquidity rules and in that light, how do you view
progress in both of these areas?
A.11. Higher capital and liquidity standards work in concert to bolster the stability of individual institutions and the financial system, and the Federal Reserve has made significant progress in both
of these areas. We believe that it is important that large banking
firms have both sufficient capital to absorb losses and a sufficiently
strong liquidity risk profile to prevent creditor and counterparty
runs. The financial crisis demonstrated that preventing the insolvency or material financial distress of large banking firms requires
regulating both their capital adequacy and liquidity risk.
The new capital framework published by the U.S. banking agencies this summer will increase the quantity and quality of banks’
required capital, whereas the proposed liquidity coverage ratio will
establish for the first time a standardized minimum liquidity requirement for large banking organizations. Both measures enhance
banking organizations’ ability to continue functioning as financial
intermediaries, particularly during stressful periods, thereby reducing risks to the deposit insurance fund and the chances of taxpayer
bailouts and improving the overall resilience of the U.S. financial
system.
There is more to be done on both the capital and liquidity fronts,
however. In particular, the Board intends to supplement the new
Basel III capital rules with a proposal to implement a risk-based
capital surcharge for the largest global systemically important
banking institutions, and is working with the Basel Committee to
develop a longer-term structural liquidity requirement for global
banks.
Macro Economic
Q.12. To what extent could potential challenges within the Chinese
banking and ‘‘shadow’’ banking industry transmit credit risk into
the global financial markets?

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A.12. The Chinese economy has experienced very rapid credit
growth in recent years. Along with bank loans, nonbank (shadow)
financing has expanded substantially, which includes lending via
trust companies, corporate bond issuance, and off-balance sheet
lending undertaken by banks. This rapid and sizable credit expansion has raised concerns about asset quality at banks and in the
shadow banking sector. A future rise in problem loans could lead
to capital shortfalls in the banking sector and potentially large expenses for the Government. That said, currently banks report
sound capital buffers, and the Chinese Government has extensive
resources to meet potential shortfalls in capital. In addition, Chinese authorities appear to recognize the potential risks of excessive
credit growth to their economy, and have signaled intentions to
curb it. However, notable risks remain and the situation bears
monitoring closely. Although China has a relatively closed financial
system with fewer financial links to other countries than many
other major economies, a sharp slowdown in the Chinese economy
would slow growth in other countries as well.
Q.13. How do you view the bond purchase program orchestrated by
the Bank of Japan? How does it differ from quantitative easing?
Does it appear that the Japanese are attempting to manipulate
their currency, or is this a proper response to Japan’s more than
20 years of economic stagnation and deflation?
A.13. Japan has experienced low growth coupled with mild deflation or very low inflation for nearly two decades. It is important to
address this problem, and the Bank of Japan (BOJ) has recognized
that aggressive action is necessary. The BOJ has taken a couple of
steps. In January, the BOJ introduced an inflation target of 2 percent, similar to that of other major central banks. In April, the
Bank of Japan announced it would be greatly expanding its existing asset purchase program and increasing the maturity of its purchases (a break from prior quantitative easing, which was focused
on shorter-term maturity assets) with the goal of raising inflation
to the 2 percent goal in 2 years. These asset purchases are mainly
concentrated in Japanese Government bonds.
These measures have already contributed to supporting economic
activity in Japan—with real GDP accelerating in the first half of
the year—and deflationary pressures have also begun to recede.
However, ultimately Japan will need to take steps to restore fiscal
sustainability and implement pro-growth structural reforms.
Q.14. Do you believe that the recent increases in mortgage interest
rates this past summer—that went up nearly 100 basis points from
May 2012 3 were an overreaction to the Fed’s June statements on
‘‘tapering’’ the stimulus? Do you believe that these moves are indicative that housing sector is being over-stimulated by economic policies?
A.14. The increase in longer-term interest rates over the summer
reflected a number of factors. First, the incoming economic data
suggested a somewhat stronger economic outlook, which boosted
rates. Second, as you note, in June the FOMC provided additional
information on its expectations regarding its current purchase pro3 http://www.bankrate.com/finance/mortgages/mortgage-analysis.aspx

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gram, offering a conditional outlook for reductions in the pace of
purchases over coming quarters if the incoming economic data continued to be consistent with the outlook for ongoing improvement
in labor market conditions. The committee was clear that the policy
outlook was conditional on economic and financial developments—
our purchases are by no means on a preset course. Nonetheless,
some investors who had taken on leveraged positions in longerterm instruments reportedly decided to exit those positions, putting
additional upward pressure on rates. While the resulting tightening of financial conditions was unwelcome, and could slow the recovery in the housing sector to some degree, the reduction in leveraged positions should reduce the risks to financial stability going
forward. The committee will continue to adjust policy as appropriate to foster our dual objectives of maximum employment and
price stability.
Q.15. After the initial round of the Federal Reserve’s monetary
measures to keep the financial system solvent during the financial
crisis, the threshold for additional central bank easing action has
become lower and lower, especially with each successive round of
QE. We now see loose central bank policies in the U.S., Japan, Europe, and elsewhere. Policy makers appear to be relying on monetary manipulation as a substitute for necessary tough decisions to
structurally reform our tax, spending, and trade policies that would
make for long-term, true economic growth. Do you believe that the
U.S. Federal Reserve can continue to be a shining example of Central Bank independence? Do you anticipate that you will have the
courage to end the stimulus programs and make some of the more
difficult decisions to get our economy back to a ‘‘true’’ functioning
economy rather than an economy that only functions with Government stimulus?
A.15. Americans can be confident that the FOMC has both the ability and the will to slow our asset purchases and eventually end our
asset purchase program, and ultimately to begin to remove policy
accommodation, when the economy is strong enough to make doing
so appropriate. We have clearly indicated that the purchase program is conditional on economic and financial developments. We
anticipate ending our purchases once we have seen a substantial
improvement in the outlook for the labor market in a context of
price stability. More broadly, we are providing a high degree of
monetary policy accommodation in order to support a stronger economic recovery and move inflation back toward its 2 percent
longer-run objective—that is, to foster our congressionally mandated objectives of maximum employment and price stability.
That said, as economic conditions normalize, it will become appropriate to begin removing policy accommodation. In considering
the timing of such a step, our objective will be to assure a strong
and robust recovery while keeping inflation under control. On the
one hand, it is important not to remove support too soon, especially
when the recovery is fragile. On the other hand, it is crucial not
to wait too long to withdraw accommodation, and so allow an undesirable rise in inflation. My colleagues and I are committed to our
longer run inflation goal of 2 percent, and we will need to ensure

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that, as the recovery takes hold and progresses, we bring monetary
policy back to normal in a timely fashion.
Q.16. The Federal Reserve’s recent monetary actions have created
somewhat of an unfair recovery, where investors and banks seem
to be fairing quite well while the middle and lower classes seem to
continue to struggle. Do you agree that the monetary policies put
into place by the Federal Reserve since the financial crisis have
been a ‘‘top–down’’ approach to bolstering the economy? Do you
think that the Fed’s easy money policies punish savers? We’ve seen
a growth and love spawned in the equities market—Do you think
that this artificial ‘‘boom’’ in equities will falter once the Fed begins
tapering?
A.16. It is certainly true that savers and those who rely on investments such as certificates of deposit and Government bonds are receiving very low returns. However, savers typically wear many economic hats. For example, many savers are homeowners or would
like to be homeowners, and low interest rates make it easier to own
a home and contribute to rising house prices. In addition, many
savers own stocks and other assets through pension funds and
401(k) accounts; low interest rates are supporting the economic recovery and are thus good for businesses’ sales and earnings, and
so for stock investors. And a stronger economy will help people who
need jobs to find them. Without a job, it is difficult to save for retirement or to buy a home or to pay for an education, irrespective
of the current level of interest rates.
More broadly, we cannot have a more normal configuration of interest rates until the economy returns to a more normal state. Currently, interest rates are low for fundamental economic reasons,
not just because the Federal Reserve and other central banks are
providing accommodative monetary policy. Those fundamental reasons include slow growth and low inflation in the U.S. and other
major economies. Pursuing an accommodative monetary policy now
will help to get the economy moving and so will best enable us to
normalize policy and to get rates back to normal levels over time.
Indeed, an improved economic outlook has contributed to the rise
in interest rates we have seen of late, and most forecasters anticipate that rates will rise further as the economy strengthens.
Q.17. When does the Fed plan to begin tapering?
A.17. As we have emphasized, our purchase program is not on a
pre-set course. Instead, our decisions regarding the purchase program are data dependent. Our goal for the purchase program, as
stated in September 2012 and reiterated since then, is to achieve
a substantial improvement in the outlook for the labor market.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR MORAN
FROM JANET L. YELLEN

Q.1. Community banking is undergoing a change, especially in
rural America. There are fewer banks in Kansas, but the banks
that remain are growing due to mergers and acquisitions. One consequence of this growth is that the bank holding companies absorbing these smaller institutions fall under greater regulatory thresholds due to their increasing asset size. These small bank holding

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companies (SBHCs) are increasingly exposed to the current $500
million threshold under the Federal Reserve’s Small Bank Holding
Company Policy Statement. For example, an SBHC located in Kansas has seven branches. These branches are located in rural communities where they are, in some instances, one of the only remaining businesses located on Main Street. But since an SBHC
brought those small banks under its purview and kept a branch
open for these small communities, that SBHC is now very close to
exceeding that $500 million threshold. As I understand it, the Federal Reserve has the discretion to alter the Small Bank Holding
Company Policy Statement and has exercised that discretion in
raising the threshold in the past.
I have introduced legislation along with Sen. Tester and Sen.
Kirk along with an additional 13 of our Senate colleagues as cosponsors. Section 3 of the CLEAR Relief Act, S.1349, would require
the Federal Reserve to raise that threshold. This seems to me a
commonsense reform we could make that would ensure that small
communities across the country will maintain access to hometown
banking services. This is only one example of a regulatory burden
the Federal Reserve could lift for the betterment of community
banking. Would you comment on how you will go about reducing
the regulatory burden on small banks, utilizing the Federal Reserve’s discretionary regulatory framework, so that communities in
Kansas will still have access to a hometown bank?
A.1. Community banks play a critical role in the U.S. economy, and
the Federal Reserve is committed to implementing a supervisory
and regulatory regime for community banks that is appropriate for
their business model and economic function. To better tailor our
oversight framework to the specific characteristics of community
banks, the Federal Reserve has formed a Community Depository
Institutions Advisory Council and a small bank subcommittee of its
Committee on Bank Supervision.
The Federal Reserve has been very focused on addressing toobig-to-fail (TBTF) and protecting financial stability by strengthening the regulatory regime for systemically important financial institutions (SIFIs). TBTF is a damaging economic phenomenon that
corrodes market discipline of our largest banking firms and contributes to an unlevel playing field between large banks and small
banks. The much stricter regulatory regime that the Federal Reserve and other U.S. and global regulators are implementing for
SIFIs should help level that playing field. Consistent with this
principle, our recent final Basel III capital rule also created substantial differences between the regulatory capital regime that will
apply to large U.S. banking firms as compared to community
banks.
The Federal Reserve periodically reviews the scope of application
of its Small Bank Holding Company Policy Statement. The Federal
Reserve raises the asset threshold when appropriate in light of
changes to U.S. banking markets and the economy.
Q.2. The drafting process of the Volcker Rule has caused some confusion among investors and regulators alike. Without delving into
the specifics of the rule, I would simply mention that I have heard
concerns as to where market making ends and proprietary trading

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begins. As you well know, market making serves a very important
role in providing liquidity. I am concerned that an overly restrictive
Volcker Rule could damage a business’s ability to operate and expand. I have also heard discussions about certain asset classes,
namely non-U.S. sovereign debt, that may be under consideration
for an exemption from the Volcker rule. If you believe the Volcker
Rule is structured in a way to not have an overly negative impact
on liquidity and the costs of issuing debt, for what purpose would
certain asset classes require exemptions? Could not an asset class
exemption of this nature be viewed as favoring foreign countries
over American companies?
A.2. Among other things, section 619 of the Dodd-Frank Act prohibits banking entities from engaging in proprietary trading, which
is defined by the statute to be trading in financial instruments for
the purpose of selling in the near term or the intent to resell in
order to profit from short-term price movements. Section 619 also
provides an exception from this prohibition for market-making activities that are designed not to exceed the reasonably expected
near term demands of clients, customers and counterparties. As
you note, market-making activities serve a very important role in
providing liquidity to markets.
The statute also provides exceptions from the proprietary trading
prohibition for trading in certain asset classes. In particular, the
statute permits trading by banking entities in obligations of the
United States, obligations of any agency of the United States (including the Federal National Mortgage Association, the Federal
Home Loan Mortgage Corporation, the Federal Home Loan Banks,
and the Government National Mortgage Association) and obligations of any State or political subdivision thereof.
The Federal Reserve has been working for some time with the
FDIC, OCC, SEC, and CFTC to develop a final rule that effectively
implements section 619, including the exception for market-making
activities and the other activities permitted by the statute, in a
manner faithful to the words and purpose of the statute. In developing the rule, the Federal Reserve has met with numerous members of the public about a wide variety of issues raised by the statute and the original agency proposal, including the issues you have
raised, and has considered more than 18,000 comments on the proposal. We are striving to consider this rule before year-end in order
to provide clarity and certainty to the affected members of the industry and to the public more broadly about the requirements of
section 619.
Q.3. Among the concerns that have been raised about Basel III, the
possibility of bank-centric capital standards being applied to insurance companies is among the most difficult to justify. I realize the
Federal Reserve may feel it is obligated to regulate certain components of the insurance industry due to the Collins Amendment language of the Dodd-Frank Act. However, I believe, as do many of my
Senate colleagues, that the Federal Reserve does have flexibility in
the statute to develop insurance-based standards. I am concerned
that the very different capital accounting methods utilized by the
insurance industry will make bank-centric Basel III standards unworkable and disruptive if applied to insurers. Are you able to pro-

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vide any insight as to whether the Federal Reserve intends to saddle insurance companies with bank-centric prudential standards,
and do you believe there is a way to develop strong insurancebased standards that would make more sense? Could you elaborate
on the process moving forward?
A.3. Section 171 of the Dodd-Frank Act, by its terms, requires the
appropriate Federal banking agencies to establish minimum riskbased and leverage capital requirements for bank holding companies (BHCs), savings and loan holding companies (SLHCs), and
nonbank financial companies supervised by the Board (supervised
nonbank companies) on a consolidated basis. This statutory provision further provides that these minimum capital requirements
‘‘shall not be less than’’ the generally applicable capital requirements for insured depository institutions. In addition, the minimum capital requirements cannot be ‘‘quantitatively lower than’’
the generally applicable capital requirements for insured depository
institutions that were in effect in July 2010. Section 171 does not
contain an exception from these requirements for an insurance
company (or any other type of company) that is a BHC, SLHC, or
supervised nonbank company (Board-regulated company), or for a
Board-regulated company that has an insurance company subsidiary. In addition, because the calculation of insured depository
institution capital requirements begins with GAAP measurements,
and because statutory accounting is on a legal entity rather than
a consolidated basis, consideration of accounting methods is part of
the analysis in determining whether capital regulations meet the
requirements of section 171 of the Dodd-Frank Act.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR COBURN
FROM JANET L. YELLEN

Q.1. Was there any task more important for the Fed since the
1930s than understanding the financial system, understanding the
financial institutions which were using more and more leverage
and building massive opaque books of complicated derivatives positions, and heading off the next financial collapse? Fed minutes
from 2006 and 2007 show that the Fed did not understand the
risks of the modern financial system. Now, the Fed contends that
its policy of quantitative easing does not present a serious inflation
risk. However, considering the failure of the Federal Reserve to anticipate broad changes in the economy—including the 2008 financial crash and the worst recession in 50 years—why should Americans have confidence in that judgment?
A.1. Americans can be confident that the FOMC has both the ability and the will to prevent inflation. Everyone on the committee,
including myself, is firmly committed to our 2 percent longer-run
goal for inflation. Over the past 5 years inflation has averaged
near, but a bit below, our goal of 2 percent. More recently, inflation
has generally been running more significantly below our 2 percent
objective, and falling inflation has been a concern.
At some point as economic conditions normalize, maintaining
price stability will require removing accommodation. At that time,
the Federal Reserve will tighten the stance of monetary policy by
raising its target for the Federal funds rate and the interest rate

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it pays on reserve balances, which will put upward pressure on
short-term market interest rates to avoid an overheated economy
and higher-than-target inflation in the historically normal and well
understood way. The Federal Reserve has also developed a number
of tools that it can use if necessary to help keep market rates near
the interest rate on reserve balances. Moreover, the FOMC intends
to gradually reduce its securities holdings once the economy is
strong enough so that it no longer needs the support provided by
the committee’s large scale asset purchases. We are confident we
have the tools to normalize the stance of policy when doing so becomes appropriate, and that we can do so in a way that will avoid
inflationary consequences down the road.
Q.2. Fiat money is very difficult to preserve in value, and generations of central bankers have tried hard to project an image of sobriety and proprietary regarding the purchasing power of paper
money. Do you think the Fed has put at risk the confidence of investors and citizens in paper money by its zero-percent-interestrates and successive rounds of QE?
A.2. Investors and citizens can be confident that the FOMC has
both the will and the ability to prevent rapid inflation. Everyone
on the committee, including myself, is firmly committed to our 2
percent longer-run goal for inflation. The FOMC has employed its
nontraditional policy tools in order to support a stronger recovery
and move inflation back toward its longer-run goal—that is, to better foster its Congressionally established goals of maximum employment and price stability. Investors would only have reason to
lose confidence in the purchasing power of the dollar if inflation
had been excessive or was at risk of being excessive in the future.
However, as described in my answer to the previous question, inflation has been low in recent years and remains below our 2 percent
target, and the committee has the tools necessary to remove policy
accommodation when doing so becomes appropriate.
Q.3. Are the Fed’s statements that it could snuff out inflation in
15 minutes by raising rates consistent with past historical experience? This past spring the mere mention of slightly reducing the
Fed’s pace of bond-buying sent global fixed income markets into a
panic, and prices of long-term debt reversed almost all of the price
elevation caused by QE since the spring of 2009. It is impossible
to know whether this market reaction was the beginning of an anticipation of serious inflation, or the beginning of a loss of confidence in long-term claims on paper money that are seen as being
debased by the Fed’s policies. What do you think about what happened in the markets this past spring, and what is the support for
the Fed’s statement that if inflation arises, the Fed can get rid of
it in 15 minutes?
A.3. As you note, last spring, the FOMC provided additional information on its expectations regarding its purchase program, suggesting a conditional outlook for reductions in the pace of purchases. That outlook was explicitly conditional on economic and financial developments—our purchases are by no means on a preset
course. Partly in response to the information the committee provided about the possible path for policy, but also reflecting some
strengthening in the economic data at that time, interest rates

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rose. In addition, some investors who had taken on leveraged positions in longer-term instruments reportedly decided to exit those
positions, putting additional upward pressure on rates. However,
measures of inflation expectations, such as the difference between
yields on nominal Treasury securities and those on Treasury Inflation Protected Securities, did not change appreciably and remained
close to 2 percent, indicating that investors did not anticipate high
inflation.
As I noted above, the FOMC is firmly committed to its 2 percent
longer-run goal for inflation. The committee has the tools it needs
to address incipient inflation risks, should they develop, and it can
take steps to address unwelcome increases in inflation very rapidly
if required. Such steps would include increases in our target for the
Federal funds rate and in the interest rate paid on reserve balances as well as the use of other tools to tighten the relationship
between short-term market interest rates and the rate paid on reserves.
Q.4. After the first round of the Fed’s emergency monetary measures to keep the financial system afloat, the threshold for additional central bank easing action has become lower and lower with
successive rounds of QE. As a result, loose central bank policies in
the U.S., in Japan, and elsewhere, has resulted in policy makers
relying on monetary policy as a substitute for necessary tough decisions to structurally reform our tax, spending, and trade policies
that would allow for long lasting growth. Do you believe it is a critical role of the Fed Chair to tell the President and Congress that
monetary policy can only go so far, and that it is up to the President and Congress to do everything they can to remove the impediments to strong sustainable growth so that the Fed can discontinue
its unprecedented monetary accommodations and their associated
risks?
A.4. Policy makers should understand that monetary accommodation is not a panacea, and that other parts of the Government need
to take the necessary steps to address the challenges our economy
faces. In particular, I have emphasized that it would be helpful to
the economy to put in place a strategy for fiscal policy that is not
as restrictive in the near term, but that focuses on the longer-term
fiscal issues that are at the heart of achieving fiscal sustainability,
and that over the longer run can boost the capacity of the economy
through greater national saving, higher investment and, in turn,
increased productivity and long-run economic growth.
Q.5. The Fed’s policies of zero-percent interest rates and QE have
created a distorted, unfair recovery. Investors in bonds and stocks
are doing great, with record highs in stock prices and very high
prices of bonds across the yield curve. At the same time, ordinary
people are experiencing just about recessionary unemployment and
underemployment conditions, and millions of Americans have become discouraged by long-term unemployment and are no longer
even looking for work. Moreover, QE has boosted the prices of some
of the necessities of life and has made it impossible for savers to
earn a safe fair return on their savings, forcing them to take higher
risks. This set of distortions naturally creates resentment in those
not experiencing a full economic recovery. Do you count this wid-

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ening of inequality as a cost of QE and zero-percent interest rate
policy?
A.5. Too many people remain unemployed or have stopped looking
for work, and the extent of long-term unemployment is still very
troubling. However, only a stronger economy will allow people who
need jobs to find them. It is certainly true that savers and those
who rely on investments such as certificates of deposit and Government bonds currently are receiving low returns. But savers also
participate in the economy in many other ways as well. Many are
workers or would-be workers, and low interest rates boost economic
growth and help create jobs throughout the economy. Many are
borrowers or would-be borrowers, and Federal Reserve policy has
kept mortgage and other interest rates lower than they would have
been otherwise, helping those who want to buy homes, automobiles,
and other durable goods. Many are investors in stocks and other
financial investments, and a stronger economy will naturally generate better returns on those other investments. More generally, in
light of the continued headwinds restraining economic growth, the
FOMC judges that low interest rates are needed at this time to
provide support to the ongoing recovery. Unequivocally, the goal of
our accommodative monetary policy is to foster a more rapid return
to an economy that works better for everyone, by promoting a return to maximum employment in a context of price stability.
Q.6. Since 2008, our Nation’s largest banks are even larger than
prior to the crisis, and studies have found they can raise money at
lower rates due to their TBTF status. A major reason these firms
retain the perception of TBTF is that even the most sophisticated
market participants cannot understand the complex risks embedded in their derivatives books, which were at the heart of the recent crisis and which still contain trillions of dollars of potentially
volatile positions. In the absence of adequate derivatives disclosures, the market will continue to lack confidence that these firms
are actually safe and sound and won’t threaten a breakdown of the
financial system. Dodd-Frank gave the Fed vast new powers to end
TBTF. A key component of ending TBTF is ensuring that the market understands the risk exposures of these multi-trillion dollar derivatives books. Will you commit to using the Fed’s new powers to
make sure that the market has significantly more robust access to
the derivatives exposures of financial institutions?
A.6. I agree that TBTF is a damaging economic phenomena, and
regulators around the world need to work to address TBTF. We
have made progress in reducing the TBTF problem since the financial crisis by reducing the probability of failure of systemically important financial institutions (SIFIs), by reducing the damage to
the system if a SIFI were to fail, and by strengthening the broader
financial markets and infrastructure. For example, we have substantially raised bank capital requirements, implemented stress
tests for large bank holding companies and disclosed results,
strengthened our approach to large bank supervision, and agreed
on new liquidity rules for global banking firms. Progress also has
been made to address the failure of a SIFI, through the resolution
planning process and through the development of the FDIC’s single-point-of-entry approach to orderly liquidation authority. In ad-

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dition, the Federal Reserve is now required to consider financial
stability when reviewing merger and acquisition applications by
bank holding companies. Finally, we have strengthened financial
markets and infrastructures by, among other things, improving the
tri-party repo settlement infrastructure, strengthening the supervision of financial market utilities, moving more over-the-counter
derivatives to central clearing, and substantially improving transparency in the derivatives markets.
Market participants and some rating agency actions for large
bank holding companies have recognized this progress. But we still
have work to do to eliminate residual TBTF subsidies. We are committed to that work. If the existing regulatory reform efforts in
train prove to be insufficient to solve the TBTF problem, we are
willing to look at the costs and benefits of other approaches.
On the specific issue of disclosure of bank derivatives activities,
the Federal Reserve has been working in concert with other agencies—in particular the CFTC and SEC—to implement the broad set
of derivatives reforms mandated by the Dodd-Frank Act. These reforms should substantially increase transparency regarding banking firms’ derivatives activities, as more derivatives trading takes
place through central counterparties (CCPs) and data regarding
such activity is stored and accessible via trade repositories (TRs).
This information should augment existing data on firms’ derivatives activities publicly disclosed in regulatory filings (e.g., Y–9Cs
and 10–K/Qs).
In addition, firms’ derivatives exposures are included in the Federal Reserve’s Dodd-Frank Act Stress Test and Comprehensive
Capital Analysis and Review (CCAR) exercises, the results of which
are released publicly each year.
The Federal Reserve has a long history of supporting enhancements in bank disclosure practices.
Q.7. The Bank for International Settlements noted in its annual report that ‘‘in the years ahead, exiting from the extraordinarily accommodative policy stance will raise significant challenges for central banks. They will need to strike the right balance between the
risks of exiting prematurely and the risks associated with delaying
exit further. While the former are well understood, it is important
not to be complacent about the latter just because they have not
yet materialized.’’ Do you believe there could be a tendency to delay
exiting because the risks related to waiting too long (asset bubbles,
inflation, misallocation of credit) are not clear until it is too late?
A.7. There are risks associated with both keeping monetary policy
accommodative for too long and tightening policy too soon. As you
note, keeping policy accommodative for too long could result in an
unwelcome increase in inflation and could encourage excessive risktaking that might eventually lead to financial instability. Tightening policy too soon could cut off an incipient strengthening of the
recovery, preventing a beneficial decrease in unemployment, and
possibly causing inflation to move further below the FOMC’s target
of 2 percent. In order to determine the appropriate setting of monetary policy, the Federal Reserve assesses the outlook for economic
conditions as well as the risks around that outlook on an ongoing
basis.

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I agree that there are unique risks associated with the unconventional monetary policy instruments the FOMC is currently employing, including its large-scale asset purchases and forward guidance
for the Federal funds rate, but I do not believe those risks result
in a tendency for the FOMC to keep policy accommodative for too
long. The Federal Reserve is carefully monitoring the sources of
risk associated with accommodative policy. In particular, the Federal Reserve has increased considerably the resources it is devoting
to monitoring risks to financial stability. While there are currently
some indications of ‘‘reach for yield’’ in the low-rate environment,
there does not appear to be a widespread increase in excessive risk
taking.
It is important to note that there are also unique risks associated
with removing policy accommodation too soon because of the current policy situation. Indeed, I think the best way to bring about
an expeditious end to unconventional monetary policy is to avoid
a premature removal of accommodation.
Q.8. In a speech this spring, Fed Board Governor Jeremy Stein indicated that certain sectors of the credit market are showing signs
of overheating due to the extended period of low interest policy. He
noted these risks are developing in the corporate junk bond markets, the mortgage REIT sector, and commercial bank securities,
and he concluded that these risks may need to be dealt with
through rate increases. FSOC also identified the extended period of
low-interest as potentially causing banks to push further out along
the risk curve to ‘‘reach for yield,’’ increasing credit risk for nearterm earnings but sacrificing long term stability in the event of a
sudden large rise in rates or widening in credit spreads. Do your
views of the overheating of certain markets differ from Governor
Stein’s? Do you believe there is a potential that we can experience
a boom and bust in asset prices without ever experiencing a full
economic recovery?
A.8. We follow a great many markets and overall, I do not think
we see very much evidence of troubling excesses. I agree with Governor Stein, however, that we saw some issues in some markets
this spring and that these warrant careful monitoring. The rise in
interest rates over the summer may have helped reign in some behavior that might otherwise have grown even more concerning.
Still we continue to monitor a number of areas. We are mindful of
the fact that financial excesses can appear even before a full recovery is complete.
As Governor Stein noted, we have a number of tools for dealing
with such problems should they reach the point that a response is
required. My preferred first lines of defense involve supervisory
and regulatory tools. This is because monetary policy is a very
blunt tool for addressing excesses in particular markets. Raising
the price of credit for everyone in the economy may help to reign
in some troubling behavior, but would also impose costs on all
those behaving prudently. Thus, while it is important to maintain
the monetary policy option for dealing with financial excesses, I believe it should be a backstop used if more directed approaches fail.
Q.9. How much are the Fed’s tools to lower interest rates to stimulate consumer spending on durable goods and mortgages dimin-

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ished by the fact that the private sector is deleveraging from recent
overleveraging and massive asset bubbles? To what extent is
incentivizing consumer debt counterproductive to a stable long-run
economy? How could fixing our fiscal, tax, and regulatory policies
impact the economy as compared to accommodative monetary policies?
A.9. One key factor shaping the contours of the recovery has been
the effort of the private sector to reduce its leverage. Substantial
progress in that direction has been accomplished, and that progress
helps lay the groundwork for a more secure economic expansion
going forward. Another important factor helping to lay that groundwork is a highly accommodative monetary policy. These factors are
complementary, in that they both help to boost consumer confidence, boost hiring above where it would otherwise be, and increase business demand for capital. That said, monetary policy is
not a panacea, and policy makers of all types should be endeavoring to align their policies similarly toward bolstering the recovery
and ensuring a solid foundation for growth and stability going forward.

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