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S. HRG. 114–4

FEDERAL RESERVE’S FIRST MONETARY POLICY
REPORT FOR 2015

HEARING
BEFORE THE

COMMITTEE ON
BANKING, HOUSING, AND URBAN AFFAIRS
UNITED STATES SENATE
ONE HUNDRED FOURTEENTH CONGRESS
FIRST SESSION
ON
OVERSIGHT ON THE MONETARY POLICY REPORT TO CONGRESS PURSUANT TO THE FULL EMPLOYMENT AND BALANCED GROWTH ACT OF 1978

FEBRUARY 24, 2015

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

(
Available at: http: //www.fdsys.gov /

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COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS
RICHARD C. SHELBY, Alabama, Chairman
MICHAEL CRAPO, Idaho
SHERROD BROWN, Ohio
BOB CORKER, Tennessee
JACK REED, Rhode Island
DAVID VITTER, Louisiana
CHARLES E. SCHUMER, New York
PATRICK J. TOOMEY, Pennsylvania
ROBERT MENENDEZ, New Jersey
MARK KIRK, Illinois
JON TESTER, Montana
DEAN HELLER, Nevada
MARK R. WARNER, Virginia
TIM SCOTT, South Carolina
JEFF MERKLEY, Oregon
BEN SASSE, Nebraska
ELIZABETH WARREN, Massachusetts
TOM COTTON, Arkansas
HEIDI HEITKAMP, North Dakota
MIKE ROUNDS, South Dakota
JOE DONNELLY, Indiana
JERRY MORAN, Kansas
WILLIAM D. DUHNKE III, Staff Director and Counsel
MARK POWDEN, Democratic Staff Director
JELENA MCWILLIAMS, Chief Counsel
DANA WADE, Deputy Staff Director
JACK DUNN III, Professional Staff Member
LAURA SWANSON, Democratic Deputy Staff Director
GRAHAM STEELE, Democratic Chief Counsel
PHIL RUDD, Democratic Legislative Assistant
DAWN RATLIFF, Chief Clerk
TROY CORNELL, Hearing Clerk
SHELVIN SIMMONS, IT Director
JIM CROWELL, Editor
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C O N T E N T S
TUESDAY, FEBRUARY 24, 2015
Page

Opening statement of Chairman Shelby ................................................................
Opening statements, comments, or prepared statements of:
Senator Brown ..................................................................................................

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WITNESS
Janet L. Yellen, Chair, Board of Governors of the Federal Reserve System ......
Prepared statement ..........................................................................................
Responses to written questions of:
Chairman Shelby .......................................................................................
Senator Crapo ............................................................................................
Senator Vitter ............................................................................................
Senator Kirk ..............................................................................................
Senator Heller ...........................................................................................
Senator Menendez .....................................................................................
ADDITIONAL MATERIAL SUPPLIED

FOR THE

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50

RECORD

Monetary Policy Report to the Congress dated February 24, 2015 .....................

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FEDERAL RESERVE’S FIRST MONETARY
POLICY REPORT FOR 2015
TUESDAY, FEBRUARY 24, 2015

U.S. SENATE,
URBAN AFFAIRS,
Washington, DC.
The Committee met at 10:05 a.m., in room SD–106, Dirksen Senate Office Building, Hon. Richard C. Shelby, Chairman of the Committee, presiding.
COMMITTEE

ON

BANKING, HOUSING,

AND

OPENING STATEMENT OF CHAIRMAN RICHARD C. SHELBY

Chairman SHELBY. Today the Committee will receive testimony
from Federal Reserve Chair Yellen, as has been required by statute
since 1978. And although the Federal Reserve Chair has been
using this venue for decades to communicate directly to Congress
and the American people, I and many of my colleagues have been
calling for greater accountability and more effective disclosure for
years.
In response, we have heard a chorus of current and former Federal Reserve officials who have lined up to defend the structure and
the degree of transparency of the Fed. Further accountability to
Congress, some have argued, is not needed. I am interested to hear
whether the current Chair shares this view and whether she believes that the Fed should be immune from any reforms.
As far as monetary policy is concerned, many question whether
the Fed can rein in inflation and avoid destabilizing asset prices
when the time comes to unwind its massive $4.5 trillion balance
sheet. The minutes posted online do little to answer the questions
of when and how this will be done, and the most recent FOMC
transcript available to the public is from 2008, over 7 years ago.
Even though the Fed has several monetary policy tools at its disposal, an action of this magnitude has never before been taken, to
my knowledge. The Federal Open Market Committee continues to
report that it can be patient in keeping the Federal funds rate near
zero. Too much delay could lead to a more painful correction down
the road.
What the FOMC is thinking and how they are analyzing this
very difficult problem set remains a mystery, however; and yet
some continue to dismiss calls for change or more transparency at
the Fed.
I would argue, however, that there is an even greater need for
additional oversight by Congress and further reforms. Our central
bank has expanded its influence over households, businesses, and
markets in recent years. Not only has it pushed the boundaries of
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2
traditional monetary policy, but it has also consolidated unmatched
authority as a financial regulator.
As the Fed grows larger and more powerful, much of this authority has become more concentrated in Washington, DC, and in New
York. The Fed emerged from the financial crisis as a super regulator, with unprecedented power over entities that it had not previously overseen. With such a delegation of authority comes a
heightened responsibility, I believe, for Congress to know the impact these new requirements place on our economy as a whole.
The role of Congress is not to serve on the Federal Open Market
Committee, but it is to provide strong oversight and, when times
demand it, bring about structural reforms. As part of this process,
the Committee will be holding another hearing next week to discuss options for enhanced oversight and reform in the Fed.
Senator Brown.
STATEMENT OF SENATOR SHERROD BROWN

Senator BROWN. Thank you, Mr. Chairman. Chair Yellen, welcome back. It is good to see you again and good to have you in front
of our Committee.
Our economy continued to see strong employment gains and economic growth at the end of 2014, but we know the improvements
in the economy are not being felt by enough Americans. The gains
we have made over the past 5 years, 11.5 million net private sector
job growth in the last 5 years, come on the heels of 9 years when
we lost 4.5 million jobs. Some pundits and politicians have been
predicting runaway inflation for years. They clearly do not have a
very good grasp of what is happening for most Americans. Low
wage growth has continued for the majority of Americans. The declining participation in the workforce is troubling. In fact, as you
pointed out, Madam Chair, the income inequality gap has actually
widened during this recovery.
It is good, Mr. Chairman, that we began our session today by
commemorating the Selma Foot Soldiers. We must also note,
though, that the wealth gap between white and black American
families has widened. Low- and middle-income Americans have not
benefited much from low interest rates. Workers with stagnant
wages have trouble saving for a downpayment or their retirement
or their children’s education. These are issues that Congress should
be addressing, but the everyday struggle of Americans needs to be
part of the Fed’s consideration in making monetary policy, too.
I appreciate, Chair Yellen, your announcement last month of
plans to create the Community Advisory Council. It will have 15
members, meet twice a year with the Board in Washington to offer
perspectives on their economic circumstances and the needs of lowand moderate-income communities and consumers. I hope the entire Federal Reserve System—the 12 regional banks as well as the
Board in Washington—will engage community leaders way more
than they have in the past and will do what you have done by setting the tone in Washington and incorporate the diverse perspectives into their decision making.
We too often hear concerns that the Fed is a system that is run
by and to benefit the very largest banks. Last November, I held a
Subcommittee hearing on one facet of this: regulatory capture. The

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3
hearing explores concerns about the culture of the banks and the
regulators. A regulatory culture that is fair and tough, that challenges group think, and that produces rules and regulations designed to strengthen the financial stability of our economy will protect Americans’ financial interests.
I applaud the Fed for finalizing strong rules for the Nation’s largest and riskiest financial institutions. I encourage you to move forward to finalize outstanding proposals so that everyone will benefit
from the certainty of having appropriate rules in place.
It has been more than a year since the Fed released an Advanced
Notice of Proposed Rulemaking on commodities trading and physical asset ownership. For example, in today’s papers, there are reports of a DOJ investigation of 10 banks for activities in the precious metals markets, and we have yet to see a proposed rule. The
job does not end there. You must then send the message to your
examiners that these rules must be implemented and enforced.
Finally, while some of my colleagues are eager to help you and
the Fed decide monetary policy, I think that is the wrong role for
Congress. I am all for transparency. I think more is better as a
general rule. But every one of us knows there are times when you
can do better by having a candid discussion in private.
One real goal must be to have a Federal Reserve that works for
all Americans, to have a strong economy that benefits low-wage
workers and the middle class as much as the wealthiest, and to
have a stable and diverse financial system that provides opportunities for all Americans, not one that threatens their savings. That
is why your dual mandate to promote price stability and employment, and I so appreciate, perhaps more than you, perhaps more
than any of your predecessors, or at least as much understands the
dual mandate, including employment, how important that is. It remains important today.
Thank you.
Chairman SHELBY. Madam Chair, welcome to the Committee. We
look forward to your testimony and our question-and-answer period. Your written testimony will be made part of the record in its
entirety. You may proceed briefly to outline what you want to tell
us.
STATEMENT OF JANET L. YELLEN, CHAIR, BOARD OF
GOVERNORS OF THE FEDERAL RESERVE SYSTEM

Ms. YELLEN. Chairman Shelby, Ranking Member Brown, and
Members of the Committee, I am pleased to present the Federal
Reserve’s semiannual Monetary Policy Report to the Congress. In
my remarks today, I will discuss the current economic situation
and outlook before turning to monetary policy.
Since my appearance before the Committee last July, the employment situation in the United States has been improving along
many dimensions. The unemployment rate now stands at 5.7 percent, down from just over 6 percent last summer and from 10 percent at its peak in late 2009. The average pace of monthly job gains
picked up from about 240,000 per month during the first half of
last year to 280,000 per month during the second half, and employment rose 260,000 in January. In addition, long-term unemployment has declined substantially, fewer workers are reporting that

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4
they can find only part-time work when they would prefer full-time
employment, and the pace of quits—often regarded as a barometer
of worker confidence in labor market opportunities—has recovered
nearly to its prerecession level. However, the labor force participation rate is lower than most estimates of its trend, and wage
growth remains sluggish, suggesting that some cyclical weakness
persists. In short, considerable progress has been achieved in the
recovery of the labor market, though room for further improvement
remains.
At the same time that the labor market situation has improved,
domestic spending and production have been increasing at a solid
rate. Real gross domestic product is now estimated to have increased at a 33⁄4 percent annual rate during the second half of last
year. While GDP growth is not anticipated to be sustained at that
pace, it is expected to be strong enough to result in a further gradual decline in the unemployment rate. Consumer spending has
been lifted by the improvement in the labor market as well as by
the increase in household purchasing power resulting from the
sharp drop in oil prices. However, housing construction continues
to lag; activity remains well below levels we judge could be supported in the longer run by population growth and the likely rate
of household formation.
Despite the overall improvement in the U.S. economy and the
U.S. economic outlook, longer-term interest rates in the United
States and other advanced economies have moved down significantly since the middle of last year; the declines have reflected, at
least in part, disappointing foreign growth and changes in monetary policy abroad. Another notable development has been the
plunge in oil prices. The bulk of this decline appears to reflect increased global supply rather than weaker global demand. While the
drop in oil prices will have negative effects on energy producers
and will probably result in job losses in this sector, causing hardship for affected workers and their families, it will likely be a significant overall plus, on net, for our economy. Primarily, that boost
will arise from U.S. households having the wherewithal to increase
their spending on other goods and services as they spend less on
gasoline.
Foreign economic developments, however, could pose risks to the
U.S. economic outlook. Although the pace of growth abroad appears
to have stepped up slightly in the second half of last year, foreign
economies are confronting a number of challenges that could restrain economic activity. In China, economic growth could slow
more than anticipated as policymakers address financial
vulnerabilities and manage the desired transition to less reliance
on exports and investment as sources of growth. In the euro area,
recovery remains slow, and inflation has fallen to very low levels;
although highly accommodative monetary policy should help boost
economic growth and inflation there, downside risks to economic
activity in the region remain.
The uncertainty surrounding the foreign outlook, however, does
not exclusively reflect downside risks. We could see economic activity respond to the policy stimulus now being provided by foreign
central banks more strongly than we currently anticipate, and the

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recent decline in world oil prices could boost overall global economic growth more than we expect.
U.S. inflation continues to run below the Committee’s 2-percent
objective. In large part, the recent softness in the all-items measure
of inflation for personal consumption expenditures reflects the drop
in oil prices. Indeed, the PCE price index edged down during the
fourth quarter of last year and looks to be on track to register a
more significant decline this quarter because of falling consumer
energy prices. But core PCE inflation has also slowed since last
summer, in part reflecting declines in the prices of many imported
items and perhaps also some passthrough of lower energy costs
into core consumer prices.
Despite the very low recent readings on actual inflation, inflation
expectations as measured in a range of surveys of households and
professional forecasters have thus far remained stable. However,
inflation compensation, as calculated from the yields of real and
nominal Treasury securities, has declined. As best we can tell, the
fall in inflation compensation mainly reflects factors other than a
reduction in longer-term inflation expectations. The Committee expects inflation to decline further in the near term before rising
gradually toward 2 percent over the medium term as the labor
market improves further and the transitory effects of lower energy
prices and other factors dissipate, but we will continue to monitor
inflation developments closely.
I will now turn to monetary policy. The Federal Open Market
Committee is committed to policies that promote maximum employment and price stability, consistent with our mandate from the
Congress. As my description of economic developments indicated,
our economy has made important progress toward the objective of
maximum employment, reflecting in part support from the highly
accommodative stance of monetary policy in recent years. In light
of the cumulative progress toward maximum employment and the
substantial improvement in the outlook for labor market conditions—the stated objective of the Committee’s recent asset purchase program—the FOMC concluded that program at the end of
October.
Even so, the Committee judges that a high degree of policy accommodation remains appropriate to foster further improvement in
labor market conditions and to promote a return of inflation toward
2 percent over the medium term. Accordingly, the FOMC has continued to maintain the target range for the Federal funds rate at
0 to 1⁄4 percent and to keep the Federal Reserve’s holdings of
longer-term securities at their current elevated level to help maintain accommodative financial conditions. The FOMC is also providing forward guidance that offers information about our policy
outlook and expectations for the future path of the Federal funds
rate. In that regard, the Committee judged, in December and January, that it can be patient in beginning to raise the Federal funds
rate. This judgment reflects the fact that inflation continues to run
well below the Committee’s 2-percent objective and that room for
sustainable improvements in labor market conditions still remains.
The FOMC’s assessment that it can be patient in beginning to
normalize policy means that the Committee considers it unlikely
that economic conditions will warrant an increase in the target

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6
range for the Federal funds rate for at least the next couple of
FOMC meetings. If economic conditions continue to improve, as the
Committee anticipates, the Committee will at some point begin
considering an increase in the target range for the Federal funds
rate on a meeting-by-meeting basis. Before then, the Committee
will change its forward guidance. However, it is important to emphasize that a modification of the forward guidance should not be
read as indicating that the Committee will necessarily increase the
target range in a couple of meetings. Instead the modification
should be understood as reflecting the Committee’s judgment that
conditions have improved to the point where it will soon be the
case that a change in the target range could be warranted at any
meeting. Provided that labor market conditions continue to improve
and further improvement is expected, the Committee anticipates
that it will be appropriate to raise the target range for the Federal
funds rate when, on the basis of incoming data, the Committee is
reasonably confident that inflation will move back over the medium
term toward our 2-percent objective.
It continues to be the FOMC’s assessment that even after employment and inflation are near levels consistent with our dual
mandate, economic conditions may, for some time, warrant keeping
the Federal funds rate below levels the Committee views as normal
in the longer run. It is possible, for example, that it may be necessary for the Federal funds rate to run temporarily below its normal longer-run level because the residual effects of the financial
crisis may continue to weigh on economic activity. As such factors
continue to dissipate, we would expect the Federal funds rate to
move toward its longer-run normal level. In response to unforeseen
developments, the Committee will adjust the target range for the
Federal funds rate to best promote the achievement of maximum
employment and 2-percent inflation.
Let me now turn to the mechanics of how we intend to normalize
the stance and conduct of monetary policy when a decision is eventually made to raise the target range for the Federal funds rate.
Last September, the FOMC issued its statement on Policy Normalization Principles and Plans. This statement provides information
about the Committee’s likely approach to raising short-term interest rates and reducing the Federal Reserve’s securities holdings. As
is always the case in setting policy, the Committee will determine
the timing and pace of policy normalization so as to promote its
statutory mandate to foster maximum employment and price stability.
The FOMC intends to adjust the stance of monetary policy during normalization primarily by changing its target range for the
Federal funds rate and not by actively managing the Federal Reserve’s balance sheet. The Committee is confident that it has the
tools it needs to raise short-term interest rates when it becomes appropriate to do so and to maintain reasonable control of the level
of short-term interest rates as policy continues to firm thereafter,
even though the level of reserves held by depository institutions is
likely to diminish only gradually. The primary means of raising the
Federal funds rate will be to increase the rate of interest paid on
excess reserves. The Committee also will use an overnight reverse
repurchase agreement facility and other supplementary tools as

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needed to help control the Federal funds rate. As economic and financial conditions evolve, the Committee will phaseout these supplementary tools when they are no longer needed.
The Committee intends to reduce its securities holdings in a
gradual and predictable manner primarily by ceasing to reinvest
repayments of principal from securities held by the Federal Reserve. It is the Committee’s intention to hold, in the longer run, no
more securities than necessary for the efficient and effective implementation of monetary policy and that these securities be primarily
Treasury securities.
In sum, since the July 2014 Monetary Policy Report, there has
been important progress toward the FOMC’s objective of maximum
employment. However, despite this improvement, too many Americans remain unemployed or underemployed, wage growth is still
sluggish, and inflation remains well below our longer-run objective.
As always, the Federal Reserve remains committed to employing
its tools to best promote the attainment of its objectives of maximum employment and price stability.
Thank you. I would be pleased to take your questions.
Chairman SHELBY. Madam Chair, I first would want to get into
measures of inflation. You touched on that a little. The Federal Reserve I understand currently uses an inflation measure of core personal consumption expenditures, or PCE, which excludes volatile
food and energy prices. Several alternative measures of inflation
exist, including one called the ‘‘Trimmed Mean PCE,’’ which strips
out a larger basket of volatile items from the calculation. I know
you know all this.
Do you think that the Federal Open Market Committee should
incorporate alternative measures of inflation such as Trimmed
Mean PCE? And could you explain to us the risk of not properly
gauging inflation expectations?
Ms. YELLEN. Thank you. So let me first say that the Federal
Open Market Committee’s 2-percent objective refers to the increase, the annual increase in the total PCE price index that includes food and energy. Food and energy are very important components of every household’s spending basket, and I do not think it
would make a lot of sense or be acceptable to Americans to focus
on a measure that strips out these important components of the
consumer basket. So we focus on total consumer prices, including
food and energy.
But at the same time, we recognize that food and energy are particularly volatile prices, and in order to get a better forecast sometimes of the underlying trend in inflation, we do look at so-called
core inflation that strips out these measures.
And in trying to understand trends in inflation and the factors
impacting inflation, we look at a broad variety of measures of inflation. Although our formal index is the so-called PCE price index,
we look at the CPI, which is well known to most Americans, and
also to these Trimmed Mean and other measures that you cited.
Chairman SHELBY. You have opined on the use of monetary policy rules such as the Taylor rule, which would provide the Fed with
a systematic way to conduct policy in response to changes in economic conditions. I believe that would also give the public a greater
understanding of and perhaps confidence in the Fed’s strategy.

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You have stated, and I will quote: ‘‘Rules of the general sort proposed by Taylor capture well our statutory mandate to promote
maximum employment and price stability.’’
You have expressed concerns, however, over the effectiveness of
such rules in times of economic stress. Would you support the use
of a monetary policy rule of the Fed’s choosing if the Fed had discretion to modify it in times of economic disruption?
Ms. YELLEN. I am not a proponent of chaining the Federal Open
Market Committee in its decision making to any rule whatsoever.
But monetary policy needs to take account of a wide range of factors, some of which are unusual and require special attention, and
that is true even outside times of financial crisis.
In his original paper on this topic, John Taylor himself pointed
to conditions such as the 1987 stock market crash that would have
required a different response. I would say that it is useful for us
to consult the recommendations of rules of the Taylor type and others, and we do so routinely, and they are an important input into
what ultimately is a decision that requires sound judgment.
Chairman SHELBY. Thank you.
In a recent speech, Richard Fisher, the President of the Dallas
Federal Reserve Bank, has suggested a reorganization of the Federal Open Market Committee, specifically advocates for a rotating
Vice Chairmanship of the Federal Open Market Committee, as well
as a stronger role for regional banks on the Committee.
Do you support any of Mr. Fisher’s proposals? And why, or why
not?
Ms. YELLEN. Well, Senator Shelby, I think the current structure
of the Federal Open Market Committee and the voting structure
was decided on by Congress a long time ago, after weighing a
whole variety of considerations about the need for control in Washington and the importance of regional representation.
It is, of course, something that Congress could, if it wished, revisit. But I would say that it has worked very well. We have a
broad range of opinion that is represented at the table, and active
debates. The decision to appoint the President of the New York Fed
as Vice Chair reflected the reality that the New York Fed conducts
open market operations on behalf of the system and has special
and deep expertise pertaining to financial markets. And I think
that has worked well and continues to be true, that there is special
expertise in New York.
Chairman SHELBY. A recent article written by two economists for
the think tank e21 proposes reducing the number of Federal Reserve districts from 12 to 5 and making the Presidents of all regional banks voting members of the Federal Open Market Committee. The article states that this would preserve regional diversity while giving more authority over monetary policy to Reserve
Banks that currently rotate as voting members. It also posits that
it could allow for greater safety and soundness and remove the uncertainty created by 19 independent FOMC members.
Do you oppose consolidation of Federal Reserve districts?
Ms. YELLEN. Senator, again, this is a matter for Congress to decide. The structure of the Federal Reserve reflects choices that
were hammered out 100 years ago, and I think the current struc-

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9
ture works well, so I would not recommend changes. But, again,
you know, the Federal Reserve Banks are——
Chairman SHELBY. It is up to Congress, is it not?
Ms. YELLEN. ——play important roles in their communities, but,
again, this is up to Congress to consider.
Chairman SHELBY. My last question to you in this round: asset
threshold for banks. A recent report by the Office of Financial Research shows a large disparity in systemic risk between the largest
banks and those that are smaller and closer to $50 billion in assets.
All banks above $50 billion are subject to enhanced prudential regulation regardless of where they fall in this systemic important
scale.
Do you think the findings of the OFR, the Office of Financial Research, should be incorporated or considered in the determination
of whether a bank is systemically significant?
Ms. YELLEN. Well, Senator, we absolutely recognize in the Federal Reserve that the largest banks and those closer to $50 billion
are quite different in terms of their systemic footprint, and we have
many different measures that help us decide on the systemic importance of an institution, and there obviously are large differences
there.
In Dodd-Frank, Congress gave us the flexibility to tailor our supervision and regulation to make it appropriate to the systemic importance and complexity and size of a bank, and to the maximum
extent possible within that legislation, we have tried to use the
powers that we have to appropriately tailor our supervision and
regulation.
So, for example, we recently proposed extra capital charges on
the largest and most systemic institutions and higher leverage requirements, and those requirements would not apply to the smaller
institutions. But there are many other examples as well.
Chairman SHELBY. Do you know of any community or regional
bank that has caused systemic risk to our economy?
Ms. YELLEN. There may have been episodes in which there were
bank failures of smaller banks that did threaten systemic consequences, but certainly it is the largest——
Chairman SHELBY. I believe you chose your words carefully. You
said ‘‘may have been.’’ Do you know of any yourself and could you
furnish any for the record where smaller banks, any of them, or regional banks have caused systemic risk to our economy or to our
banking system? Would you furnish that for the record if you do?
Ms. YELLEN. So I will certainly look into it and furnish it. I am
trying to agree with you that it is——
Chairman SHELBY. That they do not——
Ms. YELLEN. By and large, that has not been the case.
Chairman SHELBY. Thank you.
Ms. YELLEN. Yes, I agree with that.
Chairman SHELBY. Thank you, Madam Chair.
Senator Brown.
Senator BROWN. Thank you, Mr. Chairman.
I have one comment about your answer to the last question of
the Chairman’s about capital requirements that you have applied.
I think there is no question, as reports have recently made pretty
clear, that it has made for stronger banks and a more stable finan-

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cial system, so thank you. And Senator Vitter on this Committee
I know has had special interest, as has Senator Shelby, in strong
capital standards. So thank you for that.
Madam Chair, I mentioned in my opening statement that last
October you gave a speech on income and wealth inequality. All of
us agree the best way to address that is a more robust job-creating
economy. What steps are you taking to incorporate your concerns
about that into the monetary policy decisions?
Ms. YELLEN. Well, Senator Brown, as you know, we are very
committed to both parts of the dual mandate—price stability and
maximum employment. We have been running a very accommodative monetary policy in order to promote stronger conditions in the
labor market. We have been monitoring a wide variety of indicators
of labor market performance, not focusing on any single summary
measure, and in particular, for example, the large magnitude of
part-time involuntary employment workers who want full-time
jobs, the decline in labor force participation, part of which we understand to be or believe to be cyclical, these are things that we
are monitoring very closely.
We are also looking at wage growth, and the fact that wage
growth has really not picked up very much during this recovery I
take to be another signal that, although the labor market is improving, we have further to go, and we want to promote full recovery.
Senator BROWN. Thank you. For much of our Nation’s economic
history, productivity has tracked wages, but since the 1970s, as you
know, this has changed; and productivity has continued, particularly in the last 15 years or so, to grow while wages have not. How
do you explain this change? And what are the dangers of wages
being uncoupled from productivity?
Ms. YELLEN. Well, we have seen a significant increase in the
share of the pie or GDP that accrues to capital as opposed to labor,
and that occurs when the growth in inflation-adjusted or real
wages fails to mirror the growth in productivity. So that has been
occurring now for some time, and we have seen that occur during
the recovery.
Real wages tend to rise more rapidly in a strong labor market,
so I interpret part of that phenomenon as a signal, a sign that the
labor market is not yet fully recovered. But I should also say that
there are longer-term structural factors that may also be affecting
the shares of the pie that accrue to labor and capital.
I think one of these factors, recent research points to the fact
that many labor-intensive activities in the global production chain
are being increasingly outsourced, and that phenomenon I think
has tended to push down the share of income going to labor as opposed to capital over the last decade or so. There is research on
this topic, so I think it is a combination of structural factors, but
also remaining cyclical weakness——
Senator BROWN. And that includes the organization of labor, of
workers being organized?
Ms. YELLEN. That certainly could include that as a factor.
Senator BROWN. I appreciate the steps that you and your predecessor have made to bring greater transparency to the Fed. As you
know, there is a proposal in the House and Senate to go one step

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further and require the GAO to audit the Fed’s monetary policy deliberations. What are your thoughts on that?
Ms. YELLEN. I want to be completely clear that I strongly oppose
‘‘audit the Fed.’’ I believe the transparency and providing Congress
and the public with adequate information to be able to understand
our operations, our financial condition, the conduct of our meeting
the responsibilities that Congress has assigned to us is essential.
But ‘‘audit the Fed’’ is a bill that would politicize monetary policy,
would bring short-term political pressures to bear on the Fed.
In terms of openness about our financial accounts, we are extensively audited. I brought with me this volume which contains an
independent outside auditor’s—Deloitte & Touche’s—audits of our
financial statements. So in the normal sense in which people understand what auditing is about, the Federal Reserve is extensively
audited. What I think is really critically important is that the Fed
be able to deliberate on the best way to meet the responsibilities
that Congress has assigned to us, to achieve maximum employment
and price stability, and that we be able to do so free of short-term
political pressures.
I would remind you that in the early 1970s, when inflation built
and became an endemic problem in the U.S. economy, history suggests that there was political pressure on the Fed that interfered
with its decision making. It was in the last 1970s that Congress
put in place the current feature of law that exempts monetary policy deliberations and decisions, the one area that is exempted from
GAO audits. And I really wonder whether or not the Volcker Fed
would have had the courage to take the hard decisions that were
necessary to bring down inflation and get that finally under control, something I think has been very important to the performance
of the U.S. economy, I wonder if that would have happened with
GAO reviews in real time of monetary policy decision making.
So central bank independence in conducting monetary policy is
considered a best practice for central banks around the world. We
are one of many, many central banks that are independent, and
academic studies I think establish beyond the shadow of a doubt
that independent central banks perform better, the economies are
more stable and have better performance in terms of inflation and
macroeconomic stability.
Senator BROWN. A last brief question, Madam Chair. You mentioned your Community Advisory Council. What are you doing to
encourage regional bank presidents to follow suit?
Ms. YELLEN. Well, regional banks, most of the regional banks are
actively involved with their communities. They have community development programs and are really trying to address the special
needs of their communities. But in Washington, we also encourage
and have oversight of those activities and strongly encourage similar practices.
Senator BROWN. Thank you.
Thank you, Mr. Chairman.
Chairman SHELBY. Senator Crapo.
Senator CRAPO. Thank you, Mr. Chairman, and, Chair Yellen, I
would like to use my time going over the EGRPRA process that we
are in right now with you.

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The first Economic Growth and Regulatory Paperwork Act, or
EGRPRA, review submitted to Congress in 2007 states, ‘‘Besides
reviewing all of our existing regulations in an effort to eliminate
unnecessary burdens, the Federal banking agencies work together
to minimize burdens resulting from new regulations and current
policy statements as they were being adopted.’’
I think you know where I am headed here.
The report submitted to Congress specifically discussed consumer
financial protection issues, anti-money-laundering issues, and included recently adopted rules. However, included in the Federal
Register put forward for this current 10-year EGRPRA process that
we are now in, where we are supposed to be having our financial
regulators by law look for outdated, unnecessary, and unduly burdensome regulatory requirements in the system, there was, I think,
a remarkable couple of footnotes included which basically said that
the agencies engaged this time around are going to back off. They
are basically not going to review new regulations that have gone
into effect, not going to review regulations that are currently being
considered and will go into effect during the EGRPRA process, and
have clarified that the CFPB is not even going to be a part of the
process. The entire Consumer Financial Protection Bureau will not
be a part of the process.
My question to you is going to be: Would you not agree that we
should have a thorough EGRPRA process that reviews all rules and
that the Consumer Financial Protection Bureau or the consumer
regulatory system should be a part of the EGRPRA process? But
before I put that question to you, I would just like to say we had
a hearing last week which was dealing with community banks and
credit unions and the regulatory burdens that they face. And I
asked the witnesses, and every one of them said that in the set of
rules and regulations that they feel are creating unnecessary and
unduly burdensome pressures are rules and regulations coming
from the consumer financial arena, coming from the anti-moneylaundering arena, and coming from the Dodd-Frank legislation that
is recently enacted which would be exempted from the current
agency’s review.
A couple of examples they gave were the qualified mortgage rule
that needs to be reviewed, the Volcker rule that needs to be reviewed, and yet all of this is apparently outside the scope of the
entire EGRPRA process that the agencies are now undertaking.
Could you respond, please?
Ms. YELLEN. So in the rules that have gone into effect or are in
the process under consideration and will go into effect related to
Dodd-Frank, we had Federal Register notices, took public comment,
an important part of designing those rules was considering the
costs, the burdens, and what was the most effective and appropriate way of designing regulations to meet Dodd-Frank objectives.
So in a sense, what EGRPRA asks of the agencies is something
that we have gone through very recently in the process of designing
regulations in some cases that have not yet even gone into effect.
Senator CRAPO. Would your answer be the same for the Consumer Financial Protection Bureau, because it is new that we do
not need to review its rules and regulations?

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Ms. YELLEN. I really cannot speak to—you know, we do not have
that rulemaking authority, and, sir, I cannot speak to what role the
CFPB is going to play.
Senator CRAPO. Well, it seems to me—I understand the argument. In fact, that is the argument we got from the regulators who
were before us 2 weeks ago in one of our hearings. But it seems
to me that that is not what EGRPRA says. EGRPRA does not say,
‘‘Let us review the rules and regulations that are old.’’ It says, ‘‘Let
us review them all.’’ That is what the law was passed to do. And
if you look at the Dodd-Frank legislation that you were just saying
has recently been through the process, or many of its rules and regulations have recently been through the process, the Dodd-Frank
legislation itself was 848 pages long. But the page count of the regulations required by Dodd-Frank has mushroomed to more than
15,000 pages so far, and they are not finished, and over 15 million
words of regulatory text. And to say that the fact that they are new
and the fact that the implementation process has just recently been
completed on them I do not think is a satisfactory response to the
requirement of EGRPRA that the agencies need to look at their
regulations and identify those that are unnecessary or unduly burdensome.
Ms. YELLEN. Well, we are holding public hearings and will be
taking extensive public comments. You mentioned community
banks. We are very focused on trying to find ways to reduce the
burdens on community banks, and during this process we will be
very sensitive to looking for ways in which we can reduce the burden of regulation, and we will be reporting back to you.
Senator CRAPO. Well, thank you. My time is up. But I would just
encourage you and the other Federal regulators to focus on the full
intent of EGRPRA and expand your review.
Thank you.
Ms. YELLEN. Thank you.
Chairman SHELBY. Senator Reed.
Senator REED. Well, thank you very much, Mr. Chairman, and,
Madam Chair, welcome.
The Federal Reserve has significant responsibilities in many
areas. One is monetary policy, in which the Federal Reserve exercises a historic, customary independence. But one other area is regulatory policy, actually supervising the operation of large financial
institutions, which leads inevitably back to the New York Federal
Reserve, which has a great deal of authority, and several of us
have had proposals to help, we hope, improve this regulatory oversight, which has been criticized in the past, I mean not only in the
run-up to 2007 and 2008, but even recently.
Can you please describe what you have done for greater accountability from the New York Fed?
Ms. YELLEN. So in the aftermath of the hearings that were held
here and the allegations that were raised about the New York Fed,
we have undertaken an internal review, and that is in process.
Now, I should say that the question that we think is important
that was raised there is—let me step back. We have a process for
supervising the largest banks that is a systemwide process, involves systemwide committees, and is led by Washington, by the
Board.

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The Reserve Banks that are involved with the supervision of the
institutions in that large bank portfolio take part in the process
that is a groupwide and Board-led process. So the question we
thought is important for us to look at is: Are we in that process,
the Board and the group that supervises these banks and makes
decisions, is the relevant information being fed up to the highest
decision-making levels, including the Board of Governors? And to
the extent that within a Reserve Bank supervision teams there
may be divergent opinions, we want to make sure that dissident
voices are heard and that dissident views can reach the highest
levels for consideration.
So that is the question that we have asked our internal team to
look at. The review includes the New York Fed, but also other Reserve Banks that are also involved in large bank supervision, because avoiding group think and making sure that dissident views
can be heard at the highest levels is really critical to sound supervision.
We have also asked our Inspector General to undertake his own
independent review, and these are in process, and I expect them
to be completed this year.
Senator REED. And you anticipate that the Federal Reserve, the
Board of Governors, will take specific action which is recognizable
and transparent to the Congress and to the people that——
Ms. YELLEN. Yes. I mean, we expect to report to you on the findings of these investigations, and if the need and suggestions for improvement are found, we expect to put those into effect.
Senator REED. At this point do you anticipate that there will be
needs to improve? I mean, that is what seems to strike most people
when you look at some of the incidents that have taken place over
the last several years, that some change has to happen. The question is: Will it be legislative or administrative?
Ms. YELLEN. Well, we will certainly take any administrative
changes that appear to be called for. You know, I would like to wait
and see what the findings are of the reviews before deciding on the
appropriate measures.
Senator REED. Thank you, Madam Chair. My time has expired,
but let me put one more issue on the table, and perhaps we could
follow up with a question. We are all acutely sensitive to systemic
risk, and in Dodd-Frank we tried to minimize that risk by introducing the notion of clearinghouses that would take bilateral transactions, derivatives swaps, et cetera, and put them onto a platform.
But that itself introduces a degree of risk in terms of the clearinghouses themselves, and I just want to obviously put on your screen,
which I think already is, the sensitivity that we have to continued
oversight of these clearinghouses, both our own and others across
the globe, because of the potential systemic problem. So can I just
put that on the table?
Ms. YELLEN. Absolutely, and I want you to know that I am—we
are very attuned to the need to be careful in our supervision that
we have taken a step forward, I think, as you mentioned, in moving a great deal of clearing to clearinghouses. Eight financial market utilities, including the most important central counterparties,
have been designated by FSOC as systemically important financial
market utilities, and they are being supervised by the Federal Re-

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serve, those based in the United States, the Fed, the CFTC, and
the SEC.
There are a set of principles that have been put in place and
agreed globally for what best practices are in terms of liquidity
standards and other risk management standards for these financial
market utilities, and it is extremely high priority for us to make
sure that we vigorously enforce those standards, and we are in the
process of doing so, because although these entities reduce risks
that were previously present, they create their own risks if they
are not appropriately managed.
So I completely agree, this is important, and we are giving it a
great deal of attention.
Senator REED. Thank you very much.
Thank you, Mr. Chairman.
Chairman SHELBY. Senator Corker.
Senator CORKER. Thank you, Mr. Chairman. And, Chair Yellen,
thank you for being here today.
There is a push right now to add a provision addressing currency
manipulation in the Asian Pacific trade deal. Do you think trade
negotiations are an appropriate place for these currency issues?
And what if such an effort leads to the inclusion of an international
arbitration panel under TPP’s enforcement procedures where companies or other Nations could challenge future monetary policy decisions by the Fed?
Ms. YELLEN. So let me first say that I think currency manipulation that is undertaken in order to alter the competitive landscape
and give one country an advantage in international trade is inappropriate and needs to be addressed.
But, that said, there are many factors that influence the value
of currencies, including differences in economic growth and capital
flows, and as you mentioned, monetary policy is a factor that can
have an impact on currencies.
So I would really be concerned about a regime that would introduce sanctions for currency manipulation into trade agreements
when it could be the case that it would hamper or even hobble
monetary policy. Monetary policies we have undertaken, the Federal Reserve has undertaken over the last number of years, having
designed for valid domestic objectives of price stability and maximum employment. We have undertaken monetary policy in order
to achieve those objectives, and that certainly is not currency manipulation. But monetary policy affects the economy through many
channels, perhaps most importantly through interest rates, but
monetary policy may have impact on currency values. And so I
would see that kind of direction as having the potential to perhaps
hamper the conduct of monetary policy or even hobble the conduct
of monetary policy. And I would really worry greatly about that approach.
Senator CORKER. So that is a long answer, but the answer I
think you just said is you would have a significant problem with
that being part of a trade deal. Is that correct?
Ms. YELLEN. Yes, I would.
Senator CORKER. OK. I want to follow the ‘‘audit the Fed’’ questioning a little bit and walk through a series here, and if we could
be a little briefer with our answers, that would be good.

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The first is with respect to the Fed’s lending facilities and the
discount window access during the financial crisis. There are legitimate questions about how these facilities were conducted, but to a
large extent, Congress addressed this issue by adopting the Sanders amendment to Dodd-Frank. Can you speak to the impact of the
Sanders amendment on GAO’s ability to audit crisis credit facilities?
Ms. YELLEN. Well, in response to that amendment, the GAO conducted a complete review of the use of our 13(3) emergency lending
authorities in all of the programs that were created and conducted
an audit that was concluded I believe in mid-2011. In addition, the
GAO has the ability to audit open market operations and discount
window lending, and we now report regularly all the details—or
the details of our open market operations and with a 2-year lag our
discount window lending.
Senator CORKER. So those are fully transparent and fully audited
now. Is that correct?
Ms. YELLEN. That is correct.
Senator CORKER. The second concern I have heard raised by the
‘‘audit the Fed’’ advocates is the size and composition of the Fed’s
current $4.5 trillion balance sheet. Does the Fed disclose the types
of assets that make up that $4.5 trillion?
Ms. YELLEN. Yes. We have audited financial statements which I
have a copy of right here. We report on a security-by-security basis.
All of the securities that are in that portfolio, they are reported on
the New York Fed’s Web site.
Senator CORKER. By CUSIP number, is that correct?
Ms. YELLEN. By CUSIP number. And we have a weekly balance
sheet that reports significant details of our balance sheet.
Senator CORKER. So I hate to ask this question, but I have read
some quotes lately, and I would just like for you—not by you but
by ‘‘audit the Fed’’ advocates. While you may issue an updated balance sheet each week, how do we know those securities actually
exist?
Ms. YELLEN. Well, we have an outside accounting firm, an independent auditor, currently Deloitte & Touche, that does a thorough
review of our balance sheet, and that is what is contained in our
annual report, both the Board and all of the Federal Reserve Banks
and the consolidated Federal Reserve System.
Senator CORKER. So they do exist?
Ms. YELLEN. They do exist, Senator.
Senator CORKER. Just my last point. It is obvious to me that the
‘‘audit the Fed’’ effort is to not address auditing the Fed, because
the Fed is audited, and every day you publish the CUSIP numbers
of the things that you own and the——
Ms. YELLEN. Correct.
Senator CORKER. ——credit facilities that you put in place during
an emergency, all of that is audited now. So to me, it is an attempt
to allow Congress to be able to put pressure on Fed members relative to monetary policy, and I would just advocate that that would
not be a particularly good idea and it would cause us to put off
tough decisions for the future, like we currently are doing with
budgetary matters. Do you agree with that?

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Ms. YELLEN. I strongly agree. As I indicated—well, let me say
more generally, I think if you look around the globe in modern
times and you consider every country that has gone through a period of chronic high inflation or hyperinflation, what you will find
is a central bank that was pressured to print money by——
Senator CORKER. Politicians.
Ms. YELLEN. By politicians who were unable to balance the budget.
Senator CORKER. So I will close. I thank you, Mr. Chairman, for
the little extra time. I do think one area that greater transparency
could be utilized is in the regulatory area around things like CCAR
and others. I think that that is an area where we should focus, and
I hope that over the course of the next several months the Fed will
work with us in a constructive manner so that we more fully understand how you go about that process. It does seem like a black
box now. It is something that I think should be far more transparent, and I hope you will work with us in that regard.
Ms. YELLEN. We would be pleased to do so.
Senator CORKER. Thank you.
Chairman SHELBY. Thank you, Senator Corker.
Senator Schumer.
Senator SCHUMER. Thank you, Mr. Chairman. Thank you, Chair
Yellen, for your testimony. Your hard work, your dedication, what
I believe is your sound judgment and timely decision making have
been a driving force behind the recovery. But I do not envy you
your position. You and other members of the FOMC have important decisions to make in the coming months.
Let me urge you to act with caution before raising rates. While
there may be data points, positive signs of economic growth, let me
be clear. I believe the Fed should remain committed to its current
accommodative policy until it sees clear evidence that shows a consistent improvement in wages. In the current environment, wage
growth needs to be a major factor, maybe even the lodestar, for the
Fed when it is deciding whether to raise rates.
As I have said over and over again, to me the single biggest problem the country faces is the decline of middle-class incomes, and
while economic progress has been seen in the past year—strong expectations for growth of GDP, for instance—wage gains have remained sluggish through the recovery. Middle-class Americans
have not yet seen the benefits of this growth in their take-home
pay, and we all know the statistics of middle-class incomes declining by 6.5 percent over the decade, $3,600 lower than when President Bush took office in 2001.
So I think the Fed must think long and hard before implementing a monetary policy that could reduce demand and hamper
the growth of the economy. Wage growth not only serves to benefit
middle-class workers who have been asked to do more with less for
too long, but placing a priority on consistent wage growth prior to
raising rates serves the dual role of fostering a rise in inflation toward the Fed’s 2-percent target, one that you have delineated.
Overall growth is rightfully a key factor in the decision, but I
firmly believe the Fed should not raise rates until wages are back
on a steady trend, steady upward trend.

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So as you begin to consider the path toward normalization of
rates, I think the Fed must place a priority on seeing consistent
real wage growth prior to any decision making. Those who are worried about inflation—you always have to worry about it, but they
should look at the last several years. There are few signs of incipient inflation, and, in fact, many economists believe that the
chances of deflation are greater than worries of drastic rises in inflation, and concerns of deflation are further precipitated by the
prospect of the Fed raising rates too soon.
So I think it is a prudent decision for our broader economy as
well as middle-class families across the country to wait until wages
really begin to rise.
So, first, do you agree it is critical for the FOMC to see evidence
of consistent wage growth prior to deciding to raise interest rates
absent indicators that inflation is climbing well above or above the
Fed’s 2-percent target? And if the FOMC does not wait, what are
the potential consequences?
Ms. YELLEN. Well, Senator, our objective is price stability, which
we have defined as 2-percent inflation. And as I indicated, before
beginning to raise rates, the Committee needs to be reasonably confident that over the medium term inflation will move up toward its
2-percent objective.
I do not want to set down any single criterion that is necessary
for that to occur. The Committee does look at wage growth. We
have not yet seen—there are perhaps hints, but we have not yet
seen any significant pick-up in wage growth. But there are a number of different factors that affect the inflation outlook, and we will
be considering carefully a range of evidence that pertains to the inflation outlook and will determine the confidence that we feel in
our—we forecast that inflation will move back up to 2 percent. Certainly seeing continued improvement in the labor market adds to
that confidence, and it would add to our confidence also that over
time wages will pick up. But our objective is 2-percent inflation,
and we will look at a wide range of evidence in deciding that.
Senator SCHUMER. Do you feel that the worry of rampant inflation, above 2-percent inflation, is any greater than the worry of deflation given the flatness of wages, 70 percent of the economy is
wages, jobs, broadly defined?
Ms. YELLEN. The Committee feels, I think anticipates that inflation is being held down by transitory factors, particularly the decline we have seen in oil prices. We have also had considerable
slack in the labor market, and it is diminishing over time. Now
wages tend to be a lagging indicator of improvement in the labor
market. We have seen improvement, and if we continue to see improvement, it would add to my confidence, especially as the impact
of oil prices diminishes over time, that inflation will move back up.
Senator SCHUMER. One final question. Do you see any real evidence of inflation heading above 2 percent right now given——
Ms. YELLEN. I do not see any evidence of that, but inflation—we
need to be forward-looking. The Committee is forward-looking in
setting monetary policy, and we do see that the labor market is improving, and we are getting closer to our goal of maximum employment.

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It is important to remember that monetary policy is highly accommodative. We have held the Federal funds rate at a 0 to 1⁄4 percent range and have a large balance sheet, and these policies have
been in place for 6 years now. And we do have an economy that
fortunately appears to be recovering, and we do have to be forwardlooking in setting monetary policy. But I want to assure you we
want to see that recovery continue. We do not feel the labor market
is fully healed, and that is a process we want to go on. And we do
not want to take policy actions that will hamper that, but monetary
policy is very accommodative at the present——
Senator SCHUMER. Thank you. I urge caution.
Chairman SHELBY. Senator Toomey.
Senator TOOMEY. Thank you, Mr. Chairman. And thank you,
Madam Chairman, for joining us today.
Let me share a completely opposing point of view from that of
the Senator from New York, which will not be a shock to Members
of this Committee. I cannot help but observe what strikes me as
a very obvious paradox here, and that is the financial and economic
crisis is over. It has been over for years, at least 6 or 7 years. And
yet we still maintain crisis-level interest rates. We have got no
wave of defaults or massive bankruptcies going on. Unemployment
has gone from 10 percent to sub-6 percent. GDP growth has been
weak. I think that is easily explained by the avalanche of new regulations, certainly not monetary policy, but it has been positive for
years. Consumer sentiment is relatively high. The FOMC in January described the economic recovery as solid. Walmart, interestingly, has made an announcement that suggests we might even be
approaching NAIRU.
The crisis has been over for a long time. And it is not as though
there is no price to be paid by having this unbelievably accommodative policy. Most immediately I see the problem incurred by
my constituents, who may have spent a lifetime working hard, sacrificing, saving, forgoing a vacation they might have taken, forgoing
a splurge here and there, so that they could save for their retirement and buy a CD, have some money on deposit at a bank, and
use that to supplement a modest pension or Social Security payments. Of course, their reward now is they get nothing. Zero. That
is what they earned on their savings year after year.
Meanwhile, of course, we have all the risks associated with this:
the risk of bubbles forming, I would argue the fixed income markets probably are a huge bubble at the moment. We have the inhibition of price discovery in the financial sector. We facilitate excessive deficits because they look so manageable with zero interest
rate environment. Credit is rationed. And what are the benefits of
this? The benefits are, at best, a timing shift in economic activity.
At best, we are moving economic activity that would otherwise
occur in the future closer to the present. As we all know, if artificially low interest rates led to strong economic growth, then everyone around the world would have zero interest rates and everything would be booming. And that is not the case.
So, Madam Chairman, I know you and I disagree on this, but I
would just suggest the crisis is clearly long over. I think the time
for normalization is well overdue. I hope we get there soon. But I
did want to ask you a specific question that is related, and that is,

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you have said repeatedly that the goal of price stability is 2-percent
inflation. Well, certainly there is a congressional mandate on price
stability. But when the Fed decides that it is acceptable—in fact,
that that is met by savers losing 2 percent of their purchasing
power annually—and let me put that a different way. That means
a 30-year-old woman who is saving, by the time she retires what
she has saved at that point will have lost half of its value. Half of
it is gone.
How is that consistent with price stability?
Ms. YELLEN. Well, the Federal Reserve is—the FOMC, in carrying out Congress’ mandate, really does have to define how we understand price stability operationally. Two-percent inflation is an
inflation rate that we chose largely for two reasons:
First of all, it is well known that price indices that we look at
contain upward biases in part because their failure to adequately
capture the benefits of new goods and quality improvement. So
there are hard-to-measure but nevertheless upward biases in price
indices.
And, second of all, because deflation is so dangerous and because
an environment of very low inflation and one of comparably extremely low interest rates makes it difficult for monetary policy to
respond to adverse shocks, we decided that in order to avoid damaging episodes of deflation, it is wise to have a small buffer that
gives greater room for monetary policy to operate.
Senator TOOMEY. Thank you. I am going to run out of time here,
so I just want to get to my second question. I would just urge you
to consider the impact of savers losing their purchasing power.
Historically, of course, we have changed the level of accommodation through open market activities, typically buying and selling securities to have corresponding changes in the level of cash. You
have suggested, if I understand you correctly, that in the process
of normalizing, assuming we will get to that process, you intend to
achieve that principally by changing the target level of the Fed
funds rate.
Ms. YELLEN. Yes.
Senator TOOMEY. And you will do that by increasing the interest
on excess reserves.
Ms. YELLEN. Correct.
Senator TOOMEY. And my question is: Since that means over
time in a normalizing environment the transfer of tens of billions
of dollars from what would go to the taxpayers to big money center
banks, why are you doing that instead of simply selling the bonds,
which is a more conventional way to operate in the open market
operation?
Ms. YELLEN. Well, remember that, first of all, we will be paying
banks rates that are comparable to those that they can earn in the
marketplace, so those payments do not involve subsidies to banks.
And, in addition, remember that we have—in expanding our provision of reserves, we have acquired longer-term assets on the asset
side of our balance sheet, and the spread above what we have been
paying in terms of interest on excess reserves is quite large. So although that will diminish over time as monetary policy is normalized, the expansion of our balance sheet, even though we are even
at present paying 25 basis points interest on reserves, we have had

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record transfers to the Treasury close to $100 billion this past year
and $500 billion since 2009. So there have been large transfers associated with that policy.
Senator TOOMEY. But that situation is likely to reverse if we get
into a normalization mode.
Ms. YELLEN. So it is very—it is likely that our transfers to, our
remittances to the Treasury will decline as short-term rates rise.
We nevertheless expect the remittances to remain positive.
Senator TOOMEY. Thank you, Mr. Chairman.
Chairman SHELBY. Senator Warner—Senator Menendez. I did
not know he had come back. Thank you. Sorry.
Senator MENENDEZ. Thank you, Mr. Chairman. I thank my colleague from Virginia.
Madam Chair, thank you for your service. As you know, our
economy continues to recover from the damage inflicted by the financial crisis and the Great Recession that followed. GDP is growing. Employers are hiring. Unemployment is falling. So it is only
natural that some are starting to look ahead to a time when the
Federal Reserve can start withdrawing the monetary stimulus that
has been so critical to our recovery.
But in my view, we still face challenges. Most Americans are still
waiting for the recovery to show up in meaningful income growth.
Long-term unemployment, while down, is still high. Inflation continues to run well below target, as it has now for an extended period of time. So from my perspective, it is critical that the Fed not
put the cart before the horse and tighten too soon.
You have said on multiple occasions that the Federal Reserve’s
timetable for raising rates will depend on the data. There are some
who say the Federal Reserve should tighten preemptively based on
unemployment or wage growth or at the first hint of inflation,
without waiting to find out if it is just a statistical blip.
What would be the risks if the Fed raises rates too soon compared to the risks of waiting?
Ms. YELLEN. Well, if the Fed were to raise rates too soon, Senator, we would risk undermining a recovery that is really just taking hold and is really succeeding, I think, in improving the labor
market. As I said, I do not think we are back to attaining yet conditions I would associate with maximum employment or normal
labor market conditions. Things have improved notably, but we are
not there yet. And so we want to see a healthy recovery continue.
In addition, as you mentioned, inflation is running well below
our 2-percent objective, and while we think a significant reason for
that is because of transitory factors, most importantly the decline
we have seen in energy prices, we are committed to our 2-percent
objective. And just as we do not want to overshoot 2 percent on the
high side, we do not want to chronically undershoot 2 percent on
the low side either.
And so before raising rates, we will want to feel confident that
the recovery will continue and that inflation is moving up over
time.
There are also, of course, risks of waiting too long to remove accommodation. We have a highly accommodative policy that has
been in place for some time. We have to be forward-looking. As the
labor market tightens, wage growth and inflation can pick up to

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the point we would overshoot our inflation objective, and conceivably there could be financial stability risks, and we want to be attentive to those as well.
Senator MENENDEZ. Right.
Ms. YELLEN. So this is a balancing of costs and risks that we are
trying to make in a deliberate and thoughtful fashion.
Senator MENENDEZ. Well, I appreciate that, and it is that balance that I hope your wisdom and that of your fellow Board members can get just about right, because I could see entering and
choking off recovery before middle-class families actually feel its
gains and trapping a too-low inflation or deflation set of circumstances, so I appreciate that.
Let me ask you one other question. I have heard several commentators say that the interest rate increase by the Fed would signal ‘‘confidence’’ to the market about the health of the U.S. economy and have a stimulative effect. Do you agree with that theory?
And if so, wouldn’t any so-called confident effect be more than offset potentially by a contractionary impact of a rate increase?
Ms. YELLEN. Well, I think it is fair to say that when we begin
to raise our target for the Federal funds rate, it will be because we
are confident about the recovery and we are reasonably confident
that inflation will move back to our 2-percent objective over time.
But that confidence will reside in real improvements that we see
in the underlying condition of households and businesses where we
would not be attempting to somehow boot-strap an improvement in
the economy that is purely occurring from a confident effect that
comes from our raising rates.
There is reason, I think, to feel good about the economic outlook.
Households have gone through major adjustments in their balance
sheets and are in better financial condition than they were. The job
situation is improving. And even though wages have not been rising in real terms very rapidly, there are more hours of work and
more jobs, so household income is improving.
Lower oil prices are boosting household income. Housing prices
have rebounded, and that has helped a lot of households, and businesses are in——
Senator MENENDEZ. So, in essence, real confidence, not confidence that is spun.
Ms. YELLEN. That is right. There is no spin here. Our confidence
in the economy has improved, and when we raise rates, it will be
a signal in our confidence in the underlying fundamentals.
Senator MENENDEZ. Thank you.
Thank you, Mr. Chairman.
Chairman SHELBY. Senator Scott.
Senator SCOTT. Thank you, Mr. Chairman. Chair Yellen, good
morning.
Ms. YELLEN. Good morning.
Senator SCOTT. Thank you for being here this morning.
Ms. YELLEN. Thank you.
Senator SCOTT. I would like to change the conversation a little
bit and talk about the insurance industry, the SIFIs, and its impact
on places like South Carolina where we have about $354 billion of
life insurance in place. As we think through the transferring of risk
that the insurance industry provides, I think it is a very important

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consideration. I am a bit prejudiced in this area because I have
spent 25 years in the insurance industry, and I appreciate the fact
that until the insurance company shows up, the ability to transfer
risk is nonexistent. So the importance of how we impact the insurance industry to the Fed I think will reverberate throughout the
economy.
I take very specific interest in the impact that the Fed may have
on regulating the insurance companies now that have been designated ‘‘systemically important’’ by FSOC, and my thought is that
last year, I believe it was, the President signed a law that clarifies
the Fed need not impose bank-like capital standards on insurance
companies under its supervision. I think this is for very obvious
reasons. When you look at the activities of banks, loans and deposits, compared to speaking to the long-term risk that most insurance
companies are holding their assets for, it is important to have that
delineation and take a very different approach to insurance companies than we do other financial institutions.
I know from experience that this is an important consideration,
and I guess my question to you is: What expertise does the Fed
have or plan to acquire as it begins to supervise insurance companies? And how closely are you working with State insurance regulators?
Ms. YELLEN. So my answer would be that we have acquired expertise; we have hired individuals who have experience in the insurance industry and are trying to build our expertise there. We
consult closely with the NAIC and with State insurance regulators
and the Federal Insurance Office. We are gaining experience because we are now in our fourth annual supervision cycle of savings
and loan holding companies, many of which are—some of which
have significant insurance activities. And, of course, several insurance companies have been designated as SIFIs, and we are supervising those as well.
We are taking the time and doing the work that is necessary to
understand their unique characteristics and fully plan to tailor our
supervision and capital and liquidity requirements for those insurance companies to make our supervisory regime appropriate. There
are very important differences between the risks faced by insurance companies and banking organizations. We have undertaken a
quantitative impact study and are actively engaged in working
with the firms we will be supervising to understand the unique
characteristics of their operations before a promulgating supervision regime.
Senator SCOTT. Thank you. You answered my third question as
well, so I will just go to the second question at this point then.
Will the Fed issue an Advanced Notice of Proposed Rulemaking
before issuing proposed rules on insurance capital standards then?
Ms. YELLEN. Yes, we will issue proposed rules. We recently
issued a proposed rule that pertains to our supervision of GE Capital, and we would do the same with the other firms.
Senator SCOTT. Thank you.
On the issue of stress tests, I know that the Fed is—through the
supervision of bank holding companies and other nonbank financial
companies, the Fed conducts stress tests to determine how well the
entity could withstand different levels of financial distress. The Fed

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currently has on its balance sheet about $4.5 trillion as a result of
the QE program, much larger, of course, than any of the financial
entities it regulates. But it appears that nobody is stress-testing
the Fed. The proverbial fox is guarding the henhouse, from my perspective.
So my question really is: As you begin to unwind the Fed’s massive balance sheet, hopefully in the near future, what assurances
can you give this Committee that the Fed will stress-test its own
QE exit plan?
Ms. YELLEN. Well, with respect to our balance sheet, let me say
that we do stress-test it, and we have issued some reports and papers where we describe what stress tests would look like when
there are interest rate shocks that would affect our balance sheet
and path of remittances. But it really is important to recognize
that the Federal Reserve is not identical to an ordinary banking organization.
First of all, capital plays a very different role in a central bank
than it does for a banking organization. Congress and the rules put
in place regarding our capital were never intended to make our
capital play the same role and it is not necessary for it to play the
same role as in a banking organization.
Importantly, unlike a bank, the Federal Reserve’s liabilities are
mainly reserves to the banking system and currency, and these are
not like the runnable deposits of an ordinary banking organization.
So the risks that the Federal Reserve faces in our balance sheet
are of a different character than those facing an ordinary bank.
But, that said, we do look at the likely consequences for our balance sheet of different interest rate scenarios.
Senator SCOTT. Certainly very different scenarios between the
Fed and the banks. Without any question, with $4.5 trillion and
the way that you wind it down would have—would reverberate
throughout the economy in a way that no other financial organization would have impacted. And the path forward is incredibly important to the economy.
Ms. YELLEN. Well, that is one reason that one of the principles
of our normalization plans is that we want to wind down our balance sheet in an orderly, gradual, and predictable way. And we
have decided to use as our main tool of policy when the time comes
for normalization something that is much more familiar both to us
and to markets, and that is, variations in short-term interest rates.
You know, of course, an alternative to that would be to say when
the time comes to want to tighten monetary policy, we could begin
to sell assets. That would be another way of going about doing
business. But we have more experience and markets have much
more experience with variations in short-term rates, and we want
to proceed in that way that is familiar to us, familiar to market
participants and the public, and to let our balance sheet play a passive role to gradually diminish in size mainly through ending reinvestment of maturing principal.
Senator SCOTT. Thank you.
Chairman SHELBY. Senator Warner, finally.
Senator WARNER. Thank you, Mr. Chairman, and thank you,
Chair Yellen. You are coming down to the home stretch here. I appreciate all your good work and this incredibly important balance

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to get right as we start down a path of unwinding. But I, like many
of my colleagues, share with inflation at such a low rate, trying to
get this timing right is so critically important.
One of the things we have talked a lot about, the statute of the
U.S. economy, but I want to raise three quick points.
One, after the January FOMC meeting, in your readouts one of
the items you mentioned was international developments. Obviously, disruption potentially in Europe, with the ongoing struggles
with Greece, China’s slowing economy, can you rank—or how will
these international developments affect the Fed’s decision on timing on monetary policy?
Ms. YELLEN. Well, there are a broad range of international developments that we monitor, and they do affect the performance, the
likely performance of the U.S. economy and factor both into our
economic forecasts and our assessment of risks.
Growth in Europe has been very slow. Growth in China is slowing. The huge decline we have seen in oil prices has had repercussions all over the global, in some areas positive, very positive, in
other areas negative. It affects our outlook, these developments,
both through trade flows and through developments in financial
markets.
The attempts of many central banks to add monetary policy accommodation is pushing down longer-run interest rates in many
parts of the world, and that is, as I mentioned in my testimony,
spilling over to the United States. So there are many channels
through which these global developments affect the U.S. outlook in
ways both positive and negative.
All in all, so factoring all of those things into account, while
there are risks—and, again, both positive and negative—stemming
from global developments, we still think that the risks for the U.S.
outlook are nearly balanced, that we have got sufficiently strong
growth in domestic demand and in domestic spending by consumers and businesses, that the recovery looks to be on solid
ground. We have just, as I mentioned in my testimony, had a very
strong growth in the second half of the year and looking forward
and analyzing the factors likely to impact domestic spending, we
are seeing perhaps not as strong as we just had but nevertheless
above-trend growth, and that really factors into account all of the
global considerations——
Senator WARNER. But, obviously, these international factors will
affect your decision——
Ms. YELLEN. They do affect our decision, yes.
Senator WARNER. I also want to associate my comments with
Senator Corker’s comments about I would like to make sure that
we deal in a perfect world with currency manipulation, but currency manipulation to one could appear as monetary policy to another.
Ms. YELLEN. Yes.
Senator WARNER. And as we have seen Japan and Europe move
toward more monetary easing, obviously one of the effects of that
has been strengthening of the dollar and it hurts our exports.
Speak to that for a moment, and if you could, let me get a last 30
seconds in at the end, so if you could take——

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Ms. YELLEN. You bet. So, you know, I think we should be on
guard against currency manipulation. The G7 in international fora
have agreed, and I know our administration in dealing with foreign
countries really tries to crack down on currency manipulation.
Nevertheless, I think certainly it is a principle agreed in the G7
that monetary policy oriented toward domestic goals like price stability or, in our case, price stability and maximum employment,
this is a very valid use of a domestic tool for a domestic purpose.
It is true that the use of that tool can have repercussions on exchanges, but I really think it is not right to call that ‘‘currency manipulation’’ and to put it in the same bucket as interventions in the
exchange markets that are really geared toward changing the competitive landscape to the advantage of a country.
Senator WARNER. Mr. Chairman, I would just in my last couple
of seconds want to make the point that one of the things that has
been absent from this discussion today has been—we have talked
a lot about your work. We have not talked as much about our work
and need to still address our own fiscal policies. I would simply
point out that because of the extraordinary remittances from the
Fed’s expanded balance sheet, we have seen north of $420 billion
in net additional revenue that has diminished our deficit. But that
is not something that can be projected on into the future. And as
we talk about the times of raising interest rates and trying to get
back to a normalized effort, I would simply point out again, you
know, a 100-basis-point increase in interest rates adds $120 billion
a year on debt service.
Ms. YELLEN. Yes.
Senator WARNER. And even CBO projections at this point will
show that debt service with our current $18 trillion in debt will exceed total defense spending or total domestic discretionary spending in 10 years, and that is not a good business plan for our country.
Ms. YELLEN. All absolutely true.
Senator WARNER. Thank you, Mr. Chairman.
Chairman SHELBY. Senator Warren.
Senator WARREN. Thank you, Mr. Chairman. Thank you for
being here, Chair Yellen.
You know, as you know, Wall Street banks could profit handsomely if they knew about the Fed’s plans before the rest of the
market found out, and that is why any leak of confidential information from the Fed results in serious penalties for the people who
are responsible.
But apparently there have been no consequences for the most recent leak. According to public reports, Scott Alvarez, the General
Counsel of the Fed, was put in charge of investigating a leak from
the September 2012 meeting of the Federal Open Market Committee. Nearly 21⁄2 years later, the results of this investigation
have not been made public, and no action has been taken.
On February 5th, Congressman Cummings and I sent a letter to
Mr. Alvarez requesting a briefing from him in advance of your appearance here today, but so far we have not received one.
Can you assure us that the Congressman and I will get a briefing soon?
Ms. YELLEN. So if I might say by way of background——

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Senator WARREN. I just need a yes or no——
Ms. YELLEN. ——the answer is——
Senator WARREN. I just want to be able to get a briefing on what
has happened that it has been 21⁄2 years and there has been no
public report about what happened from a significant——
Ms. YELLEN. We are trying to work with your staff on a process
to be responsive.
Senator WARREN. I will take that as a yes?
Ms. YELLEN. Yes.
Senator WARREN. OK. Thank you.
As you know, this past December, House Republicans successfully blew a hole in Dodd-Frank protections by tacking the repeal
of the swaps pushout rule to a must-pass Government spending
bill. That repeal, which was written by Citigroup lobbyists, will
allow the biggest banks in the country to continue to receive taxpayer protection for some of their riskiest derivatives and swaps.
Now, a month before the repeal, Mr. Alvarez spoke at a conference at the American Bar Association, an organization that includes many lawyers who represent the banks that are affected by
the Fed’s enforcement of Dodd-Frank. Mr. Alvarez openly criticized
the swaps pushout rule, saying, ‘‘You can tell it was written at 2:30
in the morning, and so it needs to be, I think, revisited just to
make sense of it.’’
Mr. Alvarez also criticized the new rules Dodd-Frank put into
place to address conflicts of interest at credit rating agencies, saying, ‘‘Restrictions on the agencies really did not work, and it does
not work, and it is more constraining than I think is helpful.’’
So let me start by asking: Does Mr. Alvarez’s criticism of these
two rules reflect your view or the view of the Federal Board of Governors?
Ms. YELLEN. So let me just say that over the years we have had
feedback that we have given on various aspects of Dodd-Frank, but
we are——
Senator WARREN. I appreciate that, Chair. The question I am
asking, though, is these are specific criticisms he has made of
Dodd-Frank rules that govern the largest financial institutions in
this country, and I am just asking: Do his criticisms reflect your
criticisms or the criticisms of the Federal Board?
Ms. YELLEN. I think we—I personally and the Board consider
Dodd-Frank to be a very important piece of legislation that has
provided a road map for us to put in place regulations——
Senator WARREN. I appreciate that, Madam Chairman, but I just
need a yes or no here. Do his criticisms reflect your criticisms?
Ms. YELLEN. I am certainly not seeking in any way to alter
Dodd-Frank at this time. It is a framework that is——
Senator WARREN. Well, then, let me ask the question differently.
Do you think it is appropriate that Mr. Alvarez took public positions that do not evidently reflect the public position of the Fed’s
Board, especially before an audience that has a direct financial interest in how the Fed enforces its rules?
Ms. YELLEN. Well, I think the Fed’s position and my position is
that we are able to work very constructively within the framework
of Dodd-Frank to tailor rules that are appropriate for the institutions we supervise, and we are not seeking to change the——

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Senator WARREN. I appreciate that. You know, we know that the
Fed staff plays a critical role in shaping Dodd-Frank rules and enforcing them. In the case of the swaps pushout, Congress passed
the law in 2010, but the Fed and the OCC delayed the effective
date of the rule until 2016, giving Citigroup and other big banks
time to get the rule repealed before it ever went into effect.
Did Mr. Alvarez provide input into the Fed’s decision to delay the
effective date of the pushout rule?
Ms. YELLEN. I do not know. I mean, we usually have phase-ins
for complicated rules that require adjustments by financial firms.
This has been true of all of the Dodd-Frank rules that we have put
into effect.
Senator WARREN. Well, I think this might be worth looking into.
You know, the Fed is our first line of defense against another financial crisis, and the Fed’s General Counsel or anyone at the Fed
staff should not be picking and choosing which rules to enforce
based on their personal views. So I urge you to carefully review
this issue and to assess whether the leadership of the Fed staff is
on the same page as the Federal Reserve Board.
Thank you, Mr. Chairman.
Chairman SHELBY. Thank you.
Senator Heitkamp.
Senator HEITKAMP. Mr. Chairman, thank you. Always last, hopefully not least.
Chair Yellen, I want to first thank you for your patience and
your responsiveness, and I was tempted to ask one question, which
was your definition of ‘‘patience.’’ But I will not do that today.
Instead, I want to look to the future. I think Senator Warner
really outlined one of the concerns that I have. We always seem to
be fighting the last economic war in the U.S. Congress. You are a
very astute and very respected student of the American economy.
It is what you do every day. I am going to give you a chance—you
have heard a lot of opinions and received a lot of advice from this
panel. I am going to give you a chance to give us some advice.
When you look at leading and lagging indicators, especially leading indicators, what troubles you and what keeps you awake at
night about the American economy in the next 10 to 15 years? And
what advice would you give to the U.S. Congress in addressing
those concerns that you have looking right now at those indicators?
Ms. YELLEN. Well, I have said on a number of occasions that the
rise we have see in inequality in the United States is a great concern to me.
Senator HEITKAMP. We discussed this the last time you were
here, and you offered no solutions toward that problem, you might
recall.
Ms. YELLEN. I think there are a variety of different things that
the Congress could consider in policy measures that might be appropriate, but this really is a domain for Congress to consider. So
that is one of the concerns that I have.
Senator HEITKAMP. So no advice on the earned income tax credit
or on tax rates or——
Ms. YELLEN. I am not going to weigh in on things that really are
in your domain to evaluate. So I think that is important, and I
would say something also in Congress’ domain is longer-run issues

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with the Federal budget. I think Congress has made painful decisions that have now really stabilized, brought down the deficit very
substantially and stabilized for a number of years the debt-to-GDP
ratio. But eventually debt-to-GDP will begin to rise and deficits
will increase again as the population ages and Medicare, Medicaid,
and Social Security get to be a larger share of GDP under current
programs. And there are a lot of ways in which—these are problems we have known about for a long time.
I also worry that if we were to again be hit by an adverse shock,
there is not much scope to use fiscal policy. It was used in the early
years after the financial crisis. We ran large deficits. But in the
course of doing that, debt-to-GDP rose, and were another negative
shock to come along, it is questionable how much scope we would
now have to put in place even on an temporary, multiyear basis expansionary fiscal policy. And I think it is important to deal with
these issues, for the Congress to do so.
Senator HEITKAMP. But your concern about scope does not lead
you to believe that interest rates should be adjusted at this point
to give you the flexibility to use interest rates should we receive
another shock?
Ms. YELLEN. Well, the Fed would, of course, use the tools that
we have to try to achieve domestic ends, but I think having fiscal
policy be available as a tool is important as well.
Senator HEITKAMP. If we look today at the American economy
and some of the challenges—and you and I have spoken privately
about this—of the millennials and saving patterns and consumptive patterns, the shared economy, what concerns you about the
now 8 years of changed behavior in consumption? What concerns
you about those issues? And do you see those changing long-term
consumptive patterns that may present some interesting challenges
for the American economy?
Ms. YELLEN. Well, I think we are just beginning to understand
how the millennials are behaving. They are certainly waiting
longer to buy houses, to get married. They have a lot of student
debt. They seem, you know, quite worried about housing as an investment. They have had a tough time in the job market. And, as
the economy strengthens, I expect more of them to form households
of their own and buy homes. But we have yet to really see how this
is going to affect that generation.
Senator HEITKAMP. Or they may have experienced a change in
consumptive patterns that will present some unique challenges,
whether it is sharing automobiles, whether it is, in fact, not buying
homes, doing the things that they have now done to accommodate
their economic challenges in the long term. And I think that one
of the things that we need to do much more carefully here in the
U.S. Congress is begin to look at not just having a discussion with
you about monetary policy, but looking at fiscal policy, whether it
is tax reform or whether it is, in fact, taking a look at what we are
doing with the mortgage market, to begin to develop an economy
that the millennials will fully participate in. And I hope you continue to think and provide us the advice that is extraordinarily valuable.
Thank you.
Ms. YELLEN. Thank you.

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Chairman SHELBY. Senator Donnelly.
Senator DONNELLY. Thank you, Mr. Chairman. And, Madam
Chair, thanks for your service. And I apologize. I have had to go
in and out of some other committees, and I know this subject has
been brought up, but the issue of wage stagnation that we have
seen and the other piece of student debt.
When we look at the student debt and the numbers are so high
and, you know, it has been a long time, but when I graduated from
college, you could basically work an entire summer and wind up
paying off about half what your tuition was.
How big a drag—and you may not have an exact measurement,
but one of my great concerns has been in some areas of the country, how do you buildup the housing market when the young people
who want to buy a house—the money that I saved up for, at that
time, that 20-percent downpayment is now in many cases being
used to pay off a student loan, and it is a box you almost can never
get out of. So how big a drag do you see that being on the economy?
Ms. YELLEN. So it is a little bit hard to tell. I mean, the housing
market has not recovered in the way that I would have anticipated.
It has been very slowly improving, but household formation has
been extremely low in the United States. It is hard to tell. You
have many young people who are living with their families still. It
is hard to tell whether that is because of student debt or because
of a weak job market.
My guess is that as the economy continues to improve, we will
see an improvement in household formation, that we will see—now,
many young people may decide that they prefer to rent rather than
buy homes. But that will give rise to a boost to multifamily construction, even if not so much to single-family construction. But the
housing market has been very depressed. Nevertheless, in spite of
that, the economy as a whole and the job market has had sufficient
strength to recover.
Senator DONNELLY. My other concern in that area is when you
see a young person who looks up and is dealing with $100,000 in
student debt and they have this big chunk of money that goes off
every month to pay that down, those dollars are dollars that are
never used to go to a restaurant, never used to maybe buy a car,
never used to travel somewhere. And so overall job-wise I think it
hits or seems to hit—makes it more difficult in all those areas to
continue job creation.
Ms. YELLEN. It is true, but it also remains true that a higher
education boosts income and is tremendously important. It is not
always the case, not for every individual, that it is a good investment, but certainly on average, it has been a very important and
worthwhile investment. So I think to my mind that is the other
side of it.
Senator DONNELLY. I completely agree what a wonderful investment it is. I just want to try to make sure that we can get that
wonderful opportunity without basically saddling yourself for years
and years as you look ahead.
Ms. YELLEN. The debt loads are very large and have really increased a great deal. You are——
Senator DONNELLY. One other area I wanted to ask you about is
cybersecurity, and I know that the Fed has certain things they

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focus on on a constant basis. In the area of cybersecurity, though,
it is, from all the financial organizations I talk to, one of the biggest concerns they have, for the companies it is. How big a risk do
you see that in the years moving forward? And how big an effect
on the financial institutions do you see this being?
Ms. YELLEN. Well, I think it is at the top of the list of concerns
that we have about the financial system, about the problems facing
financial organizations, and I would include the Federal Reserve in
that, too. It is a top concern of our own given the importance of our
own systems to the payment—the functioning of the payment system of the U.S. and global economy.
Internally, we are paying a great deal of attention to make sure
that we are addressing ever escalating threats to our own operations. The banks that we supervise, we are very attentive and
have experts who work with those banks to make sure that they
are attentive. It is a larger problem, and this is one where cooperation is needed among card systems, retailers, and others involved
in the financial system, and conceivably, legislation might be needed in this area.
Senator DONNELLY. Thank you, and I will conclude with this: For
the State I represent, Indiana, we for many years were hit very,
very hard in the manufacturing sector because of currency manipulation, among many other areas. And I know this has been mentioned, but I would like to make sure that you keep a close eye on
this, because when we talk about manufacturing, the ability to be
competitive—and all that was ever said to me by our manufacturers was, ‘‘If it is a fair field, we will do fine. But if the game is
rigged, I do not know how we win that kind of game.’’
And I have always, you know, had the same feeling—and my
Ranking Member, Sherrod Brown, right next to me in Ohio, has
dealt with this a lot with his manufacturers as well—that if currencies are fairly valued and we are not successful, our manufacturers, they have always said to me, ‘‘If I cannot win a fair game,
that is on me. But if I wind up in a situation where it is being manipulated against my company, it makes it awful tough to keep
those workers working and to keep our economy growing.’’
So I would just ask that you keep that in mind as you move forward, and thank you so much for your service.
Ms. YELLEN. Thank you.
Chairman SHELBY. Madam Chair, you mentioned that the current unemployment is listed at 5.7 percent. However, one alternative measure that seems to fully capture a better sense of labor
force participation is the U6 measure that lists total unemployed
and underemployed at 11.3 percent as of January 2015. This measure has not dipped below 10-percent unemployment since before
the crisis. According to the Bureau of Labor Statistics data, there
are now 12 million more Americans no longer participating in the
workforce than in January 2009.
Do you agree that the unemployment number that you cited, 5.7
percent, in your opening statement paints a rosy or a better picture
of the true unemployment rate that I just cited?
Ms. YELLEN. So, Senator, the U6 is a broader measure of unemployment. It includes marginally attached and discouraged workers
and also an unusually large number of individuals who are work-

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ing part-time who would like full-time jobs. So it is a much broader
indicator of underemployment or unemployment in the U.S. economy, and while it has come down—it was 12.1 percent a year ago.
It has come down from there to 11.3 percent. It definitely shows
a less rosy picture than U3 or the 5.7-percent number. And I did
mention that we do not at this point, in spite of the fact the unemployment rate has come down, feel that we have achieved so-called
maximum employment, in part for these very reasons. Labor force
participation has come down, has been trending down. That is
something that will continue for demographic reasons. I do not expect it to move up over time, but I do think a portion of the depressed labor force participation does reflect cyclical weakness in
that in a stronger job market more people would enter.
Chairman SHELBY. But you basically concede that 11.3 percent
of underemployed people, that is not good in this country, is it?
Ms. YELLEN. That is an abnormally high level, and it signifies
weakness that would be good to address.
Chairman SHELBY. The Financial Stability Board, FSB, plays an
important role, as you well know, in implementing financial reforms, including completion of a capital framework that you alluded to for banks. The Federal Reserve is a member of this FSB,
the Financial Stability Board. Given that the Financial Stability
Board is not accountable to Congress or to any branch of the U.S.
Government, to my knowledge, where do these Financial Stability
Board reforms fit in the U.S. regulatory system? My question is:
Does the Federal Reserve treat them as mandated directives or
suggestions or what? And what statutory basis does the Fed have
to implement the Financial Stability Board’s reforms verbatim? Do
you think further that the FSB decisions are important enough
that they should be fully vetted by the FSOC before implemented
in the U.S.?
Ms. YELLEN. Well, a number of——
Chairman SHELBY. That is two or three questions, but they are
all tied together.
Ms. YELLEN. So a number of U.S. regulatory agencies participate
in the FSB, including the administration and other regulators.
Chairman SHELBY. Sure.
Ms. YELLEN. Nothing that is decided in the FSB has effect in the
United States unless the relevant agencies propose rules and those
are publicly vetted through the normal public comment process and
our rulemaking process. So those recommendations have no force
in the United States unless we go through a rulemaking process.
But there is a good reason for us to participate in these international fora. Financial markets are global. If we take actions to
stiffen supervision and regulation in the United States, and other
major financial centers do not act in similar ways, we will just see
activity move out of our borders to other parts of the world, and
I do not think that will make for a safer global financial system.
So we do want to be part of international discussions that lead
all countries to work harmoniously together to try to raise standards and maintain a level playing field, and that explains why we
participate. And we can play and I think we do play a leadership
role in this organization——

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Chairman SHELBY. But you do not need to accept that their recommendations are verbatim, do you?
Ms. YELLEN. No, we do not, and often we have put in place
tougher standards than came out of those fora.
Chairman SHELBY. Thank you.
The Wall Street Journal recently reported that the Federal Reserve surcharge for the largest banks is hurting U.S. banks because it is not on par with what foreign regulators are applying to
foreign banks. The article also indicated that the Fed’s proposal is
going beyond an international standard, roughly doubling the surcharge for big U.S. banks.
We all want our banks well capitalized. I think that is very important. But does the Fed’s proposal indicate its belief that foreign
banks are not adequately capitalized? That has been said before,
you know, that when they have stress tests, they are in deep
stress, as we well know, probably a lot more than our banks are.
Ms. YELLEN. Well, our proposal embodies our own analysis of the
costs to our economy and our financial system of possible distress
at the largest and most systemic organizations. We chose to propose surcharges, capital surcharges, that rose above the level that
were agreed internationally because we think this will make our financial system safer.
There are other jurisdictions that have similarly put in effect a
super equivalent regime. Switzerland is an example of that, and
there are other countries that have gone a similar route. The proposal is out for comment, and we look forward to seeing what others say. But we do think it is important for the most systemic institutions whose distress could lead to significant financial impact on
the United States, we do think it is important for them to hold appropriate capital, and especially when in times of stress it is a competitive advantage and not a disadvantage for those firms.
Chairman SHELBY. Madam Chair, some of the large foreign
banks that do business in the U.S., do you hold them to the same
capital standards that you do our banks? And if not, why not?
Ms. YELLEN. Well, we have just put in place a rule pertaining to
foreign banking organizations that would ask them, if they are sufficiently large, require them to form intermediate holding companies that would contain their activities in the United States. And
that is a way to subject them to the same capital and liquidity
standards as U.S. firms doing business in our markets.
Chairman SHELBY. But shouldn’t the standard—in other words,
the foreign banks, as I understand what you are saying, they
should not have an advantage with lower capital standards than
our banks when they are doing business in this country.
Ms. YELLEN. Well, to the extent that they are doing business in
this country, we are going to subject them to the same standards
as our banking organizations.
Chairman SHELBY. Thank you.
Senator Brown.
Senator BROWN. Thank you, Mr. Chairman. Just a comment,
then a couple of questions, and this side will wrap up.
I understand, Madam Chair, your reluctance to weigh in on specific policy issues that are the province of the Congress, such as the
earned income tax credit. I appreciate your bringing attention to

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those issues by which taxpayers/workers will benefit from the
EITC.
Trade, of course, is another one of those matters, and your predecessor had labeled currency manipulation ‘‘an effective subsidy,’’
his words. Ohio manufacturers, similar to Indiana manufacturers
that Senator Donnelly mentioned, must compete against foreign
competitors who are subsidized. I agree with your statement that
this needs to be addressed.
Two questions—first, about living wills. The FDIC last summer
seemed positioned to declare the living wills of some of the Nation’s
largest banks not sufficient. Instead, though, the FDIC stepped
back, and together you and the FDIC asked for resubmissions in
July. Two questions, a couple questions. A two-part question: Are
you prepared to declare living wills submitted during this next
round of submissions not credible if, in fact, they are not? And
what actions will you take if the living wills are actually deemed
insufficient?
Ms. YELLEN. So we have worked, as you mentioned, closely with
the FDIC to give guidance to the largest firms on what we want
to see, what changes we want to see in their living wills in order
to improve their resolvability. There are significant changes that
we have asked for. Some pertain to their legal structure: the ability
of critical operations that support an entire organization to remain
available to the firm in a situation of distress, to simplify and make
sure that they have a holding company structure that would be
functional, to promote an orderly bankruptcy.
We agreed with the FDIC on what we want to see. We are working with the firms to make sure they understand what we expect.
We expect to see resubmissions of these plans by July of 2015, July
of this year, and we have not——
Senator BROWN. Let me interrupt there. Are you willing to—are
you unwilling to accept any of these banks saying that ‘‘you have
not given us enough information on what to do to comply by July’’?
Are you unwilling—will you say, ‘‘We will not accept that answer’’?
Ms. YELLEN. I feel we have given detailed feedback and adequate
information, and if we do not see the progress we expect, we are
fully prepared to declare the living wills to be not credible.
Senator BROWN. OK. That is good to hear. One last question, Mr.
Chairman.
Earlier this month, the major story broke about a trove of HSBC
account holder data that reveals that their Swiss banking arm collaborated in efforts by some of its account holders to engage in tax
evasion. On February 10th, I asked Ms. Hunter what steps her
agency, the Fed, your agency, had taken with regard to these allegations. I gather that investigations of some individual U.S. account holders have been undertaken by IRS. Last week, Geneva
prosecutors raided the private bank offices of HSBC as part of a
new money-laundering investigation. We know HSBC has a history
of major U.S. sanctions, major money-laundering violations. They
now face major new charges of facilitating tax evasion.
I know you may be unable to address details of an ongoing investigation, but summarize for this Committee, if you would, Madam
Chair, what the Fed would normally do to pursue allegations like
these regarding tax evasions by a major financial institution, how

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long you would expect an investigation to take—again, not specifically here if you are unwilling or unable to share that, but how you
would normally do it, how long it takes, what steps you normally
take with other Federal officials, with other countries’ regulators?
Ms. YELLEN. Well, we would have some responsibility for this if
it affected the operations of a bank in the United States. In this
case, the information has been provided to the Justice Department.
The Justice Department has primary enforcement responsibilities
related to U.S. tax laws along with the IRS. And the Justice Department normally cooperates with us and provides information to
us if they think that we would have jurisdiction if banking laws
have been violated in the United States and that we should take
action. In this case, the Justice Department has not provided us
with information.
Senator BROWN. Do you ask them, or must they make the first
move?
Ms. YELLEN. Well, we have not been privy to any of this information, and if they thought it appropriate, we would expect them to
reach out to us.
Senator BROWN. Don’t news reports suggest that there is no
harm but perhaps reason for you to ask the Justice Department for
some of this, any of this information that they might think important to this country’s financial system and to these banks and to
you?
Ms. YELLEN. Well, this is pretty recent news reports that we
have learned about this.
Senator BROWN. OK.
Chairman SHELBY. Madam Chair, thank you for appearing again
before the Committee. We look forward to further appearances, and
this will conclude the hearing. Thank you.
The Committee is adjourned.
[Whereupon, at 12:17 p.m., the hearing was adjourned.]
[Prepared statements, responses to written questions, and additional material supplied for the record follow:]

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PREPARED STATEMENT OF JANET L. YELLEN
CHAIR, BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
FEBRUARY 24, 2015
Chairman Shelby, Ranking Member Brown, and Members of the Committee, I am
pleased to present the Federal Reserve’s semiannual Monetary Policy Report to the
Congress. In my remarks today, I will discuss the current economic situation and
outlook before turning to monetary policy.
Current Economic Situation and Outlook
Since my appearance before this Committee last July, the employment situation
in the United States has been improving along many dimensions. The unemployment rate now stands at 5.7 percent, down from just over 6 percent last summer
and from 10 percent at its peak in late 2009. The average pace of monthly job gains
picked up from about 240,000 per month during the first half of last year to 280,000
per month during the second half, and employment rose 260,000 in January. In addition, long-term unemployment has declined substantially, fewer workers are reporting that they can find only part-time work when they would prefer full-time employment, and the pace of quits—often regarded as a barometer of worker confidence in labor market opportunities—has recovered nearly to its prerecession level.
However, the labor force participation rate is lower than most estimates of its trend,
and wage growth remains sluggish, suggesting that some cyclical weakness persists.
In short, considerable progress has been achieved in the recovery of the labor market, though room for further improvement remains.
At the same time that the labor market situation has improved, domestic spending and production have been increasing at a solid rate. Real gross domestic product
(GDP) is now estimated to have increased at a 33⁄4-percent annual rate during the
second half of last year. While GDP growth is not anticipated to be sustained at
that pace, it is expected to be strong enough to result in a further gradual decline
in the unemployment rate. Consumer spending has been lifted by the improvement
in the labor market as well as by the increase in household purchasing power resulting from the sharp drop in oil prices. However, housing construction continues
to lag; activity remains well below levels we judge could be supported in the longer
run by population growth and the likely rate of household formation.
Despite the overall improvement in the U.S. economy and the U.S. economic outlook, longer-term interest rates in the United States and other advanced economies
have moved down significantly since the middle of last year; the declines have reflected, at least in part, disappointing foreign growth and changes in monetary policy abroad. Another notable development has been the plunge in oil prices. The bulk
of this decline appears to reflect increased global supply rather than weaker global
demand. While the drop in oil prices will have negative effects on energy producers
and will probably result in job losses in this sector, causing hardship for affected
workers and their families, it will likely be a significant overall plus, on net, for our
economy. Primarily, that boost will arise from U.S. households having the wherewithal to increase their spending on other goods and services as they spend less on
gasoline.
Foreign economic developments, however, could pose risks to the outlook for U.S.
economic growth. Although the pace of growth abroad appears to have stepped up
slightly in the second half of last year, foreign economies are confronting a number
of challenges that could restrain economic activity. In China, economic growth could
slow more than anticipated as policymakers address financial vulnerabilities and
manage the desired transition to less reliance on exports and investment as sources
of growth. In the euro area, recovery remains slow, and inflation has fallen to very
low levels; although highly accommodative monetary policy should help boost economic growth and inflation there, downside risks to economic activity in the region
remain. The uncertainty surrounding the foreign outlook, however, does not exclusively reflect downside risks. We could see economic activity respond to the policy
stimulus now being provided by foreign central banks more strongly than we currently anticipate, and the recent decline in world oil prices could boost overall global
economic growth more than we expect.
U.S. inflation continues to run below the Committee’s 2-percent objective. In large
part, the recent softness in the all-items measure of inflation for personal consumption expenditures (PCE) reflects the drop in oil prices. Indeed, the PCE price index
edged down during the fourth quarter of last year and looks to be on track to register a more significant decline this quarter because of falling consumer energy
prices. But core PCE inflation has also slowed since last summer, in part reflecting
declines in the prices of many imported items and perhaps also some pass-through
of lower energy costs into core consumer prices.

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Despite the very low recent readings on actual inflation, inflation expectations as
measured in a range of surveys of households and professional forecasters have thus
far remained stable. However, inflation compensation, as calculated from the yields
of real and nominal Treasury securities, has declined. As best we can tell, the fall
in inflation compensation mainly reflects factors other than a reduction in longerterm inflation expectations. The Committee expects inflation to decline further in
the near term before rising gradually toward 2 percent over the medium term as
the labor market improves further and the transitory effects of lower energy prices
and other factors dissipate, but we will continue to monitor inflation developments
closely.
Monetary Policy
I will now turn to monetary policy. The Federal Open Market Committee (FOMC)
is committed to policies that promote maximum employment and price stability, consistent with our mandate from the Congress. As my description of economic developments indicated, our economy has made important progress toward the objective of
maximum employment, reflecting in part support from the highly accommodative
stance of monetary policy in recent years. In light of the cumulative progress toward
maximum employment and the substantial improvement in the outlook for labor
market conditions—the stated objective of the Committee’s recent asset purchase
program—the FOMC concluded that program at the end of October.
Even so, the Committee judges that a high degree of policy accommodation remains appropriate to foster further improvement in labor market conditions and to
promote a return of inflation toward 2 percent over the medium term. Accordingly,
the FOMC has continued to maintain the target range for the Federal funds rate
at 0 to 1⁄4 percent and to keep the Federal Reserve’s holdings of longer-term securities at their current elevated level to help maintain accommodative financial conditions. The FOMC is also providing forward guidance that offers information about
our policy outlook and expectations for the future path of the Federal funds rate.
In that regard, the Committee judged, in December and January, that it can be patient in beginning to raise the Federal funds rate. This judgment reflects the fact
that inflation continues to run well below the Committee’s 2-percent objective, and
that room for sustainable improvements in labor market conditions still remains.
The FOMC’s assessment that it can be patient in beginning to normalize policy
means that the Committee considers it unlikely that economic conditions will warrant an increase in the target range for the Federal funds rate for at least the next
couple of FOMC meetings. If economic conditions continue to improve, as the Committee anticipates, the Committee will at some point begin considering an increase
in the target range for the Federal funds rate on a meeting-by-meeting basis. Before
then, the Committee will change its forward guidance. However, it is important to
emphasize that a modification of the forward guidance should not be read as indicating that the Committee will necessarily increase the target range in a couple of
meetings. Instead the modification should be understood as reflecting the Committee’s judgment that conditions have improved to the point where it will soon be the
case that a change in the target range could be warranted at any meeting. Provided
that labor market conditions continue to improve and further improvement is expected, the Committee anticipates that it will be appropriate to raise the target
range for the Federal funds rate when, on the basis of incoming data, the Committee is reasonably confident that inflation will move back over the medium term
toward our 2-percent objective.
It continues to be the FOMC’s assessment that even after employment and inflation are near levels consistent with our dual mandate, economic conditions may, for
some time, warrant keeping the Federal funds rate below levels the Committee
views as normal in the longer run. It is possible, for example, that it may be necessary for the Federal funds rate to run temporarily below its normal longer-run
level because the residual effects of the financial crisis may continue to weigh on
economic activity. As such factors continue to dissipate, we would expect the Federal
funds rate to move toward its longer-run normal level. In response to unforeseen
developments, the Committee will adjust the target range for the Federal funds rate
to best promote the achievement of maximum employment and 2-percent inflation.
Policy Normalization
Let me now turn to the mechanics of how we intend to normalize the stance and
conduct of monetary policy when a decision is eventually made to raise the target
range for the Federal funds rate. Last September, the FOMC issued its statement
on Policy Normalization Principles and Plans. This statement provides information
about the Committee’s likely approach to raising short-term interest rates and reducing the Federal Reserve’s securities holdings. As is always the case in setting

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policy, the Committee will determine the timing and pace of policy normalization
so as to promote its statutory mandate to foster maximum employment and price
stability.
The FOMC intends to adjust the stance of monetary policy during normalization
primarily by changing its target range for the Federal funds rate and not by actively
managing the Federal Reserve’s balance sheet. The Committee is confident that it
has the tools it needs to raise short-term interest rates when it becomes appropriate
to do so and to maintain reasonable control of the level of short-term interest rates
as policy continues to firm thereafter, even though the level of reserves held by depository institutions is likely to diminish only gradually. The primary means of raising the Federal funds rate will be to increase the rate of interest paid on excess
reserves. The Committee also will use an overnight reverse repurchase agreement
facility and other supplementary tools as needed to help control the Federal funds
rate. As economic and financial conditions evolve, the Committee will phase out
these supplementary tools when they are no longer needed.
The Committee intends to reduce its securities holdings in a gradual and predictable manner primarily by ceasing to reinvest repayments of principal from securities held by the Federal Reserve. It is the Committee’s intention to hold, in the
longer run, no more securities than necessary for the efficient and effective implementation of monetary policy, and that these securities be primarily Treasury securities.
Summary
In sum, since the July 2014 Monetary Policy Report, there has been important
progress toward the FOMC’s objective of maximum employment. However, despite
this improvement, too many Americans remain unemployed or underemployed, wage
growth is still sluggish, and inflation remains well below our longer-run objective.
As always, the Federal Reserve remains committed to employing its tools to best
promote the attainment of its objectives of maximum employment and price stability.
Thank you. I would be pleased to take your questions.

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RESPONSES TO WRITTEN QUESTIONS OF CHAIRMAN SHELBY
FROM JANET L. YELLEN

Q.1. The Financial Stability Board (FSB), of which the Federal Reserve is a member, recently issued a proposal for a new long-term
debt requirement for large financial institutions. The Federal Reserve is expected to base its own long-term debt rule on the FSB’s
proposal. However, the FSB is now conducting a quantitative impact study to assess costs and effects of its proposal. Because the
comment period on the FSB proposal has already closed, the public
will not be able to comment on the results of the FSB study. Do
you think it is important for the public to be able to comment on
the FSB study? Will the Fed do its own quantitative impact study
before implementing the FSB rule? If not, why not and is it appropriate to base a rule for U.S. banks on a study conducted by an
international regulatory body?
A.1. Since the financial crisis, U.S. authorities and foreign regulators have been working to identify and mitigate the obstacles to
an orderly resolution or wind-down of a global systemically important bank (GSIB). To achieve this objective, a failed GSIB in resolution must have a sufficient amount of loss-absorbing resources so
that shareholders and creditors—instead of taxpayers—will bear
the costs of its failure. Accordingly, in November 2014, the FSB
published for consultation a proposal for a common international
standard on the total loss-absorbing capacity for GSIBs (TLAC proposal). The comment period for the FSB’s TLAC proposal closed in
February 2015; the FSB received comments from a range of commenters, including U.S. trade associations and public policy advocates. In connection with the TLAC proposal, the FSB is currently
coordinating a comprehensive quantitative impact study to which
the Federal Reserve and other U.S. authorities are contributing
participants.
Independently, the Federal Reserve has been developing a proposal that would require the largest, most complex U.S. banking
firms to keep outstanding minimum amounts of long-term, unsecured debt at the holding company level (U.S. long-term debt proposal). In proposing and adopting rules on long-term debt requirements for U.S. banking firms, the Federal Reserve will seek public
comment and comply fully with the Administrative Procedures Act
and other applicable Federal law. To the extent that the FSB quantitative impact study provides information that is relevant to the
U.S. long-term debt proposal, the Federal Reserve will take that information into account in preparing the materials that it publishes
for public comment. As part of the rulemaking process, the Federal
Reserve would consider all public comments as well as the public
benefits and burdens associated with the proposed regulation.
Q.2. During a hearing last June in connection with the Financial
Stability Oversight Council’s (FSOC) Annual Report to Congress,
Treasury Secretary Jack Lew responded to a question regarding
the designation process for SIFI and G-SIFI institutions and the
closely correlative timing by saying that, ‘‘ . . . the FSB does not
make decisions for national authorities.’’ Both the Secretary of the
Treasury and the Chair of the Federal Reserve are members of
both FSOC and FSB. There have been instances of FSB desig-

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nating certain U.S. companies as systemically important before the
FSOC did so, and other instances where the FSB proposed rules
that U.S. regulators then promulgated domestically. Do you believe
it is appropriate for a Federal Reserve governor to vote on an FSB
proposal or determination before the FSOC votes on the same
issue? What specific processes and safeguards are in place that prevent FSB rules and decisions from being implemented in the U.S.
through FSOC as a matter of formality and without due regard to
the regulatory process and our existing regulatory framework?
A.2. The FSOC’s process for designating nonbank firms as systemically important assesses the potential harm that a firm’s distress
or failure would cause to the economy of the United States. The
methodology underlying this assessment process, including the
quantitative metrics used to rule out smaller, less complex firms,
has been made public. 1 In addition, for the firms it ultimately
votes to designate, the FSOC publishes a description of the basis
for its finding. No part of this process is linked, mechanically or
otherwise, with the deliberations or findings of agencies outside the
United States, including the FSB.
The leaders of the Group of 20 Nations, including the United
States, charged the FSB with, in part, identifying firms whose distress would threaten the global economy. The fact that both groups
have examined the same firms, at times in close proximity, is to
be expected given the limited number of firms which would reasonably be large enough to be considered systemically important. However, the specific designation frameworks and standards at the
FSB and FSOC are materially different.
As an example, the FSB’s process for identifying global systemically important insurers (G-SIIs) is completely independent of the
FSOC’s designation process. A designation by the FSB that an insurer is systemically important would not logically require a similar finding by the FSOC, even if the FSB and the FSOC agreed on
the underlying facts.
The methodology for identifying global systemically important insurers (G-SIIs) was developed by the International Association of
Insurance Supervisors (IAIS). The IAIS’ assessment methodology
uses five categories to measure relative systemic importance: (1)
nontraditional insurance and non-insurance (NTNI) activities, (2)
interconnectedness, (3) substitutability, (4) size, and (5) global activity. Within these five categories, there are 20 indicators, including: intra financial assets and liabilities, gross notional amount of
derivatives, Level 3 assets, non-policyholder liabilities and non-insurance revenues, derivatives trading, short term funding, and
variable insurance products with minimum guarantees.
The FSOC considers a threat to the financial stability of the
United States to exist if a nonbank financial company’s material financial distress or activities could be transmitted to, or otherwise
affect, other firms or markets, thereby causing a broader impairment of financial intermediation or of financial market functioning.
An impairment of financial intermediation and financial market
functioning can occur through several channels, including through:
1 http://www.treasury.gov/initiatives/fsoc/rulemaking/Documents/Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies.pdf

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(1) exposure of other financial market participants to the firm; (2)
liquidation of its assets; or (3) failure of the firm to perform a critical service or function that is relied upon by other market participants. The FSOC’s analysis is based on a broad range of quantitative and qualitative information available to the FSOC through
existing public and regulatory sources and as submitted to FSOC
by the firm under consideration. The analysis is tailored, as appropriate, to address company-specific risk factors, including but not
limited to, the nature, scope, size, scale, concentration, interconnectedness, and mix of the activities of the firm.
Any standards adopted by the FSB, including designation of an
entity as a global systemically important financial institution (GSIFI), are not binding on the Federal Reserve, the FSOC, or any
other agency of the U.S. government, or any U.S. companies. Thus,
FSB designation of an entity as a nonbank SIFI does not automatically result in the Federal Reserve Board becoming the entity’s
prudential regulator. Under the Dodd-Frank Wall Street Reform
and Consumer Protection Act (Dodd-Frank Act), the FSOC is responsible for deciding whether a nonbank financial company should
be regulated and supervised by the Federal Reserve Board, based
on its assessment of the extent to which the failure, material distress, or ongoing activities of that entity could pose a risk to the
U.S. financial system.
Q.3. Governor Tarullo, the Federal Reserve’s representative to the
FSB, stated that the Fed will be promulgating a rule to implement
domestically the FSB’s proposal on minimum margin requirements
for certain forms of securities financing deals. As the FSB has been
criticized for lack of transparency and accountability by U.S. officials and regulators, it is troubling that the Fed’s FSB representative would indicate the rule’s quick adoption in the United States.
Is the Federal Reserve going to undertake an analysis independent
from the FSB before promulgating a similar rule domestically?
Since securities financing regulation has traditionally been within
the purview of the Securities and Exchange Commission (SEC), not
the Federal Reserve, how does the Federal Reserve intend to proceed with this rule and is the SEC going to be involved in that
process? If not, why not? What expertise and knowledge does the
Federal Reserve possess in this area?
A.3. The Federal Reserve would adopt minimum margin requirements for securities financing transactions only following a noticeand-comment rulemaking process supported by an independent assessment of the merits of such an approach. During that rulemaking process, the Federal Reserve would consult with the SEC,
as well as other stakeholders and experts. The Federal Reserve
would also draw on its extensive knowledge of securities financing
markets.
This knowledge derives from multiple sources, including the Federal Reserve’s supervision of financial institutions that are the
dominant intermediaries in these markets, as well as the Federal
Reserve’ s direct experience in securities financing markets related
to the conduct of monetary policy.
The FSB framework of minimum margin requirements has been
developed through a multiyear process led by a working group that

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includes representatives of the Federal Reserve and the SEC.
There have been multiple opportunities for public input into the
FSB process:
• In April 2012, the FSB published an interim report provided
an overview of the securities lending and repo markets, and
identified financial stability issues in these markets.
• In August 2013, the FSB published a policy framework for addressing shadow banking risks in securities lending and repos,
which included for public consultation the proposed regulatory
framework of minimum margin requirements.
• In October 2014, the FSB finalized minimum margin requirements for transactions involving bank lenders and nonbank
borrowers, and simultaneously proposed for public consultation
the extension of the framework of minimum margin requirements to transactions involving two nonbank entities.
• In addition, the FSB conducted a multistage quantitative impact study to help gauge the impact of minimum margin requirements on market conditions.
Q.4. The Federal Reserve is a participant in negotiations within
the International Association of Insurance Supervisors, which is
currently developing a global capital standard for international insurance companies. How will these global capital standards for insurers impact the development of insurance capital standards here
in the United States?
A.4. The Federal Reserve participates as a member to the IAIS
along with our fellow U.S. members from the Federal Insurance Office and National Association of Insurance Commissioners. Along
with these organizations, we advocate for the development of international standards that best meet the needs of the U.S. insurance
market and U.S. consumers. The standards under development by
the IAIS would only apply in the United States if adopted by the
appropriate U.S. regulators in accordance with applicable domestic
rulemaking procedures. Additionally, none of the standards are intended to replace the existing legal entity risk-based capital requirements that are already in place.
The Federal Reserve continues to focus on constructing a domestic regulatory capital framework for our supervised insurance holding companies that is well tailored to the business of insurance.
The timeline for the development of our rulemaking is distinct from
the activities of the IAIS. We are exercising great care as we approach this challenging mandate. We are committed to following a
transparent rulemaking processes to develop our insurance capital
framework, which will allow for an open public comment period on
a concrete proposal. We will continue to engage with interested
parties as we move forward.
Q.5. Over the last few years, the Federal Reserve has issued a series of new rules on capital and liquidity requirements for banks.
Although these rules are important to ensure that the banking system is adequately capitalized, the must also strike the right balance to promote safety and soundness without eroding economic
growth and job creation. Has the Federal Reserve conducted any
cost-benefit analysis of the cumulative impact of its capital and li-

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quidity rules on future economic growth and job creation? If yes,
please share with this Committee the results of that study. If no,
are you willing to conduct a cost-benefit analysis before finalizing
the rules?
A.5. As required by the Dodd-Frank Act, the Federal Reserve has
adopted new risk-based capital and liquidity requirements through
the rulemaking process to strengthen and enhance the safety and
soundness of banking organizations and the U.S. banking system.
To become informed about the benefits and burdens of any capital and liquidity requirements, the Federal Reserve collected information directly from parties that we expect will be affected by the
rulemaking through surveys and meetings. The Federal Reserve
also participated in several international studies assessing the potential impact of changes to the regulatory capital and liquidity requirements, which found that stronger capital and liquidity requirements could help reduce the likelihood of banking crises while
yielding positive net economic benefits. 2 In the rulemaking process,
the Federal Reserve specifically sought comment from the public on
the burdens and benefits of the proposed approaches and on a variety of alternative approaches to the proposal. The Federal Reserve
carefully considered public comments received on every notice of
proposed rulemaking, including information relevant to the impact
of rulemakings provided by commenters. In adopting final rules on
these topics, the Federal Reserve sought to adopt a regulatory alternative that faithfully reflected the statutory provisions and the
intent of Congress, while minimizing regulatory burden. We also
provided an analysis of the costs on small depository organizations
of our rulemaking consistent with the Regulatory Flexibility Act
and computed the anticipated cost of paperwork consistent with the
Paperwork Reduction Act. The Federal Reserve performs an impact
analysis with respect to each final rule pursuant to the Congressional Review Act. 3
As part of the adoption of Regulation Q, the Federal banking
agencies performed an analysis that showed that the vast majority
of U.S. banking organizations, including community banks, would
have already met the revised capital requirements plus the capital
conservation buffer on a fully phased-in basis, which suggests that
any negative impact stemming from the revised capital rule on
credit availability should be small.
2 Those studies included the Macroeconomic Assessment Group (MAG), a joint group of the
Basel Committee on Banking Supervision (BCBS) and Financial Stability Board, (ii) the longterm economic impact working group of the BCBS, and (iii) the BCBS Quantitative Impact
Study. See MAG, ‘‘Assessing the Macroeconomic Impact of the Transition to Stronger Capital
and Liquidity Requirements’’ (MAG Analysis), available at: http://www.bis.org/publ/othpl2.pdf.
See also BCBS ‘‘An Assessment of the Long-Term Economic Impact of Stronger Capital and Liquidity Requirements’’ (LEI Analysis), also available at: http://www.bis.org/publ/bcbs173.pdf.
See also ‘‘Results of the Comprehensive Quantitative Impact Study’’, also available at: http://
www.bis.org/publ/bcbs186.pdf.
3 Before issuing any final rule, the Federal Reserve prepares an analysis under the CRA and
provides the analysis to the Office and Management and Budget for its review. As part of this
analysis, the Federal Reserve assesses whether the final rule is a ‘‘major rule,’’ meaning the rule
could (i) have an annual effect on the economy of $100 million or more; (ii) increase or process
for consumers, individual industries, Federal, States, or local government agencies, or geographic regions; or (iii) have significant adverse effects on competition, employment, investment,
productivity, or innovation.

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

Q.1. Will the Federal Reserve follow a formal rulemaking process
for insurance capital standards and not use an expedited process
like imposing the standards by order?
A.1. The Federal Reserve is committed a transparent rulemaking
processes to develop our insurance capital framework. This will
allow for an open public comment period on a concrete proposal.
Q.2. Recognizing that there are two standard development tracks
running at the same time—development of a domestic capital
standard at the Federal Reserve, and development of an international capital standard at the IAIS—could you explain how the
Federal Reserve is coordinating these efforts?
A.2. The Federal Reserve participates as a member to the International Association of Insurance Supervisors (IAIS) along with our
fellow U.S. members from the Federal Insurance Office and National Association of Insurance Commissioners. Along with these
organizations, we advocate for the development of international
standards that best meet the needs of the United States insurance
market. The standards under development by the IAIS would only
apply in the United States if adopted by the appropriate U.S. regulators in accordance with applicable domestic rulemaking procedures. Additionally, none of the standards are intended to replace
the existing legal entity risk-based capital requirements that are
already in place.
The Federal Reserve continues to focus on constructing a domestic regulatory capital framework for our supervised insurance holding companies that is well tailored to the business of insurance. We
are committed to a transparent rulemaking process and are engaging stakeholders at various levels. The timeline for the development of our rulemaking is distinct from the activities of the IAIS.
We are exercising great care as we approach this challenging mandate. We will continue to engage with interested parties as we
move forward.
Q.3. The Basel Advanced Approaches regulation provides an avenue for companies to request a waiver from the rule. In effect, this
would allow an institution to use the Basel Standardized Approach
to calculate its capital ratios. How would the waiver process work?
What are the types of criteria that would be considered?
A.3. Under the banking agencies’ regulatory capital rules, 1 internationally active banking organizations (specifically, those with
total consolidated assets of $250 billion or more or with consolidated total on-balance-sheet foreign exposure of $10 billion or
more) must calculate risk-based capital using the advanced approaches risk-based capital rules (the advanced approaches rule) in
addition to the standardized approach. Section 100(b)(2) of the regulatory capital rules provides that a banking organization subject
to the advanced approaches rule shall remain subject to that rule
until the primary Federal regulator determines that application of
1 12 CFR part 3 (national banks and Federal savings associations), 12 CFR part 217 (State
member banks, bank holding companies, and savings and loan holding companies), and 12 CFR
part 324 (State nonmember banks and State savings associations).

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the advanced approaches rule is not appropriate in light of the
banking organization’s size, level of complexity, risk profile, or
scope of operations. In making such a determination, the primary
Federal regulator must apply notice and response procedures. The
primary Federal regulator may also set conditions on the granting
of the waiver as appropriate, and any waiver granted must be consistent with safety and soundness. The capital adequacy of a banking organization that meets the thresholds described above but has
received a waiver from application of the advanced approaches
rules would be addressed by standardized risk-based capital rules,
leverage rules, and capital planning and supervisory stress-testing
requirements.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR VITTER
FROM JANET L. YELLEN

Q.1. Ms. Yellen, in 2013, Bloomberg View, looking at 2009 creditrating date prices, placed the value on ‘‘too big to fail’’ subsidy at
$83 billion. Another study by the International Monetary Fund released in March, 2014 put the number somewhere between $16 billion and $70 billion annually in 2011 and 2012 for the eight largest
U.S. Banks. The GAO in a report released last summer then confirmed the fact that Wall Street megabanks have not only received
more support from Government bailout programs, but enjoy a taxpayer-funded advantage over community and regional banks that
widens during times of economic crisis.
Do you believe that megabanks, because creditors assume the
Government can’t let them collapse, borrow for less than they otherwise would giving them an unfair advantage over regional and
community banks? Do you think the supplemental leverage ratio
should be strengthened further to offset this advantage?
A.1. It is well documented that large banks generally fund themselves at lower cost than smaller banks. Identifying a single, specific reason for this funding differential, however, is challenging
since large banks and small banks differ along many different dimensions. At the same time, it is not unreasonable to assume that
at least some of the observed funding differential owes to heightened investor expectations of public support for large banks.
Despite the fact that large banks may benefit to some degree
from heightened investor expectations of Government support, it
should be noted that the evidence in favor of such a ‘‘Too Big to
Fail’’ (TBTF) subsidy has waned in recent years. In particular, the
cited Government Accountability Office (GAO) study documents
that the estimated size of the TBTF subsidy has declined significantly since the financial crisis. In addition, rating agencies have
begun to remove their explicit rating uplift that was directly tied
to expectations of Government support.
This decline in the observed TBTF subsidy is not an accident.
Rather, a number of coordinated policies are working in concert to
improve the capital and liquidity position as well as the resolvability of our largest and most systemic banks which will reduce
both the probability of any future insolvency as well the need to
provide Government support in the event that a large bank fails
in the future. More specifically, the capital position of our largest

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banks has been improved with the finalization of Basel III and the
recently proposed Systemically Important Financial Institution
(SIFI) capital surcharges will further enhance the resiliency of our
largest and most systemic banks. The new liquidity coverage requirement (LCR) will further help to ensure that large and systemic banks have the needed liquidity to manage through a period
of financial stress. Finally, provisions of Dodd-Frank Wall Street
Reform and Consumer Protection Act’s (Dodd-Frank Act) Title II
were designed to ensure that a large and systemically important
bank could be resolved in bankruptcy without requiring any taxpayer support.
Accordingly, a number of policies that were put in place following
the financial crisis have resulted in much tighter regulation of
large and systemically important banks and are reducing any
TBTF subsidy resulting from heightened investor expectations of
Government support.
Q.2. The Dodd-Frank Act arguably allows the assets of an insurance company affiliated with a failing depository institution to be
used to cover the costs of resolving the depository institution. Such
action could significantly harm the policyholders of the insurance
company.
Accordingly, do you support legislation clarifying that money
held by insurance affiliates of failing depository institutions cannot
be transferred without the consent of State insurance regulators?
A.2. The Federal Reserve has long considered the source of
strength doctrine, which was codified in the Dodd-Frank Act, to be
an important component of reducing the likelihood of bank failures
and protecting taxpayers against losses that might arise from bank
failures. Section 616 of the Dodd-Frank Act requires all depository
institution holding companies to serve as a source of financial
strength to their subsidiary depository institutions, including bank
holding companies, savings and loan holding companies, and any
other company that controls an insured depository institution.
Under section 5(g) of the Bank Holding Company Act, the ability
of the Federal Reserve to require a bank holding company to provide funds to a subsidiary insured depository institution may be
blocked by a State insurance regulator if the funds would be provided by a bank holding company or a subsidiary of the holding
company that is an insurance company.
We understand that legislation has been proposed which would
extend the same treatment to insurance companies that are savings and loan holding companies or are companies that otherwise
control an insured depository institution. While this legislation
would provide consistency of treatment between bank holding companies and other depository institution holding companies, it would
weaken the ability of these companies to be a source of strength
to their insured depository institutions.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR KIRK
FROM JANET L. YELLEN

Q.1. Chair Yellen, what is the appropriate response time for the
Fed to respond to a written question by a Senator on the Banking
Committee?

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Would you agree that over 6 months is unacceptable?
What is the average response time for the Fed to respond to Congress?
What is the Federal Reserve Board process for responding to official Congressional correspondence?
A.1. The Board recognizes the oversight function that the Committee exercises over the Federal Reserve and has long and consistently cooperated to provide the Committee with information that it
needs to conduct its oversight role. It is the custom and practice
of the Federal Reserve to respond fully to requests for information
from Congress, including responses to questions for the record following hearings. As always, we endeavor to respond to requests
fully and in as timely a manner as possible.
Q.2. Now that the Federal Reserve oversees approximately 1⁄3 of
the life insurance industry by premium volume, it is essential that
the Federal Reserve has the proper person[ne]l and expertise to
support proper insurance regulatory oversight. In addition to the
hiring of former Connecticut Insurance Commissioner Tom Sullivan, how many other individuals has the Board hired that have
experience regulating insurance companies?
A.2. The Federal Reserve is investing significant time and effort
into enhancing our understanding of the insurance industry and
firms we supervise, and we are committed to tailoring our supervisory framework to the specific business lines, risk profiles, and
systemic footprints of the insurance holding companies we oversee.
As part of this, we have hired a significant number of staff who
have prior experience regulating insurance companies.
Q.3. How does the Board assign examiners to insurance companies?
A.3. The Federal Reserve considers a number of factors when assigning staff to supervisory teams in order to best meet our supervisory objectives of protecting the safety and soundness of consolidated firms and mitigating any risks to financial stability. These
teams are combination of Federal Reserve staff with expertise in
risk management, insurance, and specific areas of supervision.
Q.4. How many examiners with insurance experience currently
work for the Federal Reserve?
A.4. The Federal Reserve employs approximately 70 people to supervise insurance holding companies. We will continue to evaluate
our needs and increase our hiring as needed.
Q.5. What policies and procedures has the Federal Reserve established for conducting supervision of insurance companies?
A.5. After the passage of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (Dodd-Frank Act), the Federal Reserve
moved quickly to develop a supervisory framework that is appropriate for insurance holding companies that own depository institutions and promptly assigned supervisory teams to handle day-today supervision of those insurance holding companies. We also
acted promptly to commence supervision of the three insurance
holding companies designated by the Financial Stability Oversight
Council for Federal Reserve supervision. While building our super-

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visory regime for these firms, we have reached out to our colleagues in the State insurance departments. Our supervisory efforts to date have focused on strengthening firms’ risk identification, measurement, and management; internal controls; and corporate governance. Our principal supervisory objectives for insurance holding companies are protecting the safety and soundness of
the consolidated firms and their subsidiary depository institutions
while mitigating any risks to financial stability. The supervisory
program continues to be tailored to consider the unique characteristics of insurance operations and to rely on the work of the primary functional regulator to the greatest extent possible.
Q.6. The International Association of Insurance Supervisors (IAIS)
is currently developing global insurance capital standards. This
process is occurring at the same time the Fed is implementing the
Insurance Capital Standards Clarification Act and authoring domestic insurance capital standards. The international standards
have received a good amount of criticism here in the U.S. There is
particular concern that the Fed may agree to IAIS standards before
domestic standards are finalized. Does the Federal Reserve intend
to precede these international efforts?
A.6. The Federal Reserve participates as a member to the IAIS
along with our fellow U.S. members from the Federal Insurance Office (FIO) and National Association of Insurance Commissioners
(NAIC). Along with these organizations, we advocate for the development of international standards that best meet the needs of the
U.S. insurance market and U.S. consumers. The standards under
development by the IAIS would only apply in the United States if
adopted by the appropriate U.S. regulators in accordance with applicable domestic rulemaking procedures. Additionally, none of the
standards are intended to replace the existing legal entity riskbased capital requirements that are already in place.
The Federal Reserve continues to focus on constructing a domestic regulatory capital framework for our supervised insurance holding companies that is well tailored to the business of insurance.
The timeline for the development of our rulemaking is distinct from
the activities of the IAIS. We are exercising great care as we approach this challenging mandate. We are committed to following a
transparent rulemaking processes to develop our insurance capital
framework, which will allow for an open public comment period on
a concrete proposal. We will continue to engage with interested
parties as we move forward.
Q.7. Who represents the Federal Reserve Board at meetings of the
IAIS?
A.7. Since joining the IAIS in late 2013, the Federal Reserve has
been an active participant in several key committees, working
groups, and work streams. We currently hold a seat on the Financial Stability Committee and the Technical Committee of the IAIS.
Our participation in these activities is primarily overseen by Thomas Sullivan, Associate Director, Division of Banking Supervision
and Regulation, with support and participation of other staff of the
Federal Reserve System at the direction and under the supervision
of the Board of Governors which ultimately is responsible for our
policy positions.

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Q.8. Can you describe the process the U.S. uses to present a position during IAIS negotiations?
A.8. The Federal Reserve has acted on the international insurance
stage in an engaged partnership with our colleagues from the FIO,
the State insurance commissioners, and the NAIC. We collaborate
with one another both formally and informally on matters of import
which are before the IAIS membership. Our multiparty dialogue,
while respectful of each of our individual authorities, strives to develop a central ‘‘Team USA’’ position on the most critical matters
of global insurance regulatory policy.
RESPONSES TO WRITTEN QUESTIONS OF SENATOR HELLER
FROM JANET L. YELLEN

Q.1. Shortly after the Federal Reserve joined the International Association of Insurance Supervisors (IAIS), the IAIS voted to shut
out public observers including consumer groups from most of their
meetings. How did the Federal Reserve representative vote on this
issue? If the Federal Reserve is committed to being transparent in
its operations, will you support allowing the public to observe the
IAIS meetings in the same way Congress—and this Committee—
does with its hearings and mark-ups?
A.1. The Federal Reserve, along with our partners, the State insurance commissioners, the National Association of Insurance Commissioners and the Federal Insurance Office have, and will continue to actively seek out U.S. insurance stakeholders to ensure we
are fully engaged and understanding of their perspectives as we negotiate global insurance standards at IAIS. For instance, the U.S.
delegation has hosted several meetings in recent months, where we
invited in U.S. insurance stakeholders for open dialogue and active
working sessions regarding matters of policy which are currently
before the IAIS. This level of engagement will continue with U.S.
interested parties.
The Federal Reserve supports intervals and protocols for stakeholders to provide comment and input. We believe strongly in independence within the standard setting process and would also seek
to mitigate any opportunity for regulatory capture within the proceedings. The IAIS voted to revise its approach for industry participation in standard setting. Under the new process, industry will no
longer provide financial support to the IAIS or be day-to-day participants in the development of international supervisory standards
for insurance. The industry and public will be able to provide input
through stakeholder meetings as well as through comments on exposures of draft IAIS proposals. The Federal Reserve supports
transparency in rulemaking and policy development and believes
that it is critical that standard-setting bodies be fully independent
of the regulated.
Q.2. The Financial Stability Oversight Council (FSOC) recently
adopted guidance on how it deals with entities it is considering for
SIFI designation, however the Council’s actions did not address
concerns about how it mitigates systemic risk. In particular, the
Council did not create a process that would reduce potential
threats to the financial system by allowing a company or its pri-

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mary regulator to address identified risks before designation.
Shouldn’t FSOC’s primary focus be to identify and ensure systemic
risks are addressed rather than simply sending a nonbank entity
to the Federal Reserve for undefined regulation? Why should the
Federal Reserve regulate nonbank systemically important financial
institutions as opposed to their primary regulator?
A.2. The Dodd-Frank Act gives the FSOC authority to reduce systemic risks by requiring that systemically important financial institutions be supervised by the Federal Reserve and subject to enhanced prudential standards. Such enhanced prudential standards
are designed to reduce systemic risk by ensuring that these firms
maintain adequate capital and liquidity, and that they appropriately plan for an orderly resolution in the event of their failure.
In supervising systemically important financial institutions, the
Federal Reserve’s role is not to replace the functional regulator, but
rather to focus on consolidated supervision and systemic risk reduction. The Federal Reserve is committed to tailoring its enhanced
prudential standards for systemically important firms it supervises
to the specific risks posed by each firm. The Dodd-Frank Act requires the FSOC to reevaluate each designation annually to consider whether the designation should be rescinded. This annual review process establishes a process for the FSOC to rescind a designation if the company has taken steps to reduce the risk that the
firm poses a threat to the financial stability of the United States.
RESPONSES TO WRITTEN QUESTIONS OF
SENATOR MENENDEZ FROM JANET L. YELLEN

Q.1. With Congress preparing to consider a budget in the near future, some members on the other side of the aisle are calling for
severe, across-the-board funding cuts. In addition to being bad policy for many of the priorities that could be cut, what would be the
impact on the economy of a major fiscal tightening? How is the Fed
taking into account the risk of new fiscal austerity in its timeline
for tightening?
If Congress were to impose severe fiscal cuts, would the Fed have
to delay its timeline for tightening monetary policy to compensate
for the contractionary effect? Given where monetary policy is with
respect to the zero lower bound, wouldn’t it be better policy to
allow monetary policy to normalize first, before considering severe
budget cuts?
A.1. The implications for the economy of a fiscal contraction would
depend on many aspects of the situation. But in general, a fiscal
contraction would generally be associated with slower GDP growth
for a time, higher unemployment for a time, and somewhat lower
inflation for a time, holding all other influences on the economy
constant. As time passed, these effects would normally be expected
to fade, as a result of the normal pursuit of monetary policy objectives, namely price stability and maximum employment. In other
words, monetary would seek to restore the economy to its mandateconsistent performance, with labor fully employed and with inflation running at its mandate-consistent pace of 2 percent.
As the Federal Open Market Committee (FOMC) assesses the
best path for monetary policy to follow, the Committee attempts to

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take into account the totality of factors affecting the pace of
progress toward the Committee’s congressionally mandated policy
objectives. Moreover, as I have noted many times, our policy decisions will evolve in light of the latest evidence concerning the position of the economy relative to our policy objectives. Specifically, if
the sum total of factors restraining the pace of activity proves to
be stronger than anticipated, then a more-accommodative monetary
policy will be warranted to best promote attainment of the policy
objectives. Conversely, if the factors restraining the pace of activity
prove to be less potent than anticipated, then a less-accommodative
monetary policy will be warranted, all else equal.
Q.2. Long-term unemployment is coming down from its peak after
the financial crisis, but the level is still high. As you know, Americans who have been hit with long-term unemployment face greater
obstacles to returning to work, which, in addition to the human toll
on these families, reduces our economy’s overall productive capacity. How can monetary policy help address the challenge of longterm unemployment? Is long-term unemployment a reason to let
the economy run a little bit ‘‘hotter’’ for a little bit longer before
tightening?
A.2. The issue of long-term unemployment is very serious, as it has
enormous implications in human terms for those most directly affected by it—first and foremost the workers themselves and their
immediate families—but also for the overall performance of the
economy. I would note that there are some reasonably encouraging
signs that, as overall labor-market conditions have improved, the
situation of the long-term unemployed has also improved. The best
contribution that the Federal Reserve can make to the ongoing reduction in long-term unemployment is to continue to pursue our
congressionally mandated objectives of price stability and maximum employment. A broad consensus agrees that by pursuing
these objectives, the Federal Reserve provides the best possible
backdrop for the economy to perform as well as possible.
Q.3. As you may be aware, some of my colleagues on the other side
of the aisle would like to throw sand in the gears of our financial
regulators by tampering with the way agencies evaluate the benefits and costs of their actions. These proposals would impose a
rigged version of cost-benefit analysis that would prevent the implementation of financial reform laws, create a nearly insurmountable obstacle to action, and invite frivolous legal challenges at taxpayers’ expense. Can you elaborate on some of the problems with
proposals such as these?
A.3. The Federal Reserve takes quite seriously the importance of
evaluating the benefits and burdens associated with our rulemaking efforts. To become informed about these benefits and burdens, before we develop a regulatory proposal, we often collect information directly from parties that we expect will be affected by
the rulemaking. This helps us craft a proposal that is both effective
and minimizes regulatory burden. In the rulemaking process, we
also specifically seek comment from the public on the burdens and
benefits of our proposed approach as well as on a variety of alternative approaches to the proposal. In adopting a final rule, we seek
to adopt a regulatory alternative that faithfully reflects the statu-

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tory provisions and the intent of Congress while minimizing regulatory burden. We also provide an analysis of the costs on 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.
Imposing additional procedural steps and providing new avenues
for legal challenge to the Federal Reserve’s rulemaking process
would likely extend the amount of time it takes the Federal Reserve to promulgate new regulations and to revise existing regulations. This could slow the pace at which the Federal Reserve implements financial reform laws and could limit the Federal Reserve’s
ability to respond promptly to situations where amendments to
Board regulations are deemed to be necessary.
Q.4. In the aftermath of the financial crisis, there was a clear consensus that the compensation practices of some financial companies
created incentives for employees to chase profits by taking on large,
inappropriate risks, where taxpayers could be stuck with the downside if things went wrong. We’re now approaching 5 years after the
passage of the 2010 Wall Street Reform law, and many of the compensation reforms have yet to be implemented.
The Federal Reserve, with our other financial regulators, has responsibility for implementing Section 956 of the Wall Street Reform law, which prohibits compensation arrangements at financial
companies that could drive inappropriate risk-taking. Can you
please provide an update on the status of this rulemaking?
A.4. Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) requires the Federal Reserve, the Office of the Comptroller of the Currency (OCC), the
Federal Deposit Insurance Corporation (FDIC), the Securities and
Exchange Commission, the National Credit Union Administration
Board, and the Federal Housing Finance Agency (the Agencies) to
jointly issue regulations or guidelines that would prohibit any types
of incentive based payment arrangement, or any feature of any
such arrangement, that regulators determine encourage inappropriate risks by providing excessive compensation or that could lead
to material financial loss to a covered financial institution.
Section 956 helps address a critical safety and soundness issue
that may have contributed to the financial crisis: poorly designed
compensation structures that can misalign incentives and result in
excessive risk-taking in financial organizations. The Agencies’ implementation of this and other sections of the Dodd-Frank Act, as
Congress directed, is designed to address many of the systemic
issues that contributed to the crisis. To that end, an interagency
notice of proposed rulemaking to implement the provisions of section 956, titled Incentive-Based Compensation Arrangements, was
published in the Federal Register on April 14, 2011. The Agencies
received more than 11,000 comments on the proposal, many of
which raised complex issues requiring additional research and
analysis.
The Agencies’ staffs are meeting regularly to work through the
issues raised in the comments, which the Agencies will consider
carefully before proceeding. The Federal Reserve expects that the
Agencies will take further action to implement section 956 soon

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and the Federal Reserve recognizes the importance of completing
this rulemaking as expeditiously as possible. In the meantime, the
Federal Reserve will continue its ongoing supervisory and regulatory work addressing compensation-related issues at financial institutions that it supervises. Currently this work is based on the
Interagency Guidance on Sound Incentive Compensation Policies, 1
enacted by the Federal Reserve, OCC and FDIC after being proposed by the Federal Reserve, as well as interagency guidelines
adopted by the same agencies implementing the compensation-related safety and soundness standards in section 39 of the Federal
Deposit Insurance Act. 2
Q.5. The Federal Reserve, OCC, and FDIC have on several occasions expressed concern about the risk management practices of
regulated institutions with respect to leveraged lending. As regulators have required banks to reduce their risks in this area, however, there have been reports that nonbank lenders are stepping in
to fill the void. Even if regulated institutions reduce their direct exposure to leveraged loans, they still face risks from lending that occurs through the ‘‘shadow banking’’ sector—for example, if a regulated bank is lending money to a hedge fund or other entity that
invests in risky loans, if a crisis occurs with nonbank lenders that
could depresses bank asset values through a fire sale or destabilize
credit availability marketwide, or through a cascade of defaults
that could find its way back to a bank’s doorstep.
How is the Federal Reserve working with other regulators, the
Financial Stability Oversight Council, and the Office of Financial
Research to monitor leveraged lending by institutions other than
those it regulates?
A.5. Within the Federal Reserve, staff regularly review marketwide
information on underwriting trends as well as deals being made by
lenders to assess the effects of supervisory actions to require banks
to reduce their risks in leveraged lending. An important part of the
analysis is the extent to which the origination of leveraged loans
is migrating to nonbank institutions. Federal Reserve staff’s financial stability analysis looks at various sources to assess this, including market data sources which provide information on the
bookrunners, or main underwriters, for highly leveraged transaction deals that have closed in the last quarter as well anecdotal
evidence based on regular staff meetings with market participants.
Federal Reserve staff have presented on the issue of leveraged
lending to the principals of the Financial Stability Oversight Council. 3
Q.6. How is the Fed monitoring the direct and indirect exposure of
its regulated institutions to nonbank entities that are engaging in
leveraged lending?
A.6. The Federal Reserve studied extensively the exposures of the
majority of its regulated institutions (specifically, about 80 percent
of the banking sector) to a sudden reversal in conditions in leveraged lending—alongside a severe recession—in the severely ad1 75

Federal Register 36395 (June 25, 2010).
U.S.C. §1831p-1(c); 12 CFR Part 208, Appendix D-1.
3 See the readout from the January 21, 2015 meeting at http://www.treasury.gov/initiatives/
fsoc/council-meetings/Documents/January%2021,%202015.pdf.
2 12

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verse scenario used in the recently completed stress test exercise.
This exercise studied both direct exposures—including from loans
held in the pipeline prior to sale to nonbank entities and holdings
of securities issued by collateralized loan obligations—as well as indirect exposures—including (as described in the scenario narrative)
a sharp deterioration in the secondary market for leveraged loans
and related assets consistent with the distress of a number of
nonbank entities engaged in leveraged lending.
Regular assessments of financial stability by Federal Reserve
staff also consider other channels through which a deterioration in
the leveraged lending market—and speculative debt markets more
broadly—could create strains that could then indirectly feedback on
the financial sector, including the institutions that the Federal Reserve regulates. One such channel, which was highlighted in the
February 24, 2015 Monetary Policy Report, is the growth in mutual
funds and exchange-traded funds. These investors, which now hold
a much higher fraction of the available stock of relatively less liquid assets (including leveraged loans), give the appearance of offering greater liquidity than the markets in which they transact and,
as a result, heighten the potential for forced sales in underlying
markets.
Q.7. What is the Fed’s assessment of the risks currently posed by
leveraged lending outside of the institutions it regulates?
A.7. Currently, the Federal Reserve sees little migration in the
origination of leveraged loans as a result of supervisory actions, although staff are continuing to monitor closely this issue as described in the answer to Question 5. In terms of investors in leveraged loans, however, and as described in the answer to Question
6, mutual funds’ and exchange-traded funds’ holdings of a higher
fraction of the available stock of relatively less liquid assets (including leveraged loans) heightens the potential for forced sales in
underlying markets.
Q.8. What data can you provide regarding the share and relative
riskiness of leveraged lending by nonbanks vs. regulated institutions, the exposure of regulated institutions to leveraged lending by
nonbanks, and any systemic risk concerns relating to leveraged
lending by nonbanks?
A.8. As described earlier, the Federal Reserve relies on a variety
of market data sources—which are broadly available—to assess the
state of the speculative grade corporate debt market across a variety of dimensions. Importantly, the Federal Reserve has highlighted key trends in speculative-grade corporate debt markets, including issuance volume and important underwriting trends in recent Monetary Policy Reports.
The Federal Reserve sees little migration in the origination of leveraged loans as a result of supervisory actions. However, in the
instances where nonbanks have increased their share of originations of leveraged loans, often these transactions have been higher
risk.
The Federal Reserve’s views on leveraged lending are informed
by the findings of ongoing supervisory examinations of practices at

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banks. We publish the findings of an important part of this supervisory exercise, the Shared National Credits review. 4
Q.9. In your remarks at the National Summit on Diversity in the
Economics Profession on October 30, 2014, you highlighted the
need for diversity in the economics profession—both at the Federal
Reserve and elsewhere—and discussed how a diversity of perspectives can lead to more informed policy decisions and research that
informs policy. What steps is the Federal Reserve taking to cultivate diversity among its economists and more broadly, and in particular among its senior and mid-level leadership? How would you
rate the Federal Reserve’s progress so far? What role does the Office of Minority and Women Inclusion play in this process?
A.9. I would reiterate the Federal Reserve’s commitment to diversity, and while we continue to work towards achieving a more diverse workforce, we recognize that we need to do more. During the
initial stages of appointing official staff, the Director of the Office
of Minority and Women Inclusion (OMWI), who also is the Director
of Office of Diversity and Inclusion (ODI), is consulted and is a
member of the reviewing team that evaluates proposed official staff
actions.
This allows the ODI Director to better support inclusion and diversity at the official staff level and to ensure that the Board’s
leadership nomination criteria and process are inclusive.
In 2014, the Federal Reserve hired 36 economists, of which 33
percent were minorities and 19 percent were women. Based on the
2010 Census civilian labor force data and subsequent updates, the
availability of minority and female candidates in the economist job
occupation remains low. To foster recruitment, the Federal Reserve
continues to organize, oversee, and participate in the three programs under the purview of the American Economic Association’s
(AEA) Committee on the Status of Minority Groups in the Economics Profession (CSMGEP): (1) the Summer Economics Fellow Program, (2) the Summer Training Program, and (3) the Mentoring
Program. Also, through its participation in the Science Technology
Engineering and Mathematics (STEM) Education Coalition and financial literacy programs, the Federal Reserve aims to stimulate
an interest in economics and math among minorities and women.
However, the Federal Reserve faces real challenges in hiring minorities in the economist job family as does the rest of the economics profession. The Federal Reserve has addressed these challenges
as an active member of the AEA’s CSMGEP, which was established
by the AEA to increase the representation of minorities in the economics profession, primarily by broadening opportunities for a
training of underrepresented minorities. The Board continues to be
involved in the range of program (from undergraduate to postPh.D.) sponsored by CSMGEP including the following:
• The Federal Reserve partnered with the AEA to host the National Summit on Diversity in the Economics Profession at the
Federal Reserve on October 30, 2014, in Washington, DC. This
conference brought together presidents and research directors
4 See the results of the review at: http://www.federalreserve.gov/newsevents/press/bcreg/
20141107a.htm.

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of the Federal Reserve Banks and chairs of economics departments from around the country to open a profession-wide dialogue about diversity. Speakers and panelists discussed the
state of diversity in the economics profession and examples of
successful diversity initiatives in academia. A hallmark of the
conference was the opportunity for collegial learning, discussion, and sharing among faculty peers to develop practical
ideas about what can be accomplished to attract and retain diversity in the economics profession. The proceedings of the conference are available on the Federal Reserve’s public Web
site; 5
• Board staff have been involved with the CSMGEP Summer
Training Program since its inception in 1974. That program is
designed to provide undergraduate students with a program of
study and research opportunities that prepare then to enter
doctoral level Ph.D. programs in economics. Board staff regularly participate as adjunct faculty in the Summer Training
Program;
• The Federal Reserve strives to encourage summer intern applicants from the CSMGEP Summer Fellows Program for the
Board’s summer internship program and also focuses on
matching minority advanced graduate students with researchoriented sponsoring institutions to work on their own research
projects while participating in the research community at the
Federal Reserve; and
• Board staff have served as mentors through the CSMGEP
Mentoring Program in which students are matched with a
mentor who sees them through the critical junctures of their
graduate program.
In addition, the Federal Reserve has participated in or initiated
other outreach efforts including the following:
• The Federal Reserve has hosted the ‘‘Math x Econ’’ (math
times econ) program for the past 3 years which is aimed at
high-performing math students in minority-serving high
schools in the Washington, DC, metropolitan area. Math x
Econ brings math students to the Board for a one-day program
that introduces them to the field of economics with the goal of
encouraging them to explore economics when they begin their
college educations.
• A group of research assistants in our economics divisions as
well as our supervision division continued with the fourth year
of the Fed Ed Outreach program to present information on
monetary policy, financial literacy, and the role of the Federal
Reserve in the economy to local high school students. The program consists of hour-long presentations presented in high
school classrooms or at the Board. This past school year, the
program delivered 18 presentations to 11 schools and more
than 500 students.
5 http://www.federalreserve.gov/newsevents/conferences/national-summit-diversity-economicsprofession-program.htm

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Q.10. As you know, I worked during Wall Street Reform to include
provisions in the law to create Offices of Minority and Women Inclusion, or OMWIs, at the Federal financial regulators, including
the Federal Reserve. In 2013, the financial regulators jointly issued
proposed interagency OMWI standards for assessing the diversity
policies and practices of regulated entities, and it is my understanding that the regulators intend to issue final joint standards
later this year. Some community groups have expressed concerns
that the proposal needs stronger standards and accountability
measures in order to meet its objectives and improve workforce and
supplier diversity for regulated institutions, such as mandating reporting on employee and supplier diversity rather than proposing
that regulated entities voluntarily submit self-assessments to the
agencies.
How is the Fed responding to these concerns, and what plans do
the financial regulators have to ensure the final interagency standards will be best designed to improve diversity and promote inclusion in recruiting, advancement, leadership, and contracting? What
steps is the Fed taking to strengthen the final interagency standards to ensure real progress in expanding the role of women, people
of color, and other underrepresented groups in the financial sector?
What is the expected timeline for adopting final standards?
A.10. In 2013, an interagency working group comprising the OMWI
directors from each of the financial agencies (the Federal Reserve,
the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the National Credit Union Administration,
the Consumer Financial Protection Bureau, and the Securities and
Exchange Commission) published proposed standards for assessing
the diversity policies and practices of entities regulated by each
agency. The proposed standards were published in the Federal Register on October 25, 2013, for public comment; the comment period
was later extended to February 7, 2014, to allow interested parties
adequate time to respond.
The standards seek to promote transparency and awareness of
diversity policies and practices within regulated entities, and provide a framework for assessing diversity in four major areas:
• Organizational commitment to diversity and inclusion
• Workforce profile and employment practices
• Procurement and business practices and supplier diversity
• Practices to promote transparency of organizational diversity
and inclusion
The agencies carefully considered over 200 comments received
and on June 9, 2015, issued a joint press release announcing publication in the Federal Register of the final policy statement that establishes joint standards for assessing the diversity policies and
practices of the entities they regulate. The final policy statement
establishing joint standards is effective as of the date it is published in the Federal Register, June 10, 2015. The press release and
policy statement are posted on our public Web site. 6
The joint standards, which are generally similar to the proposed
standards, provide a framework for regulated entities to create and
6 http://www.federalreserve.gov/newsevents/press/bcreg/20150609a.htm

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strengthen their diversity policies and practices—including their
organizational commitment to diversity, workforce and employment
practices, procurement and business practices, and practices to promote transparency of organizational diversity and inclusion within
the entities’ U.S. operations.

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