Full text of Statements and Speeches of Daniel K. Tarullo : Statement before the Committee on Banking, Housing, and Urban Affairs, United States Senate

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10 a.m. EST
December 6, 2011

Statement by
Daniel K. Tarullo
Member
Board of Governors of the Federal Reserve System
before the
Committee on Banking, Housing, and Urban Affairs
United States Senate
December 6, 2011

Chairman Johnson, Ranking Member Shelby, and other members of the committee, thank
you for the opportunity to testify on the Federal Reserve’s implementation of the Dodd-Frank
Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act).
The Federal Reserve’s Approach to Dodd-Frank Implementation
Needless to say, implementation of the Dodd-Frank Act has been, and continues to be, a
formidable task. At the Federal Reserve, hundreds of staff members are contributing to DoddFrank projects. We have issued 29 final rules, public notices, and reports already and we have
another 13 rules underway. All told, we expect the Board will issue approximately 60 sets of
rules and formal guidelines as part of its implementation efforts. We are working diligently to
complete the remaining rules. The challenge arises from the sheer number of studies, rules, and
other implementation tasks the Act requires the Federal Reserve to produce in a relatively short
period of time. Moreover, much of the work involves the more time-consuming process of joint
rulemakings or coordination with other agencies, all of which are facing similar demands.
For all the variation and complexity in our Dodd-Frank implementation responsibilities,
we have several unifying goals.
First and foremost, we want to get it right. This means implementing the statute
faithfully, in a manner that maximizes financial stability and other social benefits at the least cost
to credit availability and economic growth. To achieve this balance, we have assembled
interdisciplinary teams for our significant rulemakings, bringing together economists,
supervisors, legal staff, and other specialists to help develop sensible policy alternatives and to
help avoid unintended consequences.
Second, in addition to a thorough internal analytic process, we also are committed to
soliciting and considering the comments of others. We are, of course, consulting extensively

-2with other financial regulatory agencies, both bilaterally and through the Financial Stability
Oversight Council. The interagency consultation process has included staff discussions during
the initial policy development stage, sharing of draft studies and regulatory text in the interim
phases, and dialogue among agency principals in the advanced stages of several rulemakings.
Along with the other agencies testifying today, we have gone well beyond the formal
consultation requirements of Dodd-Frank. Members of the Board, as well as staff at senior
levels, have regular meetings with their counterparts at other agencies to discuss implementation
issues of common interest. Consultations at multiple levels and across agencies help to improve
the consistency of regulation across the banking industry and reduce the potential for
overlapping regulatory requirements. In addition, these consultations help highlight the
interaction among different rules under development by these agencies, as well as the interplay
between proposed policy alternatives and existing regulations.
We are also trying to make our rulemaking process as fair and transparent as possible,
with ample opportunity for the public to comment. During the proposal stage, we specifically
seek comment from the public on the costs and benefits of our proposed approach, as well as on
alternative approaches to our proposal. We believe strongly that public participation in the
rulemaking process improves our ability to identify and resolve issues raised by our regulatory
proposals. We generally provide the public a minimum of 60 days to comment on all significant
rulemaking proposals, with longer periods permitted for especially complex or significant
proposals.
Federal Reserve staff have participated in more than 300 meetings with outside parties
and their representatives, including community and consumer groups. To promote transparency
in the rulemaking process, we include in the public record a memorandum describing the

-3attendees and subjects covered in any meetings involving non-governmental participants at
which Dodd-Frank rulemakings are discussed. These summaries are posted on the Federal
Reserve Board’s website on a weekly basis, as are updates on Board rulemakings and other
Dodd-Frank initiatives.
Third, in drafting regulations, we have made special efforts to identify and, to the degree
possible consistent with statutory requirements, minimize the regulatory burden on smaller
entities. We conduct an assessment that takes appropriate account of the potential impact a rule
may have on small businesses, small governmental jurisdictions, and small organizations
affected by the rule, in accordance with the Regulatory Flexibility Act. We have paid particular
attention to reducing the regulatory burden on community banking organizations. For example,
the Federal Reserve has established community depository institution advisory councils at each
of the 12 Federal Reserve banks. These councils gather input from community depository
organizations on ways to reduce regulatory burden and improve the efficiency of our
supervision, and also collect information about the economy from the perspective of community
organizations throughout the nation. A representative from each of these 12 advisory councils
serves on a national Community Depository Institution Advisory Council that meets
semiannually with the Board of Governors to bring together the ideas of all the advisory groups.
The Board of Governors has also established a subcommittee of our regulatory and
supervisory oversight committee for the express purpose of reviewing all regulatory matters from
the perspective of community depository organizations. These reviews are intended to find ways
to reduce the burden on community depository organizations arising from our regulatory policies
without reducing the effectiveness of those policies in improving the safety and soundness of
depository organizations of all sizes.

-4Fourth, we are working to complete our Dodd-Frank projects as quickly as possible while
meeting the three objectives already stated. There is obviously considerable value in providing
as much clarity as possible as soon as possible to financial markets and the public about the postcrisis financial regulatory landscape.
Capital Regulation after Dodd-Frank
The breadth of Dodd-Frank’s provisions reflects in part that the pre-crisis regulatory
regime had been insufficiently attentive to a variety of risks from a variety of sources. But we
should not forget that strong capital requirements remain the most supple form of prudential
regulation, because they can provide a buffer against bank losses from any source. To put it
simply, the best way to avoid another TARP is for our large regulated institutions to have
adequate capital buffers, reflecting the damage that would be done to the financial system were
such institutions to fail.
Implicitly, passage of Dodd-Frank was a criticism of the specific features of capital
regulation that prevailed during the pre-crisis period. Basel I capital requirements relied almost
exclusively on capital ratios that were snapshots of balance sheets and thus frequently a lagging
indicator of a bank’s condition. The kind of capital that qualified for regulatory purposes was
not uniformly reliable as a buffer against losses. Moreover, capital requirements were set solely
with reference to the balance sheet of each firm individually, with little attention to the economywide impact of financial stress at large institutions. And, most fundamentally, capital
requirements had simply been too low, in general and with respect to the risk-weightings of
certain assets.
Strong capital requirements must be at the center of the post-crisis period regulatory
regime. The Federal Reserve is integrating the specific capital-related provisions of Dodd-Frank

-5into its overall capital program. That program has three basic components: improving capital
regulation at the level of individual firms; introducing a macroprudential or system-wide element
to capital regulation; and conducting regular stress testing and capital planning. I will discuss
each of the three areas briefly.
The first component is to improve the traditional, firm-based approach to capital
regulation. This work is mostly related to standards developed in cooperation with other
supervisors in the Basel Committee on Banking Supervision, but there is also a Dodd-Frank
element. The “Collins amendment” in Dodd-Frank provided a safeguard against declines in
minimum capital requirements in a capital regime based on bank internal modeling. The socalled Basel 2.5 agreement strengthened the market risk capital requirements of Basel II. Basel
III upgraded the quality of regulatory capital, increased the quantity of minimum capital
requirements, created a capital conservation buffer, and introduced an international leverage ratio
requirement. In the coming months the banking agencies will be jointly proposing regulations
consistent with Basel 2.5 and Basel III.
The second component of our capital program is to introduce a macroprudential element
to capital regulation. Section 165 of the Dodd-Frank Act mandated that the Board establish
enhanced risk-based capital standards for large bank holding companies. This mandate
complements the Basel Committee’s effort to develop a framework for assessing a capital
surcharge on the largest, most interconnected banking organizations based on their global
systemic importance. Both the Dodd-Frank provision and the Basel systemic surcharge
framework are motivated by the fact that the failure of a systemically important firm would have
dramatically greater negative consequences on the financial system and the economy than the
failure of other firms. In addition, stricter capital requirements on systemically important firms

-6should help offset any funding advantage these firms derive from their perceived status as toobig-to-fail and provide an incentive for such firms to reduce their systemic footprint.
Of course, Dodd-Frank requires the Federal Reserve to impose more stringent capital
requirements on all bank holding companies with assets of $50 billion or more, not just the U.S.
firms that will appear on the Basel Committee’s list of global systemic banks. No decision has
yet been made as to whether the more stringent capital requirement to be applied to large U.S.
banking firms that are not on the eventual list of global systemic banks will be in the form of a
quantitative surcharge. However, analysis of the systemic footprints of these other U.S. bank
holding companies suggests that even if surcharges were to apply, their amounts would be quite
modest, at least based on the current characteristics of these bank holding companies.
The third component of the Federal Reserve’s capital program is to establish regular,
firm-specific stress testing and capital planning. Dodd-Frank creates two kinds of stress-testing
requirements. First, it mandates that the Federal Reserve Board conduct annual stress tests on all
bank holding companies with $50 billion or more in assets to determine whether they have the
capital needed to absorb losses in baseline, adverse, and severely adverse economic conditions.
Second, it requires both these companies and certain other regulated financial firms with between
$10 billion and $50 billion in assets to conduct internal stress tests.
We will be implementing the specific stress-testing requirements of Dodd-Frank
beginning later in 2012. However, in the interim we are using a modified form of stress testing
as part of the annual capital planning process we have established for large bank holding
companies. Last month we announced the parameters and process for this year’s capital review,
which will be completed in March, at which time the results of the stress test will be publicly
reported for the 19 largest firms.

-7Conclusion
For all the work that has already gone into implementing Dodd-Frank, both at the Federal
Reserve and at the other regulatory agencies, there is still considerable work to do. Final
regulations implementing some of the Act’s most important provisions, such as the “living will”
requirement and the Collins amendment, are now in place. Measures to implement other
prominent provisions, such as the Volcker rule, have been proposed, but are not yet in final form.
Still others, such as the section 165 requirements, have not yet been proposed. Whether
completing work on proposed regulations, or moving forward with those yet to be proposed, the
Federal Reserve will continue to pursue the four goals I noted earlier.
Thank you very much for your attention. I would be pleased to answer any questions you
might have for me.

As of December 5, 2011

Final Rule on Resolution Plans (living wills) [R-1414]. On October 17, 2011, the Board and
the FDIC issued a final rule that would require large, systemically significant bank holding
companies and nonbank financial companies to submit annual resolution plans and quarterly
credit exposure reports. (Section 165)

Status

1/1/2012

Completed.

No
Comment period
Deadline closed.

No
Completed.
Deadline

Due

Page 1 of 10

The implementation initiatives highlighted below do not include the Board’s rulemaking responsibilities as part of the Financial
Stability Oversight Council, or rulemaking initiatives where the Board serves in a consultative role.

Proposed Rule to Establish Certain Definitions Under Title I [R-1405]. On February 8,
2011, the Board issued a proposed rule to define when a nonbank company is “predominantly
engaged” in financial activities; and the terms “significant nonbank financial company” and
“significant bank holding company.” (Section 102)

Rulemaking Under Title I
1.
Final Rule to Establish Minimum Risk-Based Capital Requirements (Collins Amendment)
[R-1402]. On June 14, 2011, the Board issued a joint final rule, along with the FDIC and the
OCC, to establish a floor for the risk-based capital requirements applicable to the largest,
internationally active banking organizations. (Section 171)

Seq. Description

Table 1. Summary of the Board’s Rulemaking Efforts Under the Dodd-Frank Act as of December 5, 2011 1

The following highlights key initiatives undertaken by the Board of Governors of the Federal Reserve System (Board) in
connection with the implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Act). As of
December 5, 2011, the Board has issued seventeen final rules, three public notices and nine reports (Tables 1 and 2). The Board has
proposed an additional thirteen rules for public comment.

Update on Key Implementation Initiatives of the Board of Governors of the Federal Reserve System
Under the Dodd-Frank Wall Street Reform and Consumer Protection Act

Appendix A to statement by
Daniel K. Tarullo, Member, Board of Governors of the Federal Reserve System
Before the Committee on Banking, Housing, and Urban Affairs U.S. Senate
Washington, DC, December 6, 2011

Final Rule on Capital Plans and Stress Testing Instructions [R-1425]. On November 22,
2011, the Board issued a final rule requiring top-tier U.S. bank holding companies (BHCs) with
total consolidated assets of $50 billion or more to submit annual capital plans for review and
provided stress testing instructions outlining the information to be provided for the Federal
Reserve’s 2012 Comprehensive Capital Analysis and Review. (Section 165(i)).

Interim Final Rule to Amend OTS Regulations [R-1429]. On August 12, 2011, the Board
issued an interim final rule setting forth regulations for SLHCs. The interim final rule has three
components: (1) a new Regulation LL, setting forth regulations generally governing SLHCs; (2)
a new Regulation MM, setting forth regulations governing SLHCs in mutual form (MHCs); and
(3) several technical amendments to current Board regulations necessary to accommodate the
transfer of supervisory authority for SLHCs from the OTS to the Board. (Section 312)

Information Collection Proposal Related to the Supervision of SLHCs. On August 22, 2011,
the Board issued an information collection proposal for comment that would permit a two-year
phase-in period for most SLHCs to file Federal Reserve regulatory reports with the Board and an
exemption for some SLHCs from initially filing Federal Reserve regulatory reports. (Title III,
generally)

Notice of OTS Regulations To Be Continued. On July 21, 2011, the Board issued a public
notice of all OTS regulations that it anticipates continuing to enforce. (Section 316)

Page 2 of 10

Notice Related to Supervision of SLHCs [OP-1416]. On April 15, 2011, the Board issued a
public notice that outlines how it intends to apply certain parts of its current consolidated
supervisory program for bank holding companies to SLHCs after assuming supervisory
responsibility for SLHCs. (Title III, generally)

Rulemaking Under Title III
5.
Notice of Intent to Require Reporting Forms For Savings and Loan Holding Companies.
On February 3, 2011, the Board provided public notice of its intention to require savings and
loan holding companies (SLHCs) to submit the same reports as bank holding companies,
beginning with the March 31, 2012 reporting period. (Title III, generally)

Completed.

No
Comment period
Deadline closed.

No
Completed.
Deadline

7/21/11

No
Comment period
Deadline closed.

No
Completed.
Deadline

1/1/2012

As of December 5, 2011

Final Rule to Allow Interest on Demand Deposits [R-1413]. On July 14, 2011, the Board
issued a final rule repealing Regulation Q and allowing payment of interest on demand deposits
at institutions that are member banks of the Federal Reserve System. (Section 627)

Proposed Rule on Registration of Securities Holding Companies [R-1430]. On August 31,
2011, the Board issued a proposed rule that outlines the requirements that a nonbank company
that owns at least one registered broker or dealer, and that is required by a foreign regulator or
provision of foreign law to be subject to comprehensive consolidated supervision (securities
holding company), must satisfy in order to register with the Board and subject themselves to
supervision by the Board. (Section 618)

12.

13.

Page 3 of 10

Rulemaking Under Title VII
14. Proposed Rule on Margin and Capital Requirements for Swaps [R-1415]. On April 12,
2011, the Board issued a joint proposed rule with the FCA, FDIC, FHFA and OCCto establish
margin and capital requirements for swap dealers, major swap participants, security-based swap
dealers, and major security-based swap participants. The Agencies previously extended the
comment period to July 11, 2011, to allow interested persons more time to analyze the issues and
prepare their comments. (Sections 731 and 764)

Final Rule to Implement the Volcker Rule Conformance Period [R-1397]. On February 9,
2011, the Board issued a final rule to implement the provisions of the Act that give banking firms
a period of time to conform their activities and investments to the prohibitions and restrictions of
the Volcker Rule. (Section 619(c)(6))

11.

Rulemaking Under Title VI
10. Proposed Rule implementing the Volcker Rule Requirements. On October 11, the Board
requested public comment on a proposed rule that would implement Section 619 of the Act,
which contains certain prohibitions and restrictions on the ability of a banking entity and
nonbank financial company supervised by the Board to engage in proprietary trading and have
certain interests in, or relationships with, a hedge fund or private equity fund. The comment
period will be open until January 13, 2012. (Section 619, generally)

Completed.

Comment period
open.

No
Comment period
Deadline closed.

No
Completed.
Deadline

1/21/11

10/11/11

As of December 5, 2011

Proposed Rule on Retail Foreign Exchange Futures and Options [R-1428]. On July 28,
2011, the Board issued a proposed rule that that sets standards for banking organizations
regulated by the Federal Reserve who engage in certain types of foreign exchange transactions
with retail customers. (Section 742)

Page 4 of 10

Proposed Rule on Incentive Compensation [R-1410]. On March 30, 2011, the Board issued a
joint proposed rule with the OCC, FDIC, OTS, NCUA, SEC and FHFA to prohibit incentivebased compensation arrangements that encourage inappropriate risk-taking by covered financial
companies, and to require the disclosure and reporting of certain incentive-based compensation
information by covered financial companies. (Section 956)

19.

Proposed Rule on Credit Risk Retention [R-1411]. On March 29, 2011, the Board issued a
joint proposed rule with five other federal agencies, to implement the credit risk retention
requirements applicable in connection with the issuance of asset-backed securities. The agencies
previously had extended the comment period for the proposed rule to allow interested persons
more time to analyze the issues and prepare their comments. (Section 941)

18.

Rulemaking Under Title IX
17. Advanced Notice of Proposed Rulemaking on Alternatives to the Use of Credit Ratings in
Capital Rules (Regulations H and Y) [R-1391]. On August 10, 2010, the Board issued an
advanced notice of proposed rulemaking regarding the alternatives to the use of credit ratings in
the risk-based capital rules for banking organizations. (Section 939A)

Rulemaking Under Title VIII
16. Proposed Rule on Financial Market Utilities (FMU) Risk Management Standards and
Procedures [R-1412]. On March 30, 2011, the Board issued a proposed rule related to the
supervision of FMUs designated as systemically important by the Financial Stability Oversight
Council. (Sections 801and 806)

15.

4/21/11

4/17/11

Comment period
closed.

No
Comment period
Deadline closed.

As of December 5, 2011

Page 5 of 10

Debit Interchange—Interim Final Rule Regarding Fraud Prevention Adjustment [R-1404].
On June 29, 2011, the Board issued an interim final rule that allows for an upward adjustment of
no more than 1 cent to an issuer’s debit card interchange fee if the issuer develops and
implements policies and procedures reasonably designed to achieve the rule’s fraud-prevention
standards. (Section 1075)

23.

Debit Interchange—Final Rules Establishing Interchange Standards and Limitations on
Payment Card Restrictions [R-1404]. On June 29, 2011, the Board issued a final rule to
establish standards for debit card interchange fees, regulations governing network fees, and
prohibitions against network exclusivity arrangements and routing restrictions. The statutory
deadline for issuing interchange and network fee rules was April 21, 2011. The final rules to
implement the exclusivity and routing restrictions of the Act were not due until July 21, 2011,
but have been combined with the rules on interchange fees. (Section 1075)

22.

Proposed Rules on Remittance Transfers Disclosures (Regulation E) [R-1419]. On May 12,
2011, the Board issued a proposed rule to require that remittance transfer providers make certain
disclosures to senders of remittance transfers, including information about fees and the exchange
rate, as applicable, and the amount of currency to be received by the recipient. The proposed rule
also would provide error resolution and cancellation rights for senders of remittance transfers.
(Section 1073)

21.

Rulemaking Under Title X
20. Final Rule on Data Requirements for Motor Vehicle Dealers [R-1426]. On September 20,
2011, the Board issued a final rule under Regulation B to clarify that motor vehicle dealers are
not required to comply with certain data collection requirements in Act until the Board issues
final regulations to implement the statutory requirements. (Section 1071)

4/21/11

4/21/11
and
7/21/11

1/21/12

Completed.

Comment period
closed (rule has been
transfer to the
CFPB).

No
Completed.
Deadline

As of December 5, 2011

No
Completed.
Final Rule Implementing Combined FCRA Notices Under the Equal Credit Opportunity
Act (Regulation B) [R-1408]. On July 6, 2011, the Board issued a final rule amending
Deadline
Regulation B to include the disclosure of credit scores and related information if a credit score is used
in taking adverse action. The revised model notices reflect the new content requirements in section
615(a) of the FCRA, as amended by section 1100F of the Act. (Section 1100F)

29.

Page 6 of 10

Final Rule Revising Risk-Based Pricing Notices Under the Fair Credit Reporting Act
(FCRA) (Regulation V) [R-1407]. On July 6, 2011, the Board and the FTC issued a joint final
rule to revise the content requirements for risk-based pricing notices and to add related model
forms to reflect the new credit score disclosure requirements. (Section 1100F)

28.

Final Rule to Increase Exemption Threshold Under the Truth in Lending Act (Regulation
Z) [R-1424]. On March 25, 2011, the Board issued a final rule to increase the dollar threshold
for exempt consumer credit transactions. These annual adjustments are required by statute.
(Section 1100(E))

27.

No
Completed.
Deadline

Final Rule to Increase Exemption Threshold Under the Consumer Leasing Act (Regulation
M) [R-1423]. On March 25, 2011, the Board issued a final rule under Regulation M (Consumer
Leasing) to increase the dollar threshold for exempt consumer lease transactions. These annual
adjustments are required by statute. (Section 1100(E))

26.

No
Completed.
Deadline

Completed.
Final Rule to Expand Coverage Under the Consumer Leasing Act (Regulation M) [R-1400]. No
On March 25, 2011, the Board issued a final rule requiring lessors to provide consumers with
Deadline
disclosures regarding the cost and other terms of personal property leases. (Section 1100(E))

No
Completed.
Deadline

As of December 5, 2011

25.

Rulemaking Under Title XI
24. Final Rule to Expand Coverage Under the Truth in Lending Act (Regulation Z) [R-1399].
On March 25, 2011, the Board issued a final rule to require creditors to disclose key terms of
consumer loans and prohibit creditors from engaging in certain practices with respect to those
loans. (Section 1100(E))

Page 7 of 10

Interim Final Rule on Appraisal Independence (Regulation Z) [R-1394]. On October 18,
2010, the Board issued an interim final rule that is intended to ensure that real estate appraisers
are free to use their independent professional judgment in assigning home values without
influence or pressure from those with interests in the transactions. (Section 1472)

33.

Final Rule on Escrow Requirements Under the Truth in Lending Act (Regulation Z) [R1392]. On February 23, 2011, the Board issued a final rule to increase the annual percentage rate
threshold used to determine whether a mortgage lender is required to establish an escrow account
for property taxes and insurance for first-lien “jumbo” residential mortgage loans, effective
April 1, 2011. (Section 1461)

32.

Proposed Rule Regarding Ability to Repay Under the Truth In Lending (Regulation Z) [R1417]. On April 19, 2011, the Board issued a proposed rule under Regulation Z that would
require creditors to determine a consumer's ability to repay a mortgage before making the loan
and would establish minimum mortgage underwriting standards. The proposal would also
implement the Act’s limits on prepayment penalties. The Board is soliciting comment on the
proposed rule until July 22, 2011. (Sections 1411, 1412 and 1414)

31.

10/19/10

1/21/13

Rulemaking Under Title XIV
30. Proposed Rule on Escrow Account Requirements Under the Truth in Lending Act
1/21/13
(Regulation Z) [R-1406]. On February 23, 2011, the Board issued a proposed rule to expand the
minimum period for mandatory escrow accounts for first-lien, higher-priced mortgage loans from
one to five years, and longer under certain circumstances; provide an exemption from the escrow
requirement for certain creditors that operate in rural or underserved counties; and implement
new disclosure requirements contained in the Act. (Sections 1411, 1412 and 1414)

Completed.

Comment period
open (rule has been
transfer to the CFPB)

Comment period
closed (rule has been
transfer to the CFPB)

As of December 5, 2011

7/21/11
Study of International Coordination Relating to the Resolution of Systemic Financial
Companies. The Board has approved a study, which the Board has conducted, in consultation
with the Administrative Office of the U.S. Courts, regarding international coordination relating to
the resolution of systemic financial companies under the Bankruptcy Code and applicable foreign
law. (Section 217)

Report on Remittance Transfers: Automated Clearing House Expansion (ACH). On
July 19, 2011, the Board approved a report to Congress on the status of ACH expansion for
remittance transfers to foreign countries. (Section 1073)

Page 8 of 10

Study of the Resolution of Financial Companies under the Bankruptcy Code. The Board
has approved a study, which the Board has conducted, in consultation with the Administrative
Office of the U.S. Courts, related to the resolution of financial companies under the Bankruptcy
Code. (Section 216)

Report on Debit Card Transactions. On June 29, 2011, the Board issued a report disclosing
7/21/11
certain aggregate or summary information concerning interchange transaction and payment card
network fees charged or received in connection with electronic debit transactions. (Section 1075)

1/20/11

Report on OTS Transition Plan. On January 25, 2011, the Board, OTS, OCC, and FDIC
issued a joint report to Congress and the Inspectors General of the participating agencies on the
agencies’ plans to implement the transfer of OTS authorities. (Section 327)

7/21/11

Due
10/19/10

Seq. Description
1.
Study of the Impact of Credit Risk in Securitization Markets. On October 19, 2010, the
Board issued a report on the potential impact of credit risk retention requirements on
securitization markets. (Section 941)

Table 2. Reports and Studies Under the Dodd-Frank Act

Completed.

Status
Completed.

As of December 5, 2011

Report on Government Prepaid Cards. On July 21, the Board issued a report to Congress on
the use of prepaid cards by government authorities, and the interchange transaction and
cardholder fees charged with respect to such prepaid cards. (Section 1075)

Page 9 of 10

Establishment of the Consumer Financial Protection Bureau (CFPB).The Board has
established a transition team, headed by Governor Duke, to work closely with staff at the CFPB
and at the Treasury Department to facilitate the transition. (Title X, generally)

OTS Transition Initiatives. The Board has made substantial progress in its plans relating to the
transfer of the supervisory authority of the OTS for SLHCs to the Board. (Title III, generally)

Seq. Description
1.
Assistance to the Financial Stability Oversight Council (FSOC). The Board has been
providing significant support to the FSOC. The Board continues to assist the FSOC in designing
its systemic risk monitoring and evaluation process and in developing its analytical framework
and procedures for identifying systemically important nonbank firms and FMUs. The Board also
has contributed significantly to the FSOC’s recent studies and reports. (Title I, generally)

7/21/11

Transfer
date was
7//21/11
Transfer
date was
7/21/11

Various
deadlines

Due

Table 3. Other Implementation Initiatives Under the Dodd-Frank Act

Report on the Use of Credit Ratings in the Board’s Rules. The on July 25, 2011, the Board
issued a report to Congress discussing the review the Board has conducted on the use of credit
ratings in its regulations and sometime thereafter report to Congress. (Section 939A)

Report on Designated Clearing Entities. The Board, CFTC and SEC have approved and soon
will issue a joint report to Congress containing recommendations for promoting robust risk
management standards and consistency in the supervisory programs of the CFTC and SEC for
designated clearing entities. (Section 813)

Ongoing.

Status
Ongoing.

Completed.

As of December 5, 2011

Page 10 of 10

Office of Minority and Women Inclusion. The Board and the Federal Reserve Banks each
have established a formal Office of Minority and Women Inclusion to consolidate and build on
existing equal opportunity and contracting resources. (Section 342)

Federal Reserve Governance, Transparency and Audit Initiatives. On December 1, 2010,
the Board provided detailed information on its public website about more than 21,000 individual
credit and other transactions conducted during the financial crisis. The Board also has provided
on its public website certain audit and related financial information, including audit reports,
financial statements and reports to Congress on the Board’s facilities under Section 13(3) of the
Federal Reserve Act. (Sections 1109 and 1103)

1/21/11

for certain
disclosures

12/1/10

Ongoing.

As of December 5, 2011

Full text of Statements and Speeches of Daniel K. Tarullo : Statement before the Committee on Banking, Housing, and Urban Affairs, United States Senate

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