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St. Louis Fed's Bullard Addresses "Containing Risk in the New
Global Financial Landscape"
4/15/2010
NEW YORK — In remarks today to the 19th Annual Hyman P. Minsky Conference, St.
Louis Fed President James Bullard assessed the state of the regulatory reform
debate. In his presentation, “Containing Risk in the New Global Financial Landscape,”
Bullard said, “As the nation’s lender of last resort, the Fed will be at the center of
managing any future nancial crisis and this argues for the Fed playing the lead role in
the new regulatory structure. A future Fed with an appropriately broad regulatory
authority provides the U.S. with the best chance of avoiding a future crisis.”
He also described how current regulatory reform proposals are not adequately
addressing several key issues that could contribute to future nancial crises. “Only a
few of the current nancial reform proposals are likely to help prevent future crises,
most are not,” said Bullard. These issues include the susceptibility of non-bank nancial
rms to “run-like” phenomena; the existence of large nancial rms worldwide that are
“too big to fail;” the question of how any form of regulation could prevent an entire
industry from adopting the same strategies, and addressing government-sponsored
enterprises (GSEs).
Beyond Banking, Considering the Entire Financial Landscape
Bullard emphasized the critical need to consider the entire nancial landscape rather
than just the banking sector. “The crisis encompassed a far larger segment than just
commercial banking,” Bullard said. “Many non-bank nancial rms, outside the banking
sector, were at the heart of the crisis. These rms were not regulated by the Fed.”
He added, “As the crisis started in the fall of 2007, 20 rms accounted for about 80
percent of nancial sector assets in the U.S.” He noted that about one-third of this total
was comprised of bank holding companies, with two-thirds comprised of non-bank
nancial entities such as the GSEs (Fannie Mae and Freddie Mac), investment banks,
insurance companies, and thrifts.
“The non-bank nancials are a ‘who’s-who’ of the most nettlesome entities during the
crisis,” he added. “All of these rms faced severe stress during the crisis, regardless of
the type of rm or the nature of regulation,” he said. “This is generally true globally as
well. All were taken in by the allure of securitized products in various ways.”
Bullard questioned whether current regulatory reform proposals would help prevent a
similar scenario from happening again. “How can we prevent an entire industry from

adopting the same strategy?” he asked. “I do not see this being addressed in current
proposals.”
The View from the Fed
Bullard explained that the U.S. has a primary regulator system for the nation’s more
than 8,000 commercial banks and thrifts. “The primary regulator has the key authority
for the regulation of the bank,” he said. “Before the crisis (as of January 2007), the Fed
had primary regulatory responsibility for about 12 percent of the banks, or about 14
percent by assets.”
The remaining 85 percent of banks and assets had non-Fed primary regulators, he
noted. Then, as the crisis unfolded, all eyes turned to the Fed as the lender of last
resort. Due to its narrow regulatory authority, the Fed’s view of the nancial landscape
was limited coming into the crisis. “This made it harder to perform its lender-of-lastresort role,” Bullard said, “And, this led to a lot of ad hoc decision-making.”
A Wall Street-Only Fed?
Bullard called for a strengthened central bank and cautioned against some current
regulatory reform proposals that seek to create a “Wall Street-only” Fed. “The Fed
should remain involved with community bank regulation so that it has a view of the
entire nancial landscape,” he said. “It is important that the Fed does not become
biased toward the very large, mostly New York-based institutions.”
Bullard explained that one critical role of regulation is to “provide a level, competitive
playing eld for institutions of all sizes. Community banks tend to fund smaller
businesses, an important source of job growth for the economy. Understanding this
process helps the Fed make sound monetary policy decisions.”
He added, “Regulation works well for the thousands of community banks in the
U.S. The system features deposit insurance plus prudential regulation. The system
allows failure—capitalism at work—but prevents bank runs and the associated
panic. Community banks did not cause the crisis and do not need to be re-regulated.”
“The central bank must be well-informed about the entire nancial landscape in order to
head off a future crisis. The reform response should be to provide the Fed with an
appropriately broad regulatory authority,” Bullard concluded.
###
With branches in Little Rock, Louisville and Memphis, the Federal Reserve Bank of St.
Louis serves the Eighth Federal Reserve District, which includes all of Arkansas, eastern
Missouri, southern Indiana, southern Illinois, western Kentucky, western Tennessee and
northern Mississippi. The St. Louis Fed is one of 12 regional Reserve banks that, along
with the Board of Governors in Washington, D.C., comprise the Federal Reserve System.
As the nation's central bank, the Federal Reserve System formulates U.S. monetary
policy, regulates state-chartered member banks and bank holding companies, provides
payment services to nancial institutions and the U.S. government, and promotes
community development and nancial education.

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