Speech, Federal Reserve Board Governor Sarah Bloom Raskin At the Ohio Bankers Day, Columbus, Ohio, June 6, 2013. Let’s Move Forward: The Case for Timely Implementation of Revised Capital Rules: “There is significant justification for both higher levels, and higher quality, of capital. In particular, we have seen that highly capitalized banks are more likely to maintain their lending activity through good times and bad, as evidenced during the recent crisis, a trend that helps their customers and the overall economy. A framework requiring higher quality and quantity of capital should be established post-haste. At the same time, however, for community banks in particular, more and better capital should be achieved without significantly increasing the complexity of capital calculations. It is not only possible and desirable, but also necessary, to ensure that our capital requirements for community banks remain relatively simple and effective. Otherwise, we risk drowning banks in a capital adequacy system that is so complex that it both misses the mark of addressing meaningful emerging risks and piles regulatory costs on banks with no public benefit. I should note here that the proposed Basel III rules include complex models-based approaches for internationally-active banks and for banks with significant trading activities. These models-based approaches are clearly inappropriate for, and will not apply to, community banks.”
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