Neither we nor shareholders should be comfortable with a process in which strategic decisions are made in one silo, risk-appetite setting in another, and capital planning in yet a third, with the convergence of these efforts coming together only when it is too late for each to affect the other, or for the board to be able to exercise effective oversight.
These major decisions need to be made in an integrated manner. 12  Indeed, insured depository institutions are prohibited by statute from making any capital distribution that would render the firm undercapitalized. 12 U.S.C. §1831o(d)(1). 13  Beverly Hirtle (2014), “Bank Holding Company Dividends and Repurchases during the Financial Crisis,” Federal Reserve Bank of New York Staff Report No.