Let me be clear, however, that while I am advocating a simplification of large bank loss absorbency requirements, I am not advocating an enervation of the regulatory capital regime applicable to large banking firms.
Although not a post-crisis regulation, the Board’s complex and occasionally opaque framework for making determinations of control under the Bank Holding Company Act (BHC Act) is another area that is ripe for re-examination through the lenses of efficiency, transparency, and simplicity.