Markets see duration risk as a potential source of portfolio losses, so they want to hedge against it, and the compensation for hedging is precisely what we call the term premium. If this premium is high, it makes long-term borrowing more expensive than short-term borrowing.
Let me take a minute to highlight some of the key proposals addressed in the ANPR. First, we propose a CRA evaluation framework that incorporates the use of metrics and tailored standards that take into account differences across local communities and reflect differences in bank size and business model.