The Board’s website has select interpretations of many laws but does not provide a comprehensive, userfriendly collection of regulatory interpretations, FAQs, and commentary. Fourth, I endorse putting significant supervisory guidance out for public comment. The Board already invites comments on its regulations, as required under the APA, and regularly invites comment on some supervisory guidance and statements of policy.
This practice of seeking comment on significant guidance leads to better, more informed supervision and better engagement by banks. And fifth, the Board should adopt a rule on how we use guidance in the supervisory process. I would expect the rule to state that the Board will follow and respect the limits of administrative law in carrying out its supervisory responsibilities.