At the same time, with debt service current and market risk premiums cyclically low, and with the same inability to quantify and measure risk, supervisory criticisms of standards are difficult to justify.
1 This cross-subsidization may now become more difficult if interest rates remain low for a long period of time; the difference between market rates and the rate paid to transaction accounts must be narrow if market rates are close to zero, implying that attracting deposits by offering free payment services would no longer be a profitable strategy.