Although the law dictates the most material consequences of an unsatisfactory management rating, we have the authority to define that rating and its calibration, as well as to define any additional supervisory consequences that are not prescribed in the law. I believe it is well worth our while to consider this calibration.
Accordingly, I have directed Board staff to look into the following issues: First, the placement of the qualitative elements of our ratings frameworks. There is somewhat more discretion in applying these elements relative to the quantitative regulatory requirements. These elements traditionally have been spread across all the ratings components, including capital and liquidity. Is this the best placement?