A year and a half ago, we proposed setting the threshold at $ billion or more in total banking assets or $ billion or more in foreign banking assets. The criteria in the forthcoming notice of proposed rulemaking are unlikely to differ materially from those levels.
At the same time, U.S. regulators - especially those among us who spent the greater part of our careers as bankers - are very sensitive to the competitive implications of having two sets of rules for the banking industry.