Therefore, as we work to fine-tune and strengthen this framework, I would hope to see the capital surcharge for systemic banking organizations integrated into CCAR to ensure robustness, even as adjustments might be made on other parameters of the framework.
Although today’s greatly enhanced common equity capital requirements should materially reduce the probability that a large bank might fail in response to a severe economic downturn or financial stress, it is not enough to reduce the risks of failure.