First, the SCB proposal would have included four quarters of dividends in a firm's SCB, in recognition of the fact that firms experience market pressure to hold dividends constant, even under stress. In my view, there may be ways of encouraging greater reliance on less sticky repurchases while providing more flexibility in the regime, and we are exploring alternatives.
Last, the SCB proposal would have included a post-stress leverage requirement. As the Federal Reserve has long maintained, leverage requirements are intended to serve as a backstop to the risk-based capital requirements. By definition, they are not intended to be risk-sensitive.