If, as I believe, it is critical that systemic risk and too-big-to-fail problems be substantially reduced, the test for any regulatory reforms must be whether they accomplish this goal, not simply whether they are useful supplemental measures. Thus the third task for regulatory agencies is to think now about other possibilities, even as we work to implement this wellconsidered agenda.
No more than a fifth of the banks under our direct supervision have set a key risk indicator for C&E risks in their risk appetite statement and only about a third of these have set a concrete limit on these indicators.