Clearly, horizontal reviews –  4  See Board of Governors of the Federal Reserve System, Division of Banking Supervision and Regulation (1991), "Interagency Examination Guidance on Commercial Real Estate Loans," Supervision and Regulation Letter SR 91-24 (November 7); and Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Federal Reserve Board, and Office of Thrift Supervision (1991), "Interagency Policy Statement on the Review and Classification of Commercial Real Estate Loans (814 KB PDF)," joint policy statement, November 7.
In this regard, it is noteworthy that while the term “shadow banking system”6 has taken its place in the lexicon of policymakers alongside “systemic risk” and “financial stability,” comparatively little has been done to regulate the channels of capital flows in which one or both transacting parties lie outside the perimeter of prudentially supervised institutions.