Written guidance may allow for risk-based or more tailored approaches, but a number of factors contribute to what the Treasury Department recently described as, “more stringent de facto regulation.” In particular, Treasury raised concerns that banks that are worried about criticism from examiners might, “adopt a more uniformly stringent vendor oversight approach rather than trying to convince their examiners to permit a more tailored approach to vendor oversight.” 21 And this may ultimately deter banks from trying to explore how they should be adapting their business strategies in light of technological change.
The Bank judged it appropriate to introduce the monetary base as the main operating target for money market operations in order to communicate its policy stance clearly to the markets and the public as well as to enhance policy effects.