Insofar as publicly traded banking organizations are required by securities laws to file consolidated, U.S. GAAP-consistent financial statements, there is both a parallelism between accounting and capital regulation and a measure of economy in the compliance costs of a consolidated capital rule. In contrast, most insurance firms subject to our regulation only because they own depository institutions do not produce consolidated financial statements.
Furthermore, Congress has prohibited the Federal Reserve from requiring insurance firms that file only Statutory Accounting Principles (SAP) financial statements to produce U.S. GAAP consolidated financial statements.