However, because it will not take effect in the United States until 2016 and because other regulatory and supervisory tasks created by Dodd-Frank and other initiatives need to be completed more quickly, we have not yet built out this tool through policy statements or other institutional steps.
Fortunately, when we do turn to the countercyclical capital buffer, we should have the benefit of a good deal of thinking and experience by the Bank of England. The setting of countercyclical capital buffers is now committed to the Financial Policy Committee (FPC) under the reorganization of regulatory functions effected in the United Kingdom on April 1, 2013.