Supervision has become increasingly less invasive and increasingly more systems- and policyoriented. These changes have been induced by evolving technology, increased complexity, and lessons learned from significant banking crises, not to mention constructive criticism from the banking community. Regulations, on the other hand, prescribe and proscribe what must be done and what may not be done in specific areas, and most reflect past events.
Many regulations are thus backward-looking, adopted in response to specific problems but often remaining after the problems are resolved. However, public comments, changing market realities, and our internal programs help us to identify regulations that no longer serve public policy objectives. We then update or remove those regulations.