Capital buffers, though not easy to design or implement in an  1  See Daniel K. Tarullo (2009), "Regulatory Restructuring," statement before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate, July 23; and Daniel K. Tarullo (2009), "Modernizing Bank Supervision and Regulation," statement before the Committee on Banking, Housing, and Urban Affairs, U.S. Senate, March 19.
2  BIS Review 95/2009  efficacious fashion, could be an especially important step in reducing the procyclical effects of the current capital rules. Further review of accounting standards governing valuation and loss provisioning also would be useful, and might result in modifications to the accounting rules that reduce their procyclical effects without compromising the goals of disclosure and transparency.