In addition, the MCA requires the Federal Reserve Banks to recover imputed costs, such as taxes and the cost of capital, and imputed profits that would have been earned if the services were provided by a private firm. Importantly, the MCA also extended reserve requirements to nonmember banks and granted all banks equal access to the Fed’s payment services.
•  It takes a deep understanding of an institution’s operations and appetite for risk for its significant activities;  •  It takes frequent interaction with regulated institutions at both board and management levels;  •  It takes a capacity to assess the effectiveness of risk management and control functions, (including how the institution is governed and the prevailing risk culture); and,  •  It takes a capacity and willingness to act when inadequacies are identified.