In that case, the operation of the buffer would not result in a proportional restriction of income as the firm's capital eases, but could be a sudden cessation of all dividends if the firm dips into the buffer by even a small amount, even if the changes in its capital levels are quite minor.
We are considering adjustments that would make the rules more consistent with the graduated intent. We plan to work with the other banking agencies to consider how best to effect this change. There are two additional elements of the SCB proposal that I believe would benefit from modification.