Banking Law Prof Blog

Fannie, Freddie, & the Fed - A Sunday Announcement

Two of the biggest participants in the U.S. secondary mortgage market, Fannie Mae and Freddie Mac, are experiencing serious repurcussions from the subprime mortgage debacle -- and their problems spill over into financial market drops and general mortgage lending liquidity concerns. 

Today, the Federal Reserve made a special Sunday announcement intended to shore up public confidence in these two major mortgage market players.  The Federal Reserve Bank of New York has been granted special authority to lend to them "to promote the availability of mortgage credit during a period of stress in financial markets."

Link to FRB Announcement:  http://www.federalreserve.gov/newsevents/press/other/20080713a.htm

Link to news story:  http://news.yahoo.com/s/ap/mortgage_giants_crisis

Last week the debate concerned former St. Louis Federal Reserve Bank President Bill Poole who has called for "nationalizing" Fannie Mae and Freddie Mac.

Link: http://www.bloomberg.com/apps/news?pid=20601087&sid=a7NPAG.LEjHQ&refer=home

(ag) July 13, 2008, in Economy/FRB

Fed's New Approach - Shades of FSLIC in the 1980's?

Mergers of underwater thrifts with slightly stronger ones postponed the S&L crisis of the 1980s --- but only for a time; meanwhile, ultimate losses had increased.  Could this be deja vu? Last week, the Fed & Treasury encouraged or arranged for JPMorgan Chase to offer to acquire Bean Steans, the investment firm going down for the third time as a result of the subprime mortgage crisis.

What about good old "moral hazard"?  It's an economic axiom that people take more risk with other people's money than with their own.  Is assisting this deal by guaranteeing $30 billion of Bear Stearns' troubled subprime mortgages rewarding not only Bear Stearns & its shareholders for bad decisionmaking but also JPMorgan Chase, which almost certainly had significant exposure resulting from credit default swaps?

Of course, if you approve of this bailout, you believe that it saves the financial markets from worse problems.  But have we seen the last of struggling giants in need of government assistance?  I think not.  So where does it stop?  Is this type of deal only masking and delaying problems?  And what about the homeowners facing foreclosure?  Should we bail out the big boys and leave mom & dad in the lurch?  But wait, even on the individual mortgage level, how do we separate the real victims from speculators?

This subprime mortgage situation has so many levels of risk-shifting.  It looks like a nation-wide shell game.  Not even the experts have unraveled all the financial machinations that spun out of subprime mortgages, so we still don't know where the actual losses will reside.  And it's impossible to tell when enough government assistance is enough -- and when it simply makes a bad situation worse.

Interesting links:

"In the Fed's Crosshairs:  Exotic Game"  http://www.nytimes.com/2008/03/23/business/23gret.html

" When feds save greedy firms, economy and morality collide" azcentral.com http://www.azcentral.com/news/articles/0323biz-moralhazard0323.html

New development:  Bear Stearns shareholders complain that $2 per share is too low.  JPMorgan Chase may increase its bid to $10, but the regulators reportedly don't like that.

Link:  http://news.yahoo.com/s/ap/20080324/ap_on_bi_ge/jpmorgan_bear_stearns

(ag) March 24, 2008, in Economy, FRB 

Fed Continues Liquidity Support

It's a new year, but the effects of last year's mortgage meltdown linger.  The Federal Reserve is continuing to provide special liquidity support, with the promise of "biweekly TAF auctions for as long as necessary to address elevated pressures in short-term funding markets."  The Term Auction Facility (TAF) is for 28 day credit.  The first two auctions, totaling $30B each, will be conducted Jan. 14 and Jan. 28.  No doubt this action will provide both real and psychological benefits.

Link to announcement:  http://www.federalreserve.gov/newsevents/press/monetary/20080104a.htm

(ag) Jan. 9, 2008, in FRB

The Fed's New HOEPA Regs Are Out for Comment

The Federal Reserve Board today announced that the long-awaited regulations Congress has pushed for to address predatory lending are out for public comment.  The proposed regulations will amend Regulation Z (Truth in Lending) for the purpose of protecting consumers from unfair or deceptive home mortgage lending and advertising practices.

I'll have more to say about this tomorrow after I've had a chance to look at the proposed regulations in  greater detail.

LInk:  http://www.federalreserve.gov/newsevents/press/bcreg/20071218a.htm

(ag) Dec. 18, 2007, in FRB, Predatory Lending

The Federal Reserve Board & the Mortgage Crisis: Using All the Tools in the Box

Last week the Federal Reserve Board pulled out all the stops to address the impact of the subprime mortgage meltdown on the financial markets and the economy.  While the Federal Open Market Committee (FOMC) lowered the target federal funds rate only 25 basis points to 4.25% rather than the more substantial cut Wall Street wanted, the Federal Reserve also lowered the discount rate from 5% to 4.75% and, on Friday, made the announcement that today (Monday, Dec. 17, 2007) it would address liquidity problems by offering $20 billion in 28-day credit through its Term Auction Facility.  This mechanism is not well known, nor is it frequently employed.  Check out the Federal Reserve Board's explanation of how financial institutions can bid for Federal Reserve advances.

Link to Dec. 11, 2007, announcement of FOMC interest rate cut:  http://www.federalreserve.gov/newsevents/press/monetary/20071211a.htm 

Links to announcements of discount rate reductions:  http://www.federalreserve.gov/newsevents/press/monetary/20071211a.htm

http://www.federalreserve.gov/newsevents/press/monetary/20071212b.htm

http://www.federalreserve.gov/newsevents/press/monetary/20071213a.htm

Link to announcement of new liquidity provision: http://www.federalreserve.gov/newsevents/press/monetary/20071214a.htm

(ag) Dec. 17, 2007, in FRB/Economy/Interest Rates

2006 HMDA Data Analysis

The Federal Reserve analysis of 2006 Home Mortgage Disclosure Act (HMDA) data is available on the Federal Reserve website.

The analysis begins with a recap of 2004 and 2005 HMDA data analyses.  One focus of this year's analysis relates to pricing issues in the mortgage market, highlighting differences that vary with type of lender, geographic area, and population group.  Like the 2004 and 2005 HMDA data analyses, the 2006 analysis demonstrates that black and Hispanic borrowers are more likely to obtain a higher interest rate loan than white borrowers.  Other credit factors factor into pricing decisions, but this is a point of concern. 

FRB analysts considered what the data can tell us about the subprime mortgage problems and are able to draw some conclusions, although the 2007 HMDA data will relate more to those issues.

Link:  http://www.federalreserve.gov/pubs/bulletin/2007/pdf/hmda06draft.pdf

(ag) Oct. 1, 2007, in FRB

FOMC Keeps Interest Rates at 5 1/4%

To no one's surprise, the Federal Open Market Committee (FOMC) today announced that it will maintain the target federal funds rate at 5 1/4%.  The vote was unanimous.  The FOMC statement recognized that economic growth was only moderate and the financial markets have been volatile, while core inflation has moderated.  Nevertheless, the FOMC weighs the risk of inflation to be greater than the risk to economic growth. 

Link to FOMC Statement:  http://www.federalreserve.gov/boarddocs/press/monetary/2007/20070807/default.htm

(ag) Aug. 7, 2007, in Economy/Interest Rates.

Senate Confirmation Hearing for 3 Federal Reserve Board Spots

Today, the Senate Banking Committee is holding confirmation hearings for two new potential Federal Reserve Governors and for current Governor Randall Kroszner's reappointment. 

Link to Senate Banking Committee posting, with resumes:  http://banking.senate.gov/index.cfm?Fuseaction=Hearings.Detail&HearingID=275

(ag) Aug. 2, 2007, in FRB

Minority Owned Financial Institutions

Federal Reserve Governor Randall Kroszner today delivered a speech entitled "Federal Reserve Initiatives to Support Minority-Owned Institutions and Expand Consumer  Protection" before the Interagency Minority Depository Institutions National Conference, Miami, Florida.

Did you know that there are currently 200 minority-owned financial institutions?

Link:  http://www.federalreserve.gov/boarddocs/speeches/2007/20070801/default.htm

(ag) Aug. 1, 2007, in FRB

What's Up With Bank Consolidation?

The St. Louis Federal Reserve Bank has assembled an instructive analysis of the bank consolidations over the past twenty years.  Today, the number of banking organizations is about half what it was in the 1980s.  Check out this on-line publication.

Link:  http://www.stlouisfed.org/publications/ar/2006/presmes.html

(ag) July 30, 2007, in FRB

Members of Congress Concerned About Reg B

Three members of Congress -- Melvin Watt (D-NC), Chairman of the House Financial Services Subcommittee on Oversight and Investigations; Carolyn Maloney (D-NY), Chairman of the Subcommittee on Financial Institutions & Consumer Credit; and Barney Frank (D-MA), Chairman of the House Financial Services Committee -- have sent a letter to the Government Accountability Office expressing their concern that the Federal Reserve has decided not to amend Regulation B, which implements the Equal Credit Opportunity Act (ECOA). 

In fact, they're so concerned that they are asking the GAO to conduct its own study of the impact of removing Reg B's prohibition on collecting and publicly reporting of race and gender data for non-mortgage credit. 

Link to letter:  http://www.house.gov/apps/list/press/financialsvcs_dem/press2071707.shtml

(ag) July 18, 2007, in Congress, Consumer Protection, Federal Reserve, Lending Issues

No Requirement to Give a Receipt if Transaction at Electronic Terminal Is $15 or Less

The Federal Reserve Board has approved a Final Rule amending Regulation E, which implements the Electronic Funds Transfer Act (EFTA).  Receipts will no longer be required to be provided to consumers for transactions at electronic terminals when the amount is $15 or less. 

The rule change facilitates the use of debit cards in retail environments where it may not be practical or cost effective to generate receipts.

Link:  http://www.federalreserve.gov/boarddocs/press/bcreg/2007/20070628/default.htm

(ag) June 28, 2007, in Reg E/FRB

"The Key to the Gold Vault"

Some interesting tidbits from a pdf booklet on the New York Federal Reserve Bank website:

• The Federal Reserve Bank of New York stores gold bullion belonging to 60 foreign central banks and international monetary organizations.  The Fed does not charge foreign countries for holding gold, but it does levy a handling fee when gold enters, is moved within, or is shipped out of the vault.
• That gold is housed in a vault that rests on the bedrock of Manhattan Island -- one of the few foundations adequate to support the weight of the vault, its door, and the gold inside -- 80 feet below street level and 50 feet below sea level.
• In mid-2004, the Fed's vault contained roughly 266 million troy ounces of gold (1 troy ounce is 1.1 times as heavy as the avoirdupois ounce we use for general measurement).  This represents 25 to 30% of the world's official monetary reserves.
• The NY Federal Reserve Bank stores gold in the form of bars that resemble construction bricks and stacks them on wooden pallets like those used in warehouses.  The shape of a bar may indicate whether it was cast in the U.S. or abroad.  Before 1986, bars cast in this country generally were rectangular bricks 7" long, 3 5/8" wide and between 1 5/8 to 1 3/4" thick.  Gold bars cast more recently in the U.S. or abroad are trapezoidal.  Bars from the NY Assay Office have square edges, bars from the Denver Assay Office have rounded sides, and bars from the San Francisco Assay Office have rounded corners.
• The NY Fed's vault holds only a small fraction of the U.S. gold reserves, a majority of which are held in depositories of the Treasury Dept. at Ft. Knox, KY, and West Point, NY.
• If you are still planning your summer vacation, you too could be one of the 25,000 visitors a year to view the NY Fed's Gold Vault.

Link:  http://www.ny.frb.org/education/addpub/goldvaul.pdf

(ag) June 26, 2007, in Federal Banking Agencies/FRB

2 Bankers to Join the Federal Reserve Board?

The CSBS Examiner reports that President Bush intends to nominate two bankers to fill vacant seats on the Federal Reserve Board:  1.  Elizabeth Duke - currently SVP & COO of TowneBank, Suffolk, VA, holds a bachelor's degree from UNC-Chapel Hill and an MBA from Old Dominion University, and previously worked for Wachovia.  If confirmed by the Senate, she would serve until Jan. 31, 2012.

2.  Larry Allan Klane, if confirmed, would serve until Jan. 31, 2010. He is currently President of Global Financial Services of Capital One Financial Corp., McLean, VA.  He has also worked for

Deutsche Bank/Bankers Trust and the Corporate Strategic Planning Department at the Walt Disney Company. He holds a bachelor's degree from Harvard College and an M.B.A. from Stanford University.

3.  In addition, Bush nominated current Federal Reserve Governor Randal S. Kroszner to a new term 14-year term expiring on Jan. 31, 2022.

Pres. Bush has appointed every current member of the Federal Reserve Board.

Link:  http://csbs.informz.net/csbs/archives/archive_137782.html

Fed Reorganization Causes Some Nonlocal Checks to Become Local

Effective July 21, 2007, the Federal Reserve has amended Appendix A to Reg CC to reflect the consolidation of check processing.  This means that within the Atlanta Reserve Bank's District, the transfer of processing operations from the Nashville Branch to Atlanta will reduce the permissible hold time on certain checks which were previously "nonlocal" -- or not drawn on banks within the same processing district, because after consolidation, they will be "local checks".  This results in funds being required to be made available to customers on a shorter schedule for "local checks" rather than a longer permissible hold time for "nonlocal checks".

The Fed also gives advance notice of future consolidation in the second half of 2007.  Because these changes will require new customer notices and procedure changes, the Fed will publish amendments relating to those consolidations sixty days before the effective date.

All these consolidations result from reduced volume in paper checks to be processed.

LInk:  http://www.federalreserve.gov/BoardDocs/Press/bcreg/2007/20070515/default.htm

(ag) May 16, 2007, in Federal Banking Agencies/FRB

The U.S. Payments System at a Crucial Juncture

Federal Reserve Governor Randall S. Koszner addressed the 2007 Payments Conference hosted by the Federal Reserve Bank of Chicago on Competitive Forces Shaping the Payments Environment: What's Next?

It's not new news that paper checks are losing ground to debit cards, electronic check conversion, and electronic payment.  In response, the Federal Reserve has reduced the number of its check processing centers.  As the Federal Reserve now prices its services to encourage the use of electronic check clearing, the role of the Fed in the payments system will necessarily change.  Governor Koszner stressed the interaction between technology and regulation.  Looking to the future, the two biggest challenges are fraud and data security. 

(ag) May 11, in Federal Banking Agencies/FRB

Barney Frank's Advice to Ben Bernanke

Recognizing that the Federal Reserve Chairman's position is structured as a 12-year term to preserve independence from an excess of political influence from Congress or the President, Congressman Barney Frank, nevertheless, had some interesting views he hopes Ben Bernanke will take to heart. 

Here's the link to the full text of the Speech to the National Press Club, available on Congressman Frank's House Website:  http://www.house.gov/frank/pressclub07.html

Here are some highlights of remarks focused on the Federal Reserve:

" MODERATOR: How does the Federal Reserve fit into your agenda? How do you think the Fed should change, if it should?

FRANK: Well, one, I think we should be able to talk about it more. . . . there are people in this country who think that the Fed somehow should be above democracy. . . .I mean, I remember talking to some people in the Clinton administration: Oh, we can't discuss interest rates.

I mean, we can debate whether Terri Schiavo's life should be recognized as over. We can debate abortion. We can debate wars in Iraq. We can debate the most fundamental questions in human existence, but God forbid anybody in elected office should talk about whether or not we need a 25-basis point increase in the Fed. Somehow, that's sacrosanct. No, it isn't. It's public policy.

One, I don't want a change. There are people who have been arguing that the Fed should have its mandate changed, that the Humphrey-Hawkins Act, which says it should deal both with stable prices and maximum [employment], that that should be changed, and it should just go to stable prices.  That's not going to happen when we're in power. And we can prevent that from happening.

Secondly, though, they have to pay more attention to wages. And I'm hoping that Ben Bernanke will recognize this. The last report we got -- the Fed comes and testifies before both houses twice a year and they present a report, the Humphrey-Hawkins report. . . . .There were 13 sections about this part of the economy, that part of the economy. In 12 of the sections, they talked about the economy in real terms, i.e. adjusted for inflation. . . . .Then they got to wages, and wages were not adjusted for inflation. They talked about nominal, i.e. they made wages look bigger than they are.

I think the Fed could show a little more social sensitivity to this. . . .I think the danger will be this . . .: Wages may now be starting to rise, real wages. One, they've been depressed for so long, there's a natural tendency for that to happen. Inflation, if it stays down, allows real wages to go up.  What I fear is that respected opinion, including the financial pages of some of our liberal newspapers, will start worrying that wages are going up. And oh, if wages go up, that's bad.

If corporate profits go up, that's a good thing. If wages go up, that's a bad thing. That's the basic received wisdom which I'm trying to change.  But what I'm afraid is that the Fed will join in this and that you will have people in the Fed saying, well, geez, wages are going up; we better raise the interest rates. And I talk about war on wages.

My fear is that, if we look at past practices, the Fed will be tempted to blame real wage increases, which are long overdue and which could be considerable for some time and still not have caught up, and they'll blame that as the reason for cutting back. So that would be my concern. "

(ag) Feb. 20, 2007, in Congress, Economy, Federal Banking Agencies

Paper Checks on the Way Out

The American Banker reports today that, according to Federal Reserve officials speaking at the Bank Administration Institute's 2007 conference this week in Orlando, Florida, by 2010 the Federal Reserve will only support Check 21 - no more processing of paper checks.  Other Fed officials say this date is not firm, but a prediction based on the decreased number of checks and the Fed's charge to price services according to cost. 

In an immediate move, the Fed will continue shutting down and consolidating check processing centers.  The Fed will also cut out 20% of its nightly air-transport services.  Eventually, there may be only one central check-processing center, reducing funds availability time frames so that all checks nation-wide can be processed within the current 2-day availability for local checks.

Check out the Feb. 15, 2007, American Banker Article, "Fed to Cease Carrying Paper Checks by '10" by Steve Bills.

(ag) Feb. 15, 2007, in Federal Banking Agencies - FRB

Bies Resigns from Federal Reserve Board

Susan Schmidt Bies submitted her resignation today, effective March 30, 2007.  She had served on the Board of Governors for the Federal Reserve since Dec. 7, 2001.  She will not attend the March meeting of the Federal Open Market Committee (FOMC). 

Link:  http://www.federalreserve.gov/BoardDocs/Press/other/2007/20070209/default.htm

(ag) Feb. 10, 2007, in Federal Banking Agencies/FRB

Explaining What the Fed Does

Federal Reserve Chairman Ben Bernanke is out on the speaking circuit again after the holidays.  His first talk for 2007 was a presentation to the Allied Social Science Association Annual Meeting in Chicago on January 5, 2007, entitled "Central Banking and Bank Supervision in the U.S."  For those teaching Banking Law this would be a good resource.  For the rest of you, it's a good perspective.

As we look back over 2006 and forward to 2007, the new Federal Reserve Chairman is completing his first year -- successfully stepping into some very big shoes!

Link:  http://www.federalreserve.gov/BoardDocs/Speeches/2007/20070105/default.htm 

(ag) Jan. 7, 2007, in Federal Banking Agencies/FRB

Reg O Revisions

The Federal Reserve has adopted an Interim Rule, eliminating some Regulation O (loans to insiders) reporting requirements.  The Interim Rule is effective immediately upon Federal Register Publication -- but FRB seek comments for 30 days.  This Interim Rule does not change substantive Reg O requirements, but merely fulfills the statutory mandate of the Reg Relief Act to reduce regulatory burden on banks.

Link to Dec. 6, 2006, Press Release:  http://www.federalreserve.gov/BoardDocs/press/bcreg/2006/200612062/default.htm

(ag) Dec. 8, 2006, in FRB/Lending Issues/Reg Relief

Fed Final Rule for Customer Authorization to Electronically Collect Return Check Fee

FRB has a new Final Rule amending Reg E with regard to notices and customer authorization required when a merchant electronically collects return check fees.  The Final Rule is effective Jan. 1, 2007, except for certain provisions dealing with POS notices -- with a delayed effective date of Jan. 1, 2008.

FRB also requests comments on a proposal to exempt transactions under $15 from the Reg E requirement to provide a receipt.  It's a 60 day comment period.

Link:  http://www.federalreserve.gov/boarddocs/press/bcreg/2006/20061127/default.htm

(ag) Nov. 28, 2006, in Federal Banking Agencies - FRB

Who Will Be Who at the Federal Reserve Banks

The Federal Reserve has announced the Chairmen and Vice Chairmen of all twelve Federal Banks for terms beginning in January 2007:

Link:  http://www.federalreserve.gov/BoardDocs/Press/other/2006/20061117/default.htm

(ag) November 21, 2006, in Federal Banking Agencies

JPMorgan Chase Gets a Spot on the NY Fed's Board

Jamie Dimon, President and CEO of JPMorgan Chase, was named today as a Class A Director of the Federal Reserve Bank of New York.  His three-year term begins January 2007. 

The New York Federal Reserve Bank has nine directors.  Three are Class A Directors, elected by the Fed member banks in the NY District and drawn from the banking community.  Three are Class B Directors, drawn from the community outside banking and elected by the Fed member banks in the NY District.  Three are Class C Directors, drawn from the community outside banking and appointed by the Federal Reserve.

Lee C. Bollinger, President of Columbia, was appointed as a Class C Director and Indra K. Nooyi, President and CEO of PepsiCo, Inc. has been reelected as a Class B Director for a three-year term beginning in January 2007.

(ag) Nov. 20, 2006, in FRB

Why Are the Federal Reserve Banks Important?

FRB Vice Chairman Donald Kohn delivered an address to the American Bar Association's Banking Law Section in Washington, D.C.,  yesterday.  In remarks entitled "The Evolving Role of the Federal Reserve Banks", Kohn noted that the reduced use of paper checks in favor of credit/debit cards and electronic payments has cut back significantly on the amount of check clearing conducted by the Federal Reserve Banks.  Nevertheless, Kohn stresses the importance of the Federal Reserve Banks as independent sources of regional economic information for the Board of Governors.

Link to speech:  http://www.federalreserve.gov/BoardDocs/Speeches/2006/20061103/default.htm

(ag) Nov. 4, 2006, in Federal Banking Agencies - FRB

Bernanke Talks About CDFIs as a Solution to Market Failures

Fed Chairman Ben Bernanke delivered remarks today to the Opportunity Finance Network's Annual Conference in Washington, D.C.  He stressed the positive contributions of Community Development Financial Institutions (CDFIs) in lending to the otherwise underserved and in promoting homeownership.  When Bernanke talks about CDFIs as a Solution to Market Failures, he is speaking as an economist.  Here's how he explains it: 

"Standard economic analysis tells us that when competitive conditions prevail in a market, the resulting prices induce firms and individuals to allocate resources in a manner that tends to maximize social welfare.  However, economimsts also recognize that various deviations from idealized market conditions, termed market failures, can inhibit the efficient allocation of resources."

For us non-economists, he's saying that low-income people can't always get standard loans -- and that may not be optimal for our economy.  CDFIs concentrate on making loans to underserved borrowers and neighborhoods -- and with that focus, they can be good at what they do.  Bernanke notes in his speech, that loan losses for CDFIs approximates that for commercial banks.

For banks:  Remember that loans to and investments in CDFIs count for CRA purposes!

Link to Speech:  http://www.federalreserve.gov/boarddocs/speeches/2006/20061101/default.htm

If you need more information about CDFIs and what they are, here's a link:  http://www.cdfi.org/whatare.asp

Link to Information about the Treasury Department's CDFI Fund created pursuant to the Reigle Neal Act:  http://www.cdfifund.gov/who_we_are/about_us.asp

(ag) Nov. 1, 2006, in Consumer Protection, Federal Banking Agencies - FRB, Lending & CRA

Fed Chairman Decries Regulatory Burden, Discusses BSA, CRA, Capital Standards (Basel II) and the Reg Relief Act

In remarks delivered Oct. 16, 2006, before the Annual Conventions of the American Bankers Association (in Phoenix) and America's Community Bankers (San Diego, via satellite), Ben S. Bernanke, the relatively new Chairman of the Board of Governors of the Federal Reserve System, looked at bank regulation through an economist's lens:  cost benefit analysis.  That's good new for bankers.  He appears to be a proponent of reducing regulatory burden. 

Bernanke talked specifically about three key areas bankers often complain about:  BSA, CRA, and Capital Standards.  He also highlighted the following provisions of the Regulatory Relief Act:  authority for the Fed to pay interest on sterile reserves and discretion to lower the reserve ratio (although unfortunately, not effective until 2011); authority for the Fed to pay interest on voluntary deposits with the Fed, including contractual clearing balances and excess reserve balances;  immediately raising the asset ceiling from $250M to $500M for banks that can qualify to extend the exam cycle from 12 months to 18 months if they are well-capitalized and well-managed; and the requirement for the Fed and the SEC to issue joint regulations regarding "broker" exceptions for banks under GLBA.

Link to Speech:  http://www.federalreserve.gov/boarddocs/speeches/2006/20061016/default.htm

(ag) Oct. 17, 2006, in Federal Banking Agencies - FRB, Regulatory Relied, BSA, CRA, Capital Requirements (Basel II)