CongressionalHearings/Dodd-Frank/CHRG-111shrg54533/CHRG-111shrg54533--89.txt Having the Federal Reserve become the systemic risk regulator for all large financial institutions concentrates enormous power in one agency . CongressionalHearings/Dodd-Frank/CHRG-111shrg54789/CHRG-111shrg54789--185.txt This authority would extend to business practices , including compensation practices that push consumers to purchase inappropriate products and services . CongressionalHearings/Dodd-Frank/CHRG-111shrg54789/CHRG-111shrg54789--185.txt Mr. Yingling claims that the creation of the CFPA will result in a `` potentially massive new regulatory burden . '' CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--16.txt You have people asking for collateral which does n't exist at the holding company level , which the State regulators do not regulate . CongressionalHearings/Dodd-Frank/CHRG-111shrg53085/CHRG-111shrg53085--2.txt That must be our goal , not only today but in the coming weeks , as we are charged with the responsibility of modernizing the Federal financial regulations . CongressionalHearings/Dodd-Frank/CHRG-111hhrg55809/CHRG-111hhrg55809--198.txt But on the enforcement side , the Federal Reserve takes what we call a risk-focused approach , jargon for saying that we put more resources where there are greater dangers . CongressionalHearings/Dodd-Frank/CHRG-111hhrg53248/CHRG-111hhrg53248--27.txt We have an opportunity to bring about fundamental change to our financial system , to provide greater protection for consumers and for businesses . CongressionalHearings/Dodd-Frank/CHRG-111shrg56415/CHRG-111shrg56415--246.txt State credit union regulators are cognizant of credit unions ' future financial performance as commercial credit problems begin to affect consumer credits . CongressionalHearings/Dodd-Frank/CHRG-111shrg52619/CHRG-111shrg52619--175.txt The states also encourage industry participants to adopt these standards as part of an institution 's ongoing internal review process . CongressionalHearings/Dodd-Frank/CHRG-111shrg53085/CHRG-111shrg53085--213.txt First , federal bank regulators are n't well-suited to address conduct issues of operating subsidiaries of national banks in local and state markets . CongressionalHearings/Dodd-Frank/CHRG-111hhrg52406/CHRG-111hhrg52406--184.txt Mr. Plunkett , '' Good afternoon , Mr. Chairman , and members of the committee , and Ranking Member Bachus . CongressionalHearings/Dodd-Frank/CHRG-111hhrg52406/CHRG-111hhrg52406--47.txt Mr. Mierzwinski , '' Mr. Chairman , I think that Ellen Seidman 's testimony makes some very good points about some of the issues that are framed with moving the agency . CongressionalHearings/Dodd-Frank/CHRG-111hhrg53241/CHRG-111hhrg53241--21.txt First of all , NAAHL supports Chairman Frank 's decision to preserve the bank regulators ' role to enforce the Community Reinvestment Act -LRB- CRA -RRB- . CongressionalHearings/Dodd-Frank/CHRG-111shrg52966/CHRG-111shrg52966--73.txt --------------------------------------------------------------------------- Proper risk governance was a key focus of guidance that the OCC , the SEC , and other Federal banking regulators issued in January 2007 on complex finance activities . CongressionalHearings/Dodd-Frank/CHRG-111shrg50815/CHRG-111shrg50815--120.txt There is no reason to expect that consumers will have significantly less access to credit or fewer choices because of the Fed 's new rule . CongressionalHearings/Dodd-Frank/CHRG-111shrg56415/CHRG-111shrg56415--83.txt Finally , I will address the Federal Reserve 's regulatory and supervisory responses to these challenges.Conditions in Financial Markets and the Economy Conditions and sentiment in financial markets have continued to improve in recent months . CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--33.txt Chairman Dodd , '' It is very -- '' Mr. Kohn , '' -- and they became counterparties to Maiden Lane III as part of the government 's effort to stabilize AIG . '' CongressionalHearings/Dodd-Frank/CHRG-111shrg51290/CHRG-111shrg51290--67.txt Federal Law Following deregulation of home mortgages in the early 1980 's , disclosure became the most important type of Federal mortgage regulation . CongressionalHearings/Dodd-Frank/CHRG-111shrg51290/CHRG-111shrg51290--67.txt The Regulatory Story : Race to the Bottom Federal banking regulators added fuel to the crisis by allowing reckless loans to flourish . CongressionalHearings/Dodd-Frank/CHRG-111shrg51290/CHRG-111shrg51290--67.txt The Federal Reserve Board The Federal Reserve Board had the statutory power , starting in 1994 , to curb lax lending not only for depository institutions , but for all lenders across-the-board . CongressionalHearings/Dodd-Frank/CHRG-111shrg52966/CHRG-111shrg52966--71.txt The Federal Reserve is also the primary Federal supervisor of State-member banks , sharing supervisory responsibilities with State supervisory agencies . CongressionalHearings/Dodd-Frank/CHRG-111shrg382/CHRG-111shrg382--18.txt We are talking about bank insolvency law under the FDI Act , things that the Congress and parliaments around the world have put into legislation . CongressionalHearings/Dodd-Frank/CHRG-111hhrg52406/CHRG-111hhrg52406--31.txt The States are close to the investing public and have time and time again demonstrated that they can act quickly and effectively to help investors . CongressionalHearings/Dodd-Frank/CHRG-111shrg54789/CHRG-111shrg54789--180.txt As discussed briefly above , the CFPA should also have the authority to grant intervener funding to consumer organizations to fund expert participation in its stakeholder activities . CongressionalHearings/Dodd-Frank/CHRG-111shrg54789/CHRG-111shrg54789--189.txt Poor regulation of abusive credit products by Federal regulators over many years has led to exactly the result that Mr. Yingling and Mr. Wallison are concerned about : credit rationing . CongressionalHearings/Dodd-Frank/CHRG-111shrg54675/CHRG-111shrg54675--81.txt Community banks under $ 1 billion in assets make over 60 percent of all agricultural loans extended by the commercial banking sector . CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--174.txt To mitigate these risks , the Treasury provided equity capital to AIG and the Federal Reserve provided liquidity support backed by the assets of AIG . CongressionalHearings/Dodd-Frank/CHRG-111shrg53085/CHRG-111shrg53085--207.txt Since we have not contributed to the problem , we would like not to pay a big price for the answer to a question that barely exists in our industry . CongressionalHearings/Dodd-Frank/CHRG-111hhrg48874/CHRG-111hhrg48874--205.txt These are the areas I ask Congress to focus on going forward so that when economic conditions improve , institutions will return to the securitization markets . CongressionalHearings/Dodd-Frank/CHRG-111hhrg48874/CHRG-111hhrg48874--205.txt Congress could potentially play a role in the oversight of the FASB due process , but I think we want to stress the importance of independence in the standard-setting model . CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--176.txt AIG 's securities lending activities began prior to 2000 , Its securities lending portfolio is owned pro-rata by its participating , regulated insurance companies . CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--176.txt My testimony will focus primarily on AIG , the holding company , and AIG Financial Products -LRB- AIGFP -RRB- . CongressionalHearings/Dodd-Frank/CHRG-111shrg51303/CHRG-111shrg51303--176.txt I will describe some lessons learned from the rise and fall of AIG , and offer my opinion , in hindsight , on what we might have done differently . CongressionalHearings/Dodd-Frank/CHRG-111hhrg54868/CHRG-111hhrg54868--136.txt Mr. Dugan , '' We have something called our account management guidance that applies to all credit card providers . CongressionalHearings/Dodd-Frank/CHRG-111shrg56376/CHRG-111shrg56376--127.txt The Treasury Proposal would make these types of firms subject to the Bank Holding Company Act and supervision by the Federal Reserve Board . CongressionalHearings/Dodd-Frank/CHRG-111hhrg48874/CHRG-111hhrg48874--12.txt The Federal Reserve has also been active on the supervisory front to bring about improvements in banks ' risk-management practices . CongressionalHearings/Dodd-Frank/CHRG-111shrg52619/CHRG-111shrg52619--199.txt Specifically , to address concerns about `` loan flipping '' the Board prohibited a HOEPA lender from refinancing one of its own loans with another HOEPA loan within the first year unless the new loan is in the borrower 's interest . CongressionalHearings/Dodd-Frank/CHRG-111shrg52966/CHRG-111shrg52966--75.txt The theory is that as financial institutions write down assets to current market values in an illiquid market , those losses reduce regulatory capital .