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On September 28, 2015, Governor Daniel K. Tarullo spoke on
"Capital Regulation Across Financial Intermediaries" at
the Banque de France Conference on Financial Regulation entitled
"Stability versus Uniformity; A Focus on Non-bank
Actors." In the speech, Governor Tarullo remarked on the
importance of relying on more than quantitative measures when
establishing regulatory requirements for non-bank financial
institutions. He stated that "simply deciding that an
intermediary provides mostly commercial banking services or
insurance products does not fully answer the question of what its
capital requirement should be." As an example of a rule in
which a more nuanced approach was taken, he pointed to the use of
short-term wholesale funding measures in the US G-SIB surcharge
requirement.
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