Bowman, Supervisory Modernization After Silicon Valley Bank
美联储理事Bowman在讲话中介绍新发布的硅谷银行（SVB）倒闭独立评估初步结论，指出监管者早在FDIC接管前至少九个月就已掌握该行利率与流动性风险信息，却未及时采取行动。
Bowman借独立评估的初步结论说明监管及时性与问责缺口，并列出美联储正在考虑的决策框架调整方向，同时批评国际标准机构沿用不完整报告。
报错 · 内容有误？请告诉我们。
感谢邀请我今天与你们相聚。很高兴与你们一起讨论如何确保全球金融体系能够适应不断变化的经济环境。1 变化的步伐一直很快。我们的金融体系正在迅速演变。因此，重要的是我们要定期审视监管和监督框架，思考如何最好地跟上这种演变。
今天，我将讨论监管现代化的三个相关方面。首先，我将介绍从新发布的关于硅谷银行（SVB）倒闭的独立评估中汲取的一些教训，这些教训涉及及时采取监管行动的重要性。其次，我将讨论美联储如何提高我们的监管有效性，以使决策权限清晰，并让检查人员对及时采取行动承担更多责任。第三，我将描述现代化如何改善世界各地的监管工作，包括在巴塞尔银行监管委员会（BCBS）和金融稳定委员会（FSB）等标准制定机构的指导下。
硅谷银行独立审查
2023年SVB的倒闭是一个案例研究，为国内外银行监管者提供了关键教训。虽然此前关于SVB的报告提供了重要信息，但这些报告是在有限范围内快速编制的，未能全面处理与倒闭相关的重要数据。因此，这些报告并不完整，并使一些不可靠的结论得以延续。这就是为什么今年早些时候，我委托对该银行倒闭及美联储相关监管进行独立审查。该审查填补了此前的空白，并纠正了关于SVB倒闭的重要错误印象。其初步调查结果证实了有关美联储系统监管未能及时采取行动以及未能向SVB传达可操作指导的艰难但重要的批评。
一项核心发现是，监管人员在SVB倒闭前许多个月就已掌握其重大脆弱性的信息，却未加以适当利用。一线检查人员、风险与监督专家以及储备银行和理事会工作人员，至少早在联邦存款保险公司将该银行置于接管状态整整九个月前，就已知晓SVB面临的利率和流动性风险敞口。审查得出结论，长期以来决策权限的不确定性和明确问责的缺失阻碍了及时决策。
初步审查还纠正了早先的错误描述，即社交媒体应对SVB挤兑负责，以及美联储未能采取行动是法定差异化监管或监管变化所致。2相反，报告指出，监管问责和决策方面长期存在的问题，是未能及时发出与核心风险相关的关键执法行动的最重要原因。
及时行动的必要性
监管决策必须以证据、法律授权和判断为依据，但监管决策只有在及时传达时才能发挥效力。当监管者发现新出现的脆弱性时，银行拥有更多选择和灵活性来纠正方向。在弱点刚出现时，银行通常可以逐步减少风险敞口、增强流动性状况、改进应急计划，或在正常市场条件下筹集资本。
但如果监管者长期拖延沟通或行动——不断等待更多证据、更多共识或再开一次委员会会议——监管就会陷入停滞并失去效力。及时且高效的行动是取得成功监管结果的关键。
审查指出，对SVB的监管关注往往集中在流程、程序、治理和控制上，而不是缓解潜在的利率和流动性风险敞口。2019年至其倒闭时，SVB有54项需要关注或立即关注的事项，但这些监管发现没有一项要求该银行解决其核心财务风险。换言之，一个监管机构可能极其忙碌，却仍然未能充分聚焦于最重要的风险。它可以发布许多发现，要求机构花费大量时间和资源整改较不重要的流程相关问题，并在治理和流程上投入巨大资源，却未能迫使机构对最可能威胁其生存的脆弱性采取行动。
监管优先级与问责制
及时行动的监管文化还必须与明确的角色和责任相配套，使监管者有权采取行动。独立评估报告指出，联邦储备系统内部在决策权方面存在不确定性，整个监管体系缺乏问责。在我们的结构中，不同团队识别风险，许多其他方被期望表示同意，却没有任何个人明确承担作出决定并推动行动的责任。
一个现代监管组织需要对以下基本问题给出明确答案：谁拥有推进决策的权力？谁有权采取行动？谁负责确保重大风险得到处理？当组织内不同部门意见不一致时，谁负责解决分歧并持续向前推进？
现代监管组织越来越依赖监测、专家团队和数据分析，这些手段使我们能够识别跨机构的模式。这些能力极具价值。但识别风险只有在
That is why we at the Federal Reserve System are considering ways to enhance our supervisory decisionmaking framework to ensure
- more direct allocation of responsibility, authority, and accountability between the Board and Reserve Bank staff;
- clear decision rights for examiners and supervisory leadership; and
- direct escalation channels from examination teams to senior supervision leadership.
In the fall of 2025, the Board published a Statement of Supervisory Operating Principles clearly stating our expectations about how supervisors should conduct supervision. We have refined those principles, most recently to incorporate lessons learned from the independent review of the 2023 banking stress. Publishing these principles further improves supervisory transparency and accountability. They refocus supervisory efforts on what matters most: early identification of material risks, exercising sound supervisory judgment, and a broad range of supervisory tools to enable timely and proportionate action to address material risks before they threaten the safety and soundness of an institution or the stability of the financial system.
International Implications and Proportionality
The benefits of our supervisory modernization efforts are not limited to the Federal Reserve. They have implications far beyond the United States. Our reforms and the lessons learned from the independent review are equally applicable to supervisors around the world. As chair of the FSB's Standing Committee on Supervisory and Regulatory Cooperation, I have engaged many member jurisdictions to advance the FSB's regulatory and supervisory modernization agenda. The FSB's 2026 work program reflects that countries around the world are also evaluating whether regulatory and supervisory frameworks remain well suited for future financial systems.
There are important common themes in that work. Modernization is not about doing less. It is about more effectively prioritizing the things that matter the most. This includes concentrating on material risks, appropriately tailoring supervisory intensity, periodically reconsidering processes that may have accumulated over time to ensure they are still fit for purpose, and providing clarity so that supervisors can reach decisions quickly enough to make a difference.
Tailoring or proportionality does not mean weaker supervision. It means directing supervisory attention to the risks that are most material given the institution's size, complexity, activities, business model, interconnectedness, and potential impact on financial stability. A community bank engaged in conventional lending and deposit-taking does not require the same supervisory approach as a globally active institution engaged in complex trading and cross-border activities.
The purpose of prioritization is to distinguish issues that are genuinely capable of threatening safety and soundness from matters that may warrant attention but do not present the same degree of financial risk. This distinction requires supervisory judgment. And judgment inevitably requires making choices. A supervisory organization that treats every issue as equally important will tend to devote substantial attention to matters that are easiest to document, measure, and track, leaving other risks that require synthesis, experience, and enhanced judgment to receive less attention than they deserve. The objective should not be to maximize the number of findings that are issued. It should be to identify the risks that matter most and address them while there is still time to alter the trajectory.
International bodies, including the BCBS and the FSB, can help most in this supervisory modernization effort by focusing on their core mandates and by remaining evidence and data driven. They should prioritize work on areas that matter most—issues related to safety and soundness as well as financial stability.
International Lessons Learned
The independent review of SVB shows that international standard-setting bodies, including the BCBS and the FSB, relied unquestioningly on incomplete reports compiled quickly and shortly after the failure of SVB. The independent review found that both the BCBS and the FSB took language nearly verbatim from other reports published in the United States that were not based on complete or accurate information. The independent review determined that these reports from the BCBS and the FSB generally repeated existing claims by other reports rather than independently verifying the information or increasing the breadth of evidence offered in their support.
As a result, the purported lessons learned put forth in the April 2023 report by then–Vice Chair Barr were initially used to justify additional regulatory work, including at the BCBS and the FSB. That work was inherently flawed because it was based on incomplete and faulty initial report findings, not a broader analysis like that provided by the independent review. Now, with the benefit of more comprehensive evidence and analysis, we can see that the international bodies' work based on prior results was not justified.
The BCBS's mandate is to strengthen regulation and supervision practices worldwide with the purpose of enhancing financial stability.3 Similarly, the FSB was established to coordinate and promote effective regulatory, supervisory, and other financial-sector policies in the interest of global financial stability.4 To maintain their credibility, these institutions must redouble their focus on material risks—those that affect safety and soundness or financial stability—while eschewing less valuable work that misdirects resources toward less valuable priorities.
These institutions must also seek to validate data and analysis that is relied upon for international standards and regulations. Simply accepting data and analysis without rigorous validation risks building international standards on flawed foundations, potentially undermining both the effectiveness of regulations and the credibility of these critical institutions.
Refocusing action on issues of material harm will allow these institutions to remain true to their core mandates and serve a more valuable purpose in fostering supervisory modernization.
Conclusion
As we continue to modernize supervision and regulation at the Federal Reserve, and as we work with our international colleagues through the FSB and the BCBS on modernization, we must have the humility to continually reevaluate the effectiveness of our own supervisory processes. We should continue to assess how we make sure our supervisory efforts are keeping pace with a rapidly changing ecosystem. For instance, how do we organize our people to allocate authority and prioritize risks? How do we tailor supervisory intensity and equip our staff to quickly move from identifying a material vulnerability to taking appropriate action?
The financial system will continue to evolve rapidly. Our supervisory institutions must evolve with it. A critical measure of whether that modernization succeeds will be whether supervisors are able to identify the risks that matter and act decisively at the point when their actions can have the greatest impact.
Thank you.
1. The views expressed here are my own and are not necessarily those of my colleagues on the Federal Reserve Board or the Federal Open Market Committee. Return to text
2. The 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act. Return to text
3. See the BCBS's charter, which is available on the Bank for International Settlements' website at https://www.bis.org/committees/bcbs/charter. Return to text
4. See the FSB's charter, which is available on the FSB's website at https://www.fsb.org/uploads/r_090925d.pdf. Return to text
来源：美联储讲话 · federalreserve.gov