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Is There a Process Approach to Regulation?
The focus on process is really an innovation from the 1990s. It's part of what I think is the toxic brew of regulatory supervisory policies that brought us the 2008 crisis. And we still sort of have supervision guided by this 90s approach. The SBB failure is one of several significant examples of post-2008 supervisory failure, where the supervisors are still focused on process and too unwilling to make substantive judgments.