1) Bank and thrift regulators should retain a strong leverage capital standard to generally guard against risks at insured financial institutions, including risks posed by derivative instruments. Regardless of the new risk-based standards that take into account netting, market risk, and interest rate risk, there is no substitute for a strong leverage capital requirement.

2) Comparable rules concerning capital, accounting, disclosure, and suitability should exist whether derivatives activities are conducted by a bank, broker-dealer, insurance company, or other type of financial institution.

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