In the last formal speech of his five-year term as Comptroller of the Currency, John Dugan said the financial crisis had exposed glaring gaps and differences in the regulation of different types of financial institutions and made clear the need for an updated capital framework. “The fact is that our financial regulatory system was designed to be extremely bank centric,” he said in a speech to the Exchequer Club. “Extensive rules and tremendous supervisory resources were focused on banks, with far less of both devoted to other types of financial firms. As these other types of firms became much more significant in the delivery of financial services through the growth of securitization, structured products, and derivatives, our bank-centric regulatory apparatus was not adjusted to keep pace.”