This study models the distance-to-default (DTD) of a large sample of banks with the aim of shedding light on policy and regulatory issues. The determinants of the distance-to-default in a panel sample of 94 banks over the period 2004 to 2011, controlling for the market beta of each bank, includes house prices, relative size, simple leverage, derivatives gross market value of exposure, trading assets, wholesale funding and cross-border revenue. The Basel Tier 1 ratio finds no support as a predictor of default risk. The un-weighted leverage ratio, on the other hand, finds strong support. At the macro level house prices are a powerful predictor of the DTD. At the business model level, the results appear to be consistent with an approach to policy that focuses on the apparent importance of the “size-derivativesleverage- wholesale funding nexus” in influencing the DTD of banks. While these results are preliminary, it is encouraging that the out-of-sample predictive power of the model improves systematically as each year of new observations is added. The results are also consistent with some central bank involvement in the supervision process, given the importance of the asset price cycle, identified in this study.