[W]e will be taking a fresh look at the possible scope for transition arrangements, including the potential for grandfathering, to evaluate what we could do to lighten burden without compromising our two key principles of raising the quantity and quality of capital and setting minimum standards that generally require more capital for more risk.Curry emphasized that as a career community bank and thrift supervisor, he understands how community bankers feel about the compliance burden.
It may sometimes seem that regulators are completely insensitive to regulatory burden. In preparing the June [proposals], we did actually worry a lot about three sorts of burden: the short-term costs of simply digesting the rules; the long-term costs of developing and implementing any procedures and systems needed to comply; and then of course the costs of increasing capital.While writing the proposals, the agencies were “very aware of the need to balance soundness and regulatory burden considerations,” Curry added. “We are hoping that the comment letters we receive will help us figure out how to improve this balance."
Read Curry’s speech.
ABA is reminding members that the comment deadline on the Basel III proposals is Oct. 22, and it is imperative that the agencies hear from as many banks as possible. Information to help craft and send comment letters is available on the ABA Basel III Web page.