It is important that the final rules not impair the availability of traditional banking services to bank customers, nor impose unnecessary costs on banks where there is no systemic risk or threat to the U.S. financial system.As part of the agencies’ rulemaking review process, ABA requested they consider the following in connection with the final rule:
Our members also will need to have sufficient time and opportunity to transition their affected activities to conform with the requirements of the final rules in a manner that is not disruptive to customers or to the economy.
- Include a full explanation of the agencies’ reasons for adopting provisions;
- Include a Volcker rule summary compliance guide for community banks;
- Allow a two-year compliance period from the final rules’ effective date;
- Expressly include a “good-faith” compliance provision, whereby no enforcement action or adverse regulatory action will be taken during the two-year conformance period provided reasonable efforts are being taken.