ABA expressed concern about the lack of transparency of the assessment basis used in the Federal Reserve’s proposal to assess bank, savings-and-loan and nonbank financial holding companies with over $50 billion in assets for the cost of supervision. ABA said that the proposal, issued under Section 318 of the Dodd-Frank Act, “provides insufficient information” about whether the supervisory activities the Fed proposes to fund truly relate to its oversight of the covered firms.
“Section 318 is clearly based on a direct relationship between the assessment and related supervision costs,” ABA said. “Those costs must be publicly known and subject to evaluation for the assessments to the valid under the provision.”
Read the letter.