We commend the commission for instituting these common-sense changes. These rule amendments will provide consistent treatment across regulatory charters, thus simplifying compliance and supervision.
The proposal addresses a technical error in the JOBS Act raising the threshold for registration from 500 to 2,000 shareholders and the deregistration threshold from 300 to 1,200 for BHCs — but not for S&LHCs. ABA has long sought to correct the oversight, advocating with both Congress and the SEC for a fix.
S&LHCs were also included for the first time in the Federal Reserve’s recent proposal to raise the threshold for small bank regulatory relief to $1 billion in assets. The proposal implements ABA-advocated legislation that Congress passed in December.
Read the letter.