ABA filed its fourth and final comment letter in response to the decennial EGRPRA regulatory burden review that the federal banking agencies must conduct. The letter addressed several issues that ABA identified through collaboration with banks of all sizes and from across the country.
ABA specifically asked the agencies to provide parity for state versus federally chartered institutions under the Liquidity Coverage Ratio, realign guidance on board and management responsibilities, reconsider the public disclosure of midsize banks’ stress test results, clarify required filings for bank transfer agents, reduce record-keeping requirements for securities transactions, coordinate on information-sharing arrangements, clarify Volcker Rule exam guidance and tailor debit card regulations, among others.
ABA also asked the FDIC to revisit its brokered deposit guidance and the OCC to end its unnecessary Money Laundering Risk System and minimize the burden of horizontal review surveys.
Read the letter.