[T]he sheer weight of more than 24,000 pages of proposed and final rules has become a key consideration for many institutions in determining their future. This is why Congress and the regulatory agencies must work together to continue to pursue legislative and regulatory changes that will keep financial institutions strong and vibrant so they may continue to serve their customers and communities.
ABA commended the inclusion of several provisions that have been longstanding priorities, including: the TAILOR Act, which requires that regulations be tailored to a bank’s business model; a Qualified Mortgage safe harbor provision for loans held in portfolio; the creation of an exam appeals process; greater flexibility for mutual banks and small bank holding companies; the repeal of the Durbin Amendment; and other provisions that would eliminate unnecessary compliance problems and costs.
However, the association also raised questions about other provisions, such as “additional aspects of the capital proposal that may unnecessarily limit the benefits of the approach to hundreds of well-run banks of all sizes, including many community and mid-size institutions,” adding that “the use of simple litmus tests for qualifying for relief could fail to fully incorporate the use of many safe and legitimate risk management tools that allow banks to better serve their customers and communities.”
ABA also urged the committee to consider additional reform measures, such as requiring the Financial Stability Oversight Council to establish a formal process for classifying banks as “systemically important,” and streamlining currency transaction reporting.
Read the memo.