Executive Letter: Share Your Experiences Regarding Burdensome Regulations
By Rose Oswald Poels
The federal bank regulatory agencies are seeking comment on interagency efforts to reduce regulatory burden: the Federal Deposit Insurance Corporation (FDIC); the Federal Reserve Board (FRB), and the Office of the Comptroller of the Currency (OCC).
Anyone working in banking knows that it is one of the most highly regulated industries in the country. While we certainly respect the need for regulations aimed at protecting consumers, preventing bank failures, and promoting stability in our nation’s financial system, this opportunity to comment on regulatory burden is welcome.
The Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) requires the Federal Financial Institutions Examination Council (FFIEC) and federal bank regulatory agencies to review their regulations every ten years to identify outdated or otherwise unnecessary regulatory requirements for their supervised institutions.
To facilitate this review, the agencies divided their regulations into 12 categories (in alphabetical order):
• Applications and Reporting
• Banking Operations
• Capital
• Community Reinvestment Act
• Consumer Protection
• Directors, Officers, and Employees
• International Operations
• Money Laundering
• Powers and Activities
• Rules of Procedure
• Safety and Soundness
• Securities
The agencies are now soliciting comments on their regulations in three categories: Consumer Protection; Directors, Officers, and Employees; and Money Laundering. The public has 90 days from publication in the Federal Register to comment on the relevant regulations.
On February 6, 2024, the agencies published the first notice addressing the following categories of regulations: Applications and Reporting; Powers and Activities; and International Operations. The comment period for those categories closed on May 6, 2024.
Over the next two years, the agencies will request comment on regulations in the remaining categories, asking the public to identify the regulations they believe are outdated, unnecessary, or unduly burdensome. The agencies will review the comments received and determine whether further action is appropriate with respect to the regulations.
WBA will be sharing comments in response to this interagency request. It is crucial to amplify the voice of bankers in Wisconsin who are dealing with unnecessarily onerous regulatory requirements. Please contact me to share stories of how your bank is impacted by regulations from FDIC, FRB, and OCC in the categories of Consumer Protection; Directors, Officers, and Employees; and Money Laundering that could be described as outdated, unnecessary, or unduly burdensome as well as suggestions on how to ease those burdens. It is incredibly helpful to get input from WBA members, so I welcome the frank assessments, common sense strategies, and practical potential solutions provided by leaders of Wisconsin’s banking industry.
In related news, the agencies are holding a virtual public outreach meeting on September 25, 2024, as part of their review.
The Economic Growth and Regulatory Paperwork Reduction Act Virtual Outreach Meeting is an opportunity for interested stakeholders to present their views on the six categories of regulations listed in the first two Federal Register notices (described above): Applications and Reporting; Powers and Activities; International Operations; Consumer Protection; Directors, Officers and Employees; and Money Laundering.
Individuals interested in providing oral comments need to register by August 9, 2024, and indicate the regulatory category they would like to discuss. The agencies will notify those individuals selected to provide comments by September 9, 2024. Click here to register.
Advance registration is not required to attend this virtual public meeting as an observer.
The agencies will announce additional public meetings in 2024 and 2025. Details will be available on the EGRPRA website.
Since this request for input on regulatory burden in our industry only occurs every ten years, I encourage you to take advantage of this opportunity and share your insights.
