ABA Letter to the OCC, Board and FDIC on EGRPRA

Dear Chair Powell, Chair Gruenberg, and Acting Comptroller Hsu:

The American Bankers Association (ABA) appreciates the opportunity to comment on regulatory burden through the statutory review provided under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA).

As required by EGRPRA, the federal banking agencies (Agencies) must review their regulations at least every ten years to identify outdated or otherwise unnecessary regulatory requirements imposed on insured depository institutions. During this review, the Agencies must provide notice and solicit public comment on categories of regulations under scrutiny, then conclude the review by authoring a report to Congress. This report must summarize the major regulatory burden issues raised, the merits of those issues, and whether those issues are best addressed via regulatory or legislative action.

In both the first and second decennial EGRPRA review, ABA provided numerous detailed recommendations ripe for regulatory review. Unfortunately, very few of these recommendations were ultimately acted upon by the Agencies.

With this history in mind, ABA is choosing to focus on the bigger picture: removing unnecessary burdens is a worthwhile goal shared by both regulators and the regulated.

The recommendations and examples discussed below are very much in need of being addressed—however they also serve as illustrations of a much broader problem. We encourage the Agencies to analyze these examples and use them to root out the much larger body of rules and requirements that remain much more harmful than helpful—and which hinder the ability of banks to best serve their customers.

Download the comment letter to read the full text.