Letter to the Agencies on EGRPRA

Dear Sir or Madam,

The American Bankers Association (ABA) appreciates the opportunity to provide comments on the regulatory burden review 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by EGRPRA, the federal banking agencies (Agencies) must review their regulations at least every ten years to identify outdated or otherwise unnecessary regulatory requirements imposed on insured depository institutions. This process includes providing public notice, gathering comments on specific regulatory categories, and ultimately producing a report for Congress. This report should summarize the key regulatory burdens raised, assess their validity, and recommend whether those issues are best addressed by regulation or legislation.

ABA supports the goals and purpose of the EGRPRA and strongly encourages the Agencies to use this third decennial review as an opportunity to provide meaningful regulatory relief for banks, enabling them to better serve their customers. Although ABA provided detailed recommendations in previous EGRPRA reviews, few were adopted by regulators. In response, ABA is now focusing on a broader goal: removing unnecessary regulatory burdens, a priority shared by both regulators and the banking industry. The recommendations and examples below regarding rules of procedure and safety and soundness issues require immediate attention, but they also point to a broader underlying issue. We encourage the Agencies to use the examples below to identify broader rules and requirements that hinder, rather than help, banks in effectively serving their customers.

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