PLEASE SHARE YOUR REGULATORY BURDEN/EGRPRA COMMENTS WITH ICBA
Over a two year period, the federal banking agencies are conducting a review of their regulations to identify outdated, unnecessary, or unduly burdensome regulations for insured depository institutions. This review is required by the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA) which requires this review at least once every ten years.
To facilitate this review, the agencies have divided their regulations into twelve subject-matter categories and will publish four requests for comment over the two year period. The first request dealt with three categories-- Applications and Reporting, Powers and Activities and International Operations—and comments were due on September 2, 2014. The agencies just came out with their second request for comments which deals with the categories of Bank Operations, Capital, and the Community Reinivestment Act. Comments for this request are due by May 14, 2015. A complete list of the regulations is included in the charts in the first request for comments.
With respect to the current request for comments which are due on May 14, 2015, the category of Bank Operations include the regulations concerning the Availability of Funds and the Collection of Checks (Regulation CC), the Collection of Checks and Other Items (Regulation J), Reimbursement for Providing Financial Record--Recordkeeping Requirements for Certain Financial Records (Regulation S), Reserve Requirements of Depository Institutions (Regulation D) and Assessments (12 C.F.R. Part 327).
The category of Capital includes the Prompt Corrective Action Regulations (12 C.F.R. 6.3-6.6) and the Community Reinvestment Act category includes the CRA regulations at 12 C.F.R. Part 25 and Part 35.
The banking agencies have already held two outreach meetings in Los Angeles and in Dallas and many ICBA members have attended those meetings and participated in panel discussions regarding reducing regulatory burden. Video tapes and transcripts of these outreach meetings can be found at the EGRPRA section of the FFIEC website, www.ffiec.org. The agencies have announced three more outreach meetings—in Boston, on May 4, 2015, in Chicago on October 19, 2015 and in Washington, D.C. on December 2, 2015. The Agencies also plan to hold an outreach meeting in Kansas City on August 4, 2015, which will focus on rural banking issues. Bankers are encouraged to register and attend these meetings. Bankers can register by going to www.ffiec.org and clicking on “EGRPRA.”
Please provide feedback to ICBA on those regulations currently being reviewed (i.e., Bank Operations, Capital and CRA) by going here and giving us your comments in “Your EGRPRA Feedback” section. Comments on these categories are due by Mary 14, 2015.