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ICBA called on federal regulators to take meaningful action to address excessive regulatory burdens on community banks under the agencies’ latest review under the Economic Growth and Regulatory Paperwork Reduction Act, or EGRPRA.
In comments to the agencies, ICBA said the agencies should:
Take this new EGRPRA review much more seriously because of the exponential growth of community bank regulatory burdens and the little substantive relief provided by previous reviews.
Hire an independent outside consultant to quantify the current regulatory burden on community banks because previous reviews have shown the agencies cannot objectively evaluate the burden of their own regulations.
Hold at least two livestreamed outreach meetings in every region of the country and invite community banks to participate.
Set up an EGRPRA.gov website as they have done previously to publish comment letters, post notices and outreach meeting resources, and list the regulations that bankers mention the most as being outdated, unnecessary, and unduly burdensome.
Designate an overall director of the current EGRPRA interagency review process who could overcome the objections of individual agencies to specific recommendations and resolve interagency disputes.
Conduct a thorough review of past regulatory assessments under the Paperwork Reduction Act of 1995 and the Regulatory Flexibility Act, which have consistently understated the regulatory burden of new regulation on community banks.
Simplify the call report, streamline the de novo bank applications, update the Small Bank Holding Company Policy Statement, and expedite procedures under the Bank Merger Act under its review of Applications and Reporting and Powers and Activities regulations, the first of four requests for comment under the current review.