Take Action and Support Efforts to Enact Regulatory Relief
Since it was first introduced, the CBA, alongside our colleagues at the ABA and other state banking associations, have strongly supported Senate Banking Committee Chairman Richard Shelby’s (R-AL) Financial Regulatory Improvement Act of 2015, which includes a broad range of regulatory relief provisions that amend the Dodd Frank Act (DFA) and several other banking laws. FRIA would provide, to varying degrees, regulatory relief for banks of all sizes, tailor the regulatory structure for systemically important banks and begin the restructuring of the Federal Reserve System and the housing finance system – Fannie Mae and Freddie Mac.
FRIA also contains structural reforms we strongly support, including raising the threshold for automatic designation as a systemically important financial institution (SIFI) from bank holding companies with $50 billion or more in consolidated assets to those with more than $500 billion. Banks having $50 billion to $500 billion in assets could still be designated as SIFIs after evaluation by FSOC and the Fed. Any bank with less than $50 billion in assets would not be a SIFI.
In addition, the threshold for DFA-mandated stress testing would be raised from bank holding companies with more than $10 billion in consolidated assets to those with more than $50 billion in assets. The threshold for the required supervisory stress tests would be raised from $50 billion in assets to apply to institutions with more than $500 billion in assets and those who are otherwise designated as systemically important in the $50 billion to $500 billion range.
We have a narrow but real opportunity for bipartisan action, and that window will remain open until Congress adjourns in December. After that, the difficult task of getting anything through Congress will become near-impossible in a presidential election year, likely forcing us to wait until 2017 for meaningful relief.
We encourage you to contact California’s U.S. Senators today, either by phone or email, and encourage them to support regulatory relief and share with them the very real impact overregulation is having on your bank and your ability to serve your customers and communities.