CBAI’s Immediate Past Chairman, Todd Grayson, President of South Central Bank in Chicago, was a panelist at the October 19, 2015, Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) outreach meeting at the Federal Reserve Bank of Chicago. Grayson delivered the community bank message regarding overwhelming and counterproductive regulatory burden and the need for community bank regulatory relief and tiered regulation.
The EGRPRA Act of 1996 requires that regulations prescribed by the Federal Financial Institutions Examination Council, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Board of Governors of the Federal Reserve System be reviewed by the agencies at least once every 10 years. The purpose of this review is to identify outdated, unnecessary, or unduly burdensome regulations and consider how to reduce regulatory burden on insured depository institutions while, at the same time, ensuring their safety and soundness and the safety and soundness of the financial system. The Chicago Outreach Meeting was attended by approximately 120 bankers, community group members and regulators.
Grayson’s panel was one of four that made presentations to Martin J. Gruenberg (Chairman, FDIC), Thomas J. Curry (Comptroller, OCC), Lael Brainard (Governor, Federal Reserve Board), and Bryan A. Schneider (Secretary, Illinois Department of Financial and Professional Regulation). His panel discussions included Money Laundering and Safety and Soundness. He discussed the increasing cost of regulatory compliance and urged tiered regulation for community banks. Grayson’s specific recommendations included increasing the dollar threshold and revising other requirements for residential real estate appraisals, and he also recommended increasing the dollar threshold for Currency Transaction Reports (CTRs).
CBAI’s Vice President of Governmental Relations, David Schroeder, also attended the Outreach Meeting. During Audience Comment periods, Schroeder cautioned about unintended consequences of the combined impact of multiple agency rulemaking to address the same perceived issue or concern (i.e., Basel III capital and risk weights, the proposed new FDIC assessments for community banks, and the upcoming FASB expected loss model all impacting commercial and real estate lending) and stated the need for de novo bank formation to maintain a strong, growing, evolving and vibrant banking profession
CBAI thanks Todd Grayson for participating in this important Outreach Meeting and we certainly hope that this time the decennial review of regulations will produce prompt and meaningful regulatory relief for community banks.