ABA and the Financial Services Roundtable last week filed comments on the Federal Reserve’s September proposal that would exempt many regional banks from the complex qualitative requirements of its annual Comprehensive Capital Analysis and Review, or CCAR, process. While welcoming the overall purpose of the proposal, ABA and FSR offered several recommendations to improve the proposal. Specifically, the groups recommended that the Fed clarify the supervisory review process and documentation requirements, raise the materiality threshold for Y-14 reporting, apply a risk-based rather than asset-based approach to setting thresholds and retain the de minimis exemption. For more information, contact ABA’s Hugh Carney.
ABA, associations reaffirm support for federal preemption of Illinois interchange law
ABA joined other national associations and state bankers associations in submitting a trio of letters expressing their support for recent actions by the OCC to reaffirm federal preemption of state attempts to regulate interchange fees, as in Illinois.
