In a comment letter to the FDIC today, the American Bankers Association outlined five general principles that the agency should follow to increase the transparency of its rulemaking process. ABA’s letter came in response to a recent request for information from the FDIC seeking feedback on the effectiveness, costs and benefits of its regulatory actions.
ABA recommended that the FDIC conduct a holistic review of all existing regulations prior to issuing new regulations; consider the banking industry, customers, financial markets and the broader economy in its impact assessment of potential new rules; and ensure that careful reviews are conducted to accurately understand the cost to banks of new regulations.
The association also urged the FDIC to detail and clarify any changes to bank recordkeeping and reporting requirements when proposing new regulations, and undertake voluntary data collections and impact analyses prior to finalizing a major rule.
