By John C. Asbury
The Dodd-Frank Act fundamentally reshaped the banking industry well over a decade ago. Among other things, regulators carved up the industry into different asset tiers, irrespective of the wide variety of business models and risk profiles that exist within those asset tiers.
When I came to my current role as CEO of Atlantic Union Bank, we were on the verge of crossing the infamous $10 billion asset threshold. And when I spoke to the board during my hiring process, I made it very clear that getting over that hump was going to require significant growth and fundamental changes to our business model.
My reasoning was this: You simply can’t grow gently past $10 billion.
In fact, I would argue that there’s an “escape velocity” required to make that jump, as you’re thrust into a very different regulatory environment. I believe that when you make the decision to cross into the $10 billion+ tier, what you’re actually doing is committing to being a $20 billion bank or above, given the compliance and enterprise risk management cost increases that come with it. This is in addition to losing half your debit card interchange income, which occurs when you cross that $10 billion line.
Now, I’m proud of the strategy we put together for Atlantic Union and the incredible strides we’ve made since crossing that $10 billion mark. But I’m constantly aware that elements of that decision were, to an extent, imposed upon us by the regulatory framework. And I think that’s a sign that our current regulatory framework is flawed.
We have a limited window to move the needle and see meaningful changes made to the banking rules in this country. That’s why we need every banker engaged and sharing your stories.
Regulators seem to have lost sight of the fact that banks are businesses that operate for profit. We saw this in the original architecture of Dodd-Frank a decade ago, and we’ve seen it recently in the number of misguided rule makings that have come out over the last four years.
We now have a chance to change course, due to the power shift taking place in Washington, D.C. There are now stakeholders at the agencies and in Congress with significantly more alignment on many of our issues than in recent years. But in order for us to make progress, we need to stand united as an industry — because the reality is, we aren’t the only ones knocking on our lawmakers’ doors with a list of things we want to see accomplished.
That’s why an organization like ABA is so important. As the only banking trade group representing banks of all sizes, ABA is uniquely positioned to unite the industry and get us all aligned and working together.
Lawmakers won’t burn political capital on an industry that isn’t united. As I’ve been involved with ABA over the years, something I’ve come to deeply appreciate is ABA’s ability to be that unifying force for the banking industry.
We have a limited window to move the needle and see meaningful changes made to the banking rules in this country. Bankers turned out in force for the 2025 ABA Washington Summit this week to meet face to face with the people who will be writing the banking rules of tomorrow, raising their voices on behalf of their customers and communities.
It’s time to reset the conversation on banking regulation in this country — and rewrite the rulebook to ensure that banks of all sizes can continue to thrive.
John C. Asbury is chair of ABA and CEO of Atlantic Union Bank in Richmond, Virginia.