• EGRPRA, Regulatory Relief and Comptroller of the Currency Curry’s Proposal to Reduce Regulatory Burden
  • February 20, 2015 | Author: Eric J. Dyas
  • Law Firm: Jones Walker LLP - Mobile Office
  • The Economic Growth and Regulatory Paperwork Reduction Act of 1996 ("EGRPRA") requires that the federal banking agencies (the "Agencies") and the Federal Financial Institutions Examination Council review regulations prescribed by them at least once every ten years in order to identify and, where appropriate, eliminate outdated, unnecessary, or unduly burdensome regulatory requirements imposed on insured depository institutions.

    To facilitate this decennial review, and as required by EGRPRA, the Agencies have divided their regulations into 12 subject-matter categories and identified regulations within each category. In June of this year, the Agencies published the first of what are expected to be four public notices and requests for comments over the course of two years, each of which will cover one or more of the regulatory categories. The comment period for the June notice, which covered 3 of the 12 categories, Applications and Reporting, Powers and Activities, and International Operations, closed on September 2.

    As part of this regulatory review, the Agencies have scheduled a series of at least five outreach meetings in order to afford interested persons the opportunity to share their views with senior management and staff of the Agencies. The first of these outreach meetings was held in Los Angeles, California, on December 2. In a speech given at this meeting, Comptroller of the Currency Thomas Curry introduced three specific proposals designed to reduce regulatory burden on community banks and thrifts subject to oversight by the Office of the Comptroller of the Currency ("OCC"). More specifically, the OCC proposes:

    • to increase the number of community institutions eligible for an 18-month examination cycle by raising the asset threshold for such examinations imposed by Section 10(d)(4)(A) of the Federal Deposit Insurance Act from $500 million to $750 million;
    • to exempt from the Volcker Rule banks and thrifts with total assets of less than $10 billion; and
    • to provide savings associations greater flexibility to expand their business models without the necessity of having to go to the cost and the expense of changing charters.

    Additional outreach meetings have been scheduled for Dallas, Texas, (February 4, 2015), Boston, Massachusetts, (May 4, 2015), Chicago, Illinois, (a date to be in October 2015 to be determined) and Washington, D.C. (December 2, 2015) as the work of the Agencies relating to their efforts to reduce regulatory burden consistent with EGRPRA continue.