The federal banking agencies have built on a prior effort to solicit comment on ways to improve the rules governing capital, the Community Reinvestment Act (CRA), and bank operations. Under these notice-and-comment proceedings, the agencies have carefully limited their purview to omit much of the post-crisis regulatory reforms and their scope is further limited to rules that may be unnecessary, unduly burdensome, or duplicative – not to those that may warrant broader review on more sweeping policy considerations like market impact and/or competitiveness. Nevertheless, given the impact of the capital rules on profitability and the CRA ones on legal and reputational risk, the latest notice provides an opportunity to bring concerns to the agencies’ attention, as well as to highlight broader policy considerations for a wider audience.
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