Page 24 - membership flipbook

Industry issues

• Federal
o Dozens of major issues

o Regulatory relief
▪ Done regulation by regulation – Portfolio loans, exam
frequency, capital requirements, disclosures when lower
rates, shorter call reports, exam appeals, mortgage servicing

assets, Operation Choke Point…
▪ Systemic approach – TAILORed regulation
• Rep. Scott Tipton, CBA role in conceiving & writing
• Permits and requires regulators (including CFPB) to

tailor regulations to bank/credit union’s business
model and risk profile (detail on later slide)
▪ Well capitalized banks exempt from capital calculations
▪ NCUA proposed rules

Government relations

• H.R. 1116, the “Taking Account of Institutions with Low Operation Risk
Act” (“TAILOR Act”) by Rep. Scott Tipton (R-CO)
• Tailored regulations

o Regulators authorized and required to do
o Tailor regulations to business model, risk profile, customer
impact, and cumulative impact on banks

• Enforcement
o Each regulator reports annually about their compliance with law –
written report & hearing where Members of Congress can ask
tough questions
o FFIEC report any differences – to highlight lax NCUA regulation

• 5 regulators – Fed, FDIC, OCC, NCUA, CFPB
• Look back 5 years and apply law – revise DFA regulations