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F ederal R eserve Bank
OF DALLAS
ROBERT
D. M c T E E R , J R .
P R E S ID E N T
A N D C H IE F E X E C U T IV E O F F IC E R
May 26, 1992
DALLAS, TEXAS 75222
Notice 92-47
TO:
The Chief Executive Officer of each
member bank and others concerned in
the Eleventh Federal Reserve District
SUBJECT
Request for Comments in Connection with a Study
of the Regulatory Burden Imposed on
Insured Depository Institutions
DETAILS
The Federal Financial Institutions Examination Council (FFIEC) has
announced that it is seeking public comment and is holding a series of public
meetings in connection with a study of the regulatory burden imposed on
insured depository institutions.
Section 221 of the Federal Deposit Insurance Corporation Improvement
Act of 1991 requires the council to submit to the Congress no later than
December 19, 1992, a report describing any suggested revisions to regulatory
policies, procedures, recordkeeping, and documentation requirements that could
reduce unnecessary regulatory burdens on insured depository institutions.
The council must receive comments by July 10, 1992. Comments should
be addressed to Joe M. Cleaver, Executive Secretary, Federal Financial
Institutions Examination Council, 2100 Pennsylvania Avenue, N.W., Suite 200,
Washington, D.C. 20037. All comments should refer to Docket No. S-221.
The council has also announced its intention to convene several
public meetings at which interested parties may personally express their views
on the regulatory burden imposed on insured depository institutions. In order
to ensure geographically diverse representation at the meetings, the council
has decided to hold public meetings in Kansas City, Missouri; San Francisco,
California; and Washington, D.C. The attached FFIEC notice contains the
dates, addresses, and times of the meetings.
Persons wishing to appear at these meetings should submit a written
request by June 5, 1992, containing a brief statement of the nature of the
expected remarks, the estimated time required for their presentation, and the
chosen meeting location to Matthew Maciejewski, Office of the Secretary, Board
of Governors of the Federal Reserve System, 20th Street and Constitution
Avenue, N.W., Washington, D.C. 20551 (facsimile: 202/452-3819). On the basis
For additional copies, bankers and others are encouraged to use one of the following toll-free numbers in contacting the Federal Reserve Bank of Dallas:
Dallas Office (800) 333-4460; El Paso Branch Intrastate (800) 592-1631, Interstate (800) 351-1012; Houston Branch Intrastate (800) 392-4162,
Interstate (800) 221-0363; San Antonio Branch Intrastate (800) 292-5810.
This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org)
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of these requests, council staff will prepare a schedule for persons wishing
to appear, which will be available as soon as practicable after June 8, 1992.
ATTACHMENT
A copy of the FFIEC notice (Docket No. S-221) is attached.
MORE INFORMATION
For more information, please contact the individuals listed in the
attached FFIEC notice. For additional copies of this Bank’s notice, please
contact the Public Affairs Department at (214) 651-6289.
Sincerely yours,
FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL
[Docket No. S-221]
Study on Regulatory Burden
AGENCY:
Federal Financial Institutions Examination Council.
ACTION:
Request for Public Comment; Notice of Public
Meetings.
SUMMARY:
The Federal Financial Institutions Examination Council
(the "FFIEC" or "Council") is seeking public comment regarding
the regulatory burden imposed on insured depository institutions.
The Council is required to conduct a study of regulatory burden
by Section 221 of the Federal Deposit Insurance Corporation
Improvement Act of 1 9 9 1 . The Council is now soliciting
public comment, as well as announcing its intention to hold
public meetings, in order to assist it in the conduct of the
study.
DATES:
Comments must be received no later than July 10, 1992.
ADDRESSES:
Comments, which should refer to Docket No. S-221, may
be mailed to the Federal Financial Institutions Examination
Council, 2100 Pennsylvania Avenue, N.W., Suite 200, Washington,
D.C. 20037, to the attention of Mr. Joe M. Cleaver, Executive
Secretary.
Comments will be available for public inspection and
copying in Suite 200 between 9:00 a.m. and 5:00 p.m., weekdays.
FOR FURTHER INFORMATION CONTACT:
On behalf of the Council:
M. Cleaver, Executive Secretary; or Keith J. Todd, Assistant
Executive Secretary (202/634-6526); FFIEC.
y
Thomas A. Durkin,
Pub L. 102-242, 105 Stat. 2236, 2305 (1991).
Joe
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Regulatory Planning and Review Director, Office of the Secretary
(202/452-2326); or Michael J. O'Rourke, Senior Attorney, Legal
Division (202/452-3288); both of the Federal Reserve Board.
On
behalf of the Board of Governors of the Federal Reserve System:
Martha Bethea, Deputy Associate Director, Division of Research
and Statistics (202/452-3181); or Ellen Maland, Assistant
Director, Division of Consumer and Community Affairs (202/4523667).
On behalf of the Federal Deposit Insurance Corporation:
Robert F. Miailovich, Associate Director, Division of Supervision
(202/898-6918); or Lisa Stanley, Senior Attorney, Office of the
General Counsel (202/898-7494).
Comptroller of the Currency:
On behalf of the Office of the
Raija Bettauer, Director; or Eugene
Cantor, Senior Attorney, Legislative and Regulatory Analysis
Division (202/874-5090).
Supervision:
On behalf of the Office of Thrift
Jerauld C. Kluckman, Deputy Assistant Director for
Policy, Specialized Programs (202/906-5775); or Deborah Kennedy,
Program Analyst, Policy (202/906-7324).
On behalf of the
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Department of the Treasury:
Gordon Eastburn, Director, Financial
Institutions Policy (202/566-5337) (after May 15, 1992: 202/6222730); or Laurie Schaffer, Attorney Advisor, Office of the
General Counsel (Banking and Finance) (202/566-8056) (after May
15, 1992: (202/622-1958).
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SUPPLEMENTARY INFORMATION:
I . Introduction
The Federal Deposit Insurance Corporation Improvement Act of
1991 ("FDICIA") mandated that the Council report to the Congress
on the regulatory burden imposed on insured depository
institutions.
In particular, Section 221 of FDICIA requires that the
Council, in consultation with interested parties, accomplish four
tasks:
First, review the policies, procedures,
recordkeeping and documentation requirements that are used to
monitor and enforce compliance with:
a.
all laws under the jurisdiction of the Federal
banking agencies;f/ and
b.
all laws affecting insured depository
institutions under the jurisdiction of the
Secretary of the Treasury.
Second, determine whether such policies, procedures
and requirements impose unnecessary burdens on insured depository
institutions.
^
For purposes of this study, the terms "insured
depository institution" and "Federal banking agency" have the
same meanings as in section 3 of the Federal Deposit Insurance
Act.
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Third, identify any revisions to these procedures,
policies and requirements that could reduce unnecessary burdens.
The revisions identified, however, may not:
a.
diminish compliance with or enforcement of
consumer laws in any respect; or
b.
endanger the safety and soundness of insured
depository institutions.
Fourth, and finally, submit to the Congress no later
than December 19, 1992, a report describing those revisions that
could reduce unnecessary regulatory burden on depository
institutions.
In accordance with Section 221's direction that the
Council consult "with individuals representing insured depository
institutions, consumers, community groups, and other interested
parties" regarding this study, the Council is now soliciting
public comment on the regulatory burden imposed on insured
depository institutions.
The Council as well is announcing its
intention to conduct a series of public meetings, during which
interested parties will be given an opportunity to express their
views on regulatory burden.
In that regard, the Council has reviewed the
appropriate scope of the Section 221 study.
The Council has
determined that the apparent purpose and intended focus of the
study is not the examination of, and the development of proposed
revisions to, the overall statutory scheme governing financial
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institutions.
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Rather, it appears that the Council is to accept
the statutory scheme devised by the Congress as a given, and
instead examine the manner in which the Federal banking agencies
and the Treasury Department have implemented that scheme, such as
by means of regulations, policy statements, procedures,
recordkeeping requirements and the like.
Although proposed statutory reforms to ease regulatory
burden do not appear to be the intended or primary focus of this
study, the Council recognizes that suggestions regarding
appropriate measures in this regard
may well arise.
has concluded that such suggestions
are appropriately included in
some form in the report to be submitted
TheCouncil
to the Congress.
II. Request for Public Comment
In addition to comments generally on the nature and
scope of regulatory burden imposed on depository institutions,
the Council in particular seeks:
Specific suggestions on how to comply with
particular statutory mandates while, at the same time, easing the
regulatory burden imposed on depository institutions;
Alternative forms, reports, procedures, etc., that
would simplify institutions’ reporting and recordkeeping without
diminishing compliance with applicable laws, or endangering the
ability of the agencies to monitor an institution's condition to
ensure safety and soundness.
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Information regarding the burden of regulatory
compliance relative to the size of a depository institution, as
well as any appropriate ameliorative measures to ease any undue
burden in that regard.
Any studies of regulatory burden concerning
depository institutions; particularly, studies containing
quantitative data relating to the costs and time attributable to
regulatory compliance for depository institutions.
In that
regard, commenters are asked to specify, to the extent possible,
those costs/burdens attributable to statutory requirements, and
those attributable to agency discretion.
Comments previously submitted in response to the
agencies' recent regulatory review initiatives will be made
available to the Council for its consideration in the course of
this study.
Accordingly, those comments need not be resubmitted
in response to this request for comment.
III.
Notice of Public Meetings.
As part of its process of consulting with the public,
the Council also is announcing its intention to convene several
public meetings at which interested parties may personally
express their views on the regulatory burden imposed on insured
depository institutions.
In order to ensure geographically
diverse representation at the meetings, the Council has decided
to hold public meetings in Kansas City, Missouri, San Francisco,
California, and Washington, D.C.
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The public meeting in Kansas City will be held on
June 18, 1992, at the Federal Reserve Bank of Kansas City, 925
Grand Avenue, Kansas City, Missouri 64198.
The meeting will
begin at 9:00 a.m., C.D.T.
The public meeting in San Francisco will be held on
June 19, 1992, at the Federal Reserve Bank of San Francisco, 101
Market Street, San Francisco, California 94105.
The meeting will
begin at 9:00 a.m., P.D.T.
The public meeting in Washington will be held on
June 25, 1992, at the Office of Thrift Supervision, 1700 G
Street, N.W., Washington, D.C. 20552.
The meeting will begin at
9:00 a.m., E.D.T.
Remarks at the public meetings will be presented to
panels consisting of a Presiding Officer (the Executive Secretary
of the Council or his designee) and other panel members
representative of the agencies comprising the Council.
The
public meetings will be transcribed and information regarding
procedures for obtaining a copy of the transcripts will be
announced at the public meetings.
Persons wishing to speak at these meetings should
submit a written request by June 5, 1992, to Matthew Maciejewski,
Research Assistant, Office of the Secretary, Board of Governors
of the Federal Reserve System, 20th Street and Constitution
Avenue, N.W., Washington, D.C. 20551 (facsimile: 202/452-3819).
The request should include the following information:
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1.
Name, address, telephone number (and facsimile
number, if available);
2.
Designation of chosen meeting location; and a
3.
Brief description of the nature of ones expected
remarks.
On the basis of these requests, staff assisting in the study will
prepare a schedule for persons wishing to appear, which will be
available as soon as practicable after June 8, 1992, from Matthew
Maciejewski.
Copies of any written remarks may, but need not, be
filed with the Executive Secretary before a person’s
presentation.
Federal Financial Institutions Examinations Council,
May 14, 1992.
Joe M. Cleaver
Executive Secretary
FEDERAL RESERVE BANK OF DALLAS
STATION K
DALLAS. TEXAS 7 5 2 2 2
@FedFRASER