Federal regulators are ending the year with a bang, having spent the month of October issuing major proposed and final rules. In recent weeks, we have seen the issuance of:
- “Open banking” regulations required under Section 1033 of the Dodd-Frank Act – which proposes new requirements for consumer access to financial records;
- A rewriting of the Community Reinvestment Act, with all banks over $600 million in assets experiencing some changes to how they’re monitored for CRA compliance;
- Proposed “standards for corporate governance” by the FDIC for banks over $10 billion in assets (and some under $10 billion);
- Principles for climate related risk for large financial institutions (over $100 billion); and
- Proposed changes to interchange rules for banks over $10 billion under Regulation II.
While several of these rules are targeted at larger financial institutions, IBAT will be working to identify areas where their effects might trickle down to smaller financial institutions. As we have seen in the past, there are times when regulators’ expectations of compliance precedes formal expansion of applicability to smaller institutions.
Please keep a close eye on communications in the weeks ahead, as IBAT will be asking members to participate in the open comment period on several of these rules.
