H. Rept. 115-588 - TAKING ACCOUNT OF INSTITUTIONS WITH LOW OPERATION RISK ACT OF 2017115th Congress (2017-2018)
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115th Congress } { Report
HOUSE OF REPRESENTATIVES
2d Session } { 115-588
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TAKING ACCOUNT OF INSTITUTIONS WITH LOW OPERATION RISK ACT OF 2017
_______
March 6, 2018.--Committed to the Committee of the Whole House on the
State of the Union and ordered to be printed
_______
Mr. Hensarling, from the Committee on Financial Services, submitted the
following
R E P O R T
together with
MINORITY VIEWS
[To accompany H.R. 1116]
[Including cost estimate of the Congressional Budget Office]
The Committee on Financial Services, to whom was referred
the bill (H.R. 1116) to require the Federal financial
institutions regulatory agencies to take risk profiles and
business models of institutions into account when taking
regulatory actions, and for other purposes, having considered
the same, report favorably thereon without amendment and
recommend that the bill do pass.
PURPOSE AND SUMMARY
On February 16, 2017, Representative Scott Tipton
introduced H.R. 1116, the ``Taking Account of Institutions with
Low Operation Risk Act of 2017'' or ``TAILOR Act of 2017'',
which directs the federal financial institutions regulatory
agencies (the Office of the Comptroller of the Currency (OCC),
the Board of Governors of the Federal Reserve System (Federal
Reserve), the Federal Deposit Insurance Corporation (FDIC), the
National Credit Union Administration (NCUA), and the Bureau of
Consumer Financial Protection (CFPB)) to tailor their
rulemakings in consideration of the risk profiles and business
models of the financial institutions that are subject to such
rules. The TAILOR Act also directs these agencies to annually
report to Congress and testify before the Committee on
Financial Services and the Committee on Banking, Housing, and
Urban Affairs regarding the specific actions taken to tailor
their regulatory actions.
BACKGROUND AND NEED FOR LEGISLATION
The goal of H.R. 1116 is to have federal financial
regulatory agencies that regulate financial institutions move
away from a static or one-size-fits all approach when the
agency implements regulations and instead engage in dynamic
oversight of financial institutions and consider additional
factors such of an institution such as its risk profile,
unintended potential impact of implementation of such
regulations, and underlying policy objectives of the statutory
scheme which led to the regulation.
The growing weight and complexity of regulation for
community financial institutions affects their ability to
provide the products and services necessary to allow small
businesses to grow and consumers to access credit to realize
their financial and personal goals. The regulatory burden falls
into three major categories: (1) additional operational costs
associated with compliance; (2) restrictions on fees, interest
rates, or other revenue; and (3) unintentional barriers to
offering a service due to regulatory complexity. Smaller
institutions are disproportionately affected by increased
regulation because they are less able to absorb additional
costs. Compliance with new regulations is expensive. After a
regulation has been finalized, an institution must hire lawyers
to review its procedures and forms to ensure that it complies
with the regulation; coordinate its compliance activities and
design internal audit programs; train its employees; buy
additional information technology; design, print, and mail or
electronically deliver new forms and other disclosures; monitor
its employees' compliance with new rules; and make records and
employees available for regulatory examinations.
Although the intent of the Dodd-Frank Wall Street Reform
and Consumer Act's reforms was to reach large, global,
interconnected and complex U.S. financial institutions, the
Dodd-Frank Act and the resulting regulatory regime have had a
demonstrable--and highly adverse--impact on small, community-
based financial institutions. For example, community bankers
report a ``trickle-down effect, where regulation originally
meant for big institutions is being applied to smaller banks,''
often in the form of bank examiners identifying those
regulations as ``best practices'' that should be followed by
institutions regardless of their size.
Some federal financial regulators have acknowledged the
need to tailor the regulatory regime to institutions. For
example, in September 28, 2016, testimony before the Committee,
former Federal Reserve Chair Janet Yellen stated: ``[W]hen it
comes to bank regulation and supervision, one size does not fit
all. To effectively promote safety and soundness and to ensure
that institutions comply with applicable consumer protection
laws without creating undue regulatory burden, rules and
supervisory approaches should be tailored to different types of
institutions such as community banks.'' And, in an April 30,
2015, speech, former Federal Reserve Board Governor Daniel
Tarullo noted ``the importance of differentiating prudential
regulation and supervision based on the varying nature of the
risks posed by different groups of banks . . . . At an analytic
level, we need to be clear that prudential aims vary with the
risks posed by diverse groups of banks.''
A 2015 study from researchers at Harvard University's
Kennedy School of Government entitled ``The State and Fate of
Community Banking,'' noted the ``increasingly complex and
uncoordinated regulatory system [embodied by Dodd-Frank] has
created an uneven regulatory playing field that is accelerating
consolidation [among community financial institutions] for the
wrong reasons.'' The study described a post-financial crisis
competitive landscape characterized by ``community banks'
declining market share in several key lending markets, their
decline in small business lending volume, and the
disproportionate losses being realized by particularly small
community banks.'' An April 2015 study by economists at Goldman
Sachs reached a similar conclusion about the ``pass-through''
effects of post-crisis banking regulations on small businesses
that rely heavily on the community banking sector for their
funding:
The weight and burden from increased bank regulation falls
disproportionately bank customers, such as smaller businesses
that have few alternative sources of finance. The muted
recovery in bank lending to small businesses cannot be
overemphasized. Outstanding commercial and industrial (C&I;)
loans for less than $1 million are still well below the peak
2008 level and are only 10% above the trough seen in 2012. In
contrast, larger C&I; loans outstanding (above $1 million) are
more than 25% higher than the peak in 2008. Moreover, the cost
of the smallest C&I; loans has risen by at least 10% from the
pre-crisis average. The evidence suggests that smaller firms
continue to borrow from banks--when they can get credit--
because they lack effective alternative sources of finance. It
also suggests that they are paying notably more for credit
today; this weighs on their ability to compete with larger
firms and to create new jobs.
The current Presidential administration supports regulatory
tailoring. In President Trump's February 2017 Executive Order
entitled ``Core Principles for Regulating the United States
Financial System'' one of the seven principles was to ``make
regulation efficient, effective, and appropriately tailored.''
In June 2017, the Department of the Treasury released its first
report in response to the President's Executive Order to inform
the Administration's perspective to regulate the financial
system. The report entitled, ``A Financial System That Creates
Economic Opportunities-Banks and Credit Unions'' found that
``[b]anks and credit unions are confronted with a vast array of
regulatory requirements, putting a substantial burden on
financial and human capital. Most critically, regulatory
burdens must be appropriately tailored based on the size and
complexity of a financial organization's business model and
take into account risk and impact.''
H.R. 1116 requires the federal financial institution
regulatory agencies (the OCC, Federal Reserve, FDIC, NCUA, and
CFPB) to tailor any regulatory action that occurs after the
legislation's enactment to appropriately apply to banks and
credit unions. The agencies would be required to consider the
risk profile and business model of the institutions and
determine the necessity, appropriateness, and impact of
applying such regulatory action to those institutions. Not only
will the TAILOR Act ensure appropriately tailored compliance
obligations for banks and credit unions of various risk
profiles, but the legislation will also save valuable time and
resources for bank and credit union examiners. It is important
to foster a regulatory environment where banks and credit
unions can focus their time and assets in their surrounding
communities and make long-term investments, rather than devote
their limited financial and human resources to comply with an
ever-increasing and overly burdensome regulatory regime that
reportedly was never supposed to impact smaller banks and
credit unions.
By allowing the federal regulators to weigh the compliance
impact, cost, and liability risk, together with the unintended
consequences of regulations in the aggregate, consumers will
directly benefit. Tailored adjustments to appraisal and escrow
provisions, for example, would encourage banks to make loans
they currently cannot afford to make. Small business customers
would see more efficient and expedited loan procedures,
ultimately stimulating the local economy. Regulators would also
have the flexibility to deem loans in portfolio as compliant
with ``Qualified Mortgage'' and ``Ability to Repay'' rules,
allowing loans not otherwise made to be accessed by low-income,
rural, retiree, or the recently employed segments of the
consumer lending market. H.R. 1116 is the embodiment of smart
regulation, which will promote small financial institution
competition and foster consumer choice and competitive lending.
HEARINGS
The Committee on Financial Services held a hearing
examining matters relating to H.R. 1116 on April 26, 2017, and
April 28, 2017.
COMMITTEE CONSIDERATION
The Committee on Financial Services met in open session on
October 11, 2017, October 12, 2017, and ordered H.R. 1116 to be
reported favorably to the without amendment by a recorded vote
of 39 yeas to 21 nays (Record vote no. FC-74), a quorum being
present.
COMMITTEE VOTES
Clause 3(b) of rule XIII of the Rules of the House of
Representatives requires the Committee to list the record votes
on the motion to report legislation and amendments thereto. The
sole recorded vote was on a motion by Chairman Hensarling to
report the bill favorably to the House without amendment. The
motion was agreed to by a recorded vote of 39 yeas to 21 nays
(Record vote no. FC-74), a quorum being present.
COMMITTEE OVERSIGHT FINDINGS
Pursuant to clause 3(c)(1) of rule XIII of the Rules of the
House of Representatives, the findings and recommendations of
the Committee based on oversight activities under clause
2(b)(1) of rule X of the Rules of the House of Representatives,
are incorporated in the descriptive portions of this report.
PERFORMANCE GOALS AND OBJECTIVES
Pursuant to clause 3(c)(4) of rule XIII of the Rules of the
House of Representatives, the Committee states that H.R. 1116
will require federal financial institutions regulatory agencies
tailor their regulatory actions as to take into consideration
factors such as risk profile, unintended potential impact of
implementation of such regulations, and underlying policy
objectives.
NEW BUDGET AUTHORITY, ENTITLEMENT AUTHORITY, AND TAX EXPENDITURES
In compliance with clause 3(c)(2) of rule XIII of the Rules
of the House of Representatives, the Committee adopts as its
own the estimate of new budget authority, entitlement
authority, or tax expenditures or revenues contained in the
cost estimate prepared by the Director of the Congressional
Budget Office pursuant to section 402 of the Congressional
Budget Act of 1974.
CONGRESSIONAL BUDGET OFFICE ESTIMATES
Pursuant to clause 3(c)(3) of rule XIII of the Rules of the
House of Representatives, the following is the cost estimate
provided by the Congressional Budget Office pursuant to section
402 of the Congressional Budget Act of 1974:
U.S. Congress,
Congressional Budget Office,
Washington, DC, December 12, 2017.
Hon. Jeb Hensarling,
Chairman, Committee on Financial Services,
House of Representatives, Washington, DC.
Dear Mr. Chairman: The Congressional Budget Office has
prepared the enclosed cost estimate for H.R. 1116, the TAILOR
Act of 2017.
If you wish further details on this estimate, we will be
pleased to provide them. The CBO staff contacts are Sarah Puro
and Stephen Rabent (for federal costs) and Nathaniel Frentz
(for revenues).
Sincerely,
Keith Hall,
Director.
Enclosure.
H.R. 1116--TAILOR Act of 2017
Summary: H.R. 1116 would require the federal banking
regulators--the Federal Deposit Insurance Commission (FDIC),
the Office of the Comptroller of the Currency (OCC), the
National Credit Union Administration (NCUA), the Consumer
Financial Protection Bureau (CFPB), and the Federal Reserve--to
adapt their regulatory actions to the specific risk profiles
and business models of financial institutions that are subject
to regulation. That requirement would apply to any new
regulatory action. The bill also would require the federal
banking regulators to review and revise regulatory actions from
the past seven years, including those written under the Dodd
Frank Wall Street Reform and Consumer Protection Act (Dodd-
Frank Act).
CBO estimates that enacting the legislation would increase
the deficit by $80 million over the 2018-2027 period. That
amount comprises an increase in direct spending of $56 million
and a reduction in revenues of $24 million. Because enacting
the bill would affect direct spending and revenues, pay-as-you-
go procedures apply. CBO also estimates that reviewing rules
issued by the Securities and Exchange Commission (SEC) and the
Commodity Futures Trading Commission (CFTC) would cost $3
million over the 2018-2022 period; such spending would be
subject to the availability of appropriated funds.
CBO estimates that enacting H.R. 1116 would not increase
net direct spending or on-budget deficits by more than $2.5
billion in any of the four consecutive 10-year periods
beginning in 2028.
H.R. 1116 contains no intergovernmental mandates as defined
in the Unfunded Mandates Reform Act (UMRA). Additional fees
imposed by the OCC, the NCUA, and the SEC increase the cost of
the existing mandate on private entities that are required to
pay those assessments. However, CBO estimates that the
incremental cost of the mandate would fall well below the
annual threshold established in UMRA for private-sector
mandates ($156 million in 2017, adjusted for inflation).
Estimated cost to the Federal Government: The estimated
budgetary effect of H.R. 1116 is shown in the following table.
The costs of this legislation fall within budget function 370
(commerce).
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By fiscal year, in millions of dollars--
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2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018-2022 2018-2027
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INCREASES IN DIRECT SPENDING
Estimated Budget Authority........................ 5 10 10 8 3 4 4 4 4 4 36 56
Estimated Outlays................................. 5 10 10 8 3 4 4 4 4 4 36 56
DECREASES IN REVENUES
Estimated Revenues................................ -2 -3 -4 -3 -2 -2 -2 -2 -2 -2 -13 -24
NET INCREASE IN THE DEFICIT FROM CHANGES IN DIRECT SPENDING AND REVENUES
Effect on the Deficit............................. 7 13 14 11 5 6 6 6 6 6 49 80
INCREASES IN SPENDING SUBJECT TO APPROPRIATION
Estimated Authorization Level..................... 1 1 1 0 0 0 0 0 0 0 3 3
Estimated Outlays................................. 1 1 1 * 0 0 0 0 0 0 3 3
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Components may not sum to totals because of rounding; * = between zero and $500,000.
Basis of estimate: H.R. 1116 would require the federal
banking regulators to consider the risk profiles and business
models of financial institutions when determining which
institutions are subject to regulatory action and to adapt
regulations to the characteristics of individual financial
institutions. The agencies would be required to review and
analyze all regulations adopted during the prior seven years,
in accordance with the requirements in H.R. 1116, and to revise
those regulations, if necessary, to comply with the bill.
Costs incurred by the FDIC, the NCUA, and the OCC are
recorded in the budget as increases in direct spending. Those
agencies are authorized to collect premiums and fees from
insured depository institutions to fully cover such
administrative expenses, although CBO expects that only a
portion of the costs incurred by the FDIC would be recouped by
2027.
The CFPB is permanently authorized to spend amounts
transferred from the Federal Reserve. Because that activity is
not subject to appropriation, the CFPB's expenditures are
recorded in the budget as direct spending. Costs to the Federal
Reserve System reduce remittances to the Treasury; they are
recorded in the budget as revenues.
To develop this estimate, CBO consulted with the federal
financial regulators about the number of people needed to
review and revise regulations and about the regulations adopted
over the past seven years.
Direct spending and revenues
The financial regulators have completed more than 200 rules
over the past seven years, many of them associated with the
Dodd-Frank Act.\1\ The bill would require the financial
regulators to review and possibly revise those rulemakings. In
addition, CBO expects that H.R. 1116 could increase the amount
of litigation that those regulators are subject to under the
Administrative Procedures Act because regulated institutions
would have additional grounds to challenge the application of
financial regulations.
---------------------------------------------------------------------------
\1\See DavisPolk, Dodd-Frank Progress Report: Six-Year Anniversary
Report (July 2016), http://tinyurl.com/ycovbwpx (PDF, 1.2 MB).
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The cost to implement the bill has two components. First,
CBO expects that the financial regulators would have to hire
additional staff over the 2018-2021 period to complete the
required review and revision of previous rulemakings.
Subsequently, the regulators would require additional staff to
support new rulemaking and to defend agency actions from
additional litigation.
CBO expects that over the 2018-2021 period each of the
financial regulators would need to increase its legal staff by
5 percent to 10 percent and certain other staff by less than 1
percent to complete the analysis of the regulations promulgated
over the past seven years. Currently, the agencies have a total
of about 6,000 employees, including 600 attorneys, on staff in
their Washington, D.C., offices. CBO expects that overall
staffing would increase by 60 employees over the 2018-2021
period.
After 2020, CBO expects that the regulators would no longer
need all of the additional staff that they needed to complete
the review of existing regulations, however, spending by the
financial regulators to carry out new rulemakings and to defend
agency actions from new litigation would increase. Over the
2020-2027 period CBO expects that implementing the bill would
require roughly 25 additional employees across the federal
financial regulators. The OCC and the NCUA likely would recover
any implementation costs over the next ten years by increasing
assessments on the institutions they regulate, and the FDIC
would recover most of its costs after 2027.
In total, CBO estimates that enacting the bill would
increase deficits by $80 million over the 2018-2027 period.
That amount includes an increase in net direct spending of $56
million and a decrease in revenues of $24 million because the
Federal Reserve would reduce its remittances to the Treasury.
Spending subject to appropriation
Implementing H.R. 1116 would probably require the CFTC and
the SEC to review regulations adopted under the Dodd-Frank Act.
Using information from the affected agencies, CBO estimates
that they would require four additional employees over the
2018-2021 period. Because the SEC is authorized under current
law to collect fees sufficient to offset its annual
appropriation, we estimate that the net costs to the SEC would
be negligible, assuming appropriation actions consistent with
that authority. CBO expects that costs to the CFTC would total
$3 million over the 2018-2022 period; such spending would be
subject to the availability of appropriated funds.
Pay-As-You-Go considerations: The Statutory Pay-As-You-Go
Act of 2010 establishes budget-reporting and enforcement
procedures for legislation affecting direct spending or
revenues. The net changes in outlays and revenues that are
subject to those pay-as-you-go procedures are shown in the
following table.
CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 1116, AS ORDERED REPORTED BY THE HOUSE COMMITTEE ON FINANCIAL SERVICES ON OCTOBER 12, 2017
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By fiscal year, in millions of dollars--
-----------------------------------------------------------------------------------------------------
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018-2022 2018-2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
NET INCREASE IN THE DEFICIT
Statutory Pay-As-You-Go Impact.................... 7 13 14 11 5 6 6 6 6 6 49 80
Memorandum:
Changes in Outlays............................ 5 10 10 8 3 4 4 4 4 4 36 56
Changes in Revenues........................... -2 -3 -4 -3 -2 -2 -2 -2 -2 -2 -13 -24
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Increase in long-term direct spending and deficits: CBO
estimates that enacting the legislation would not increase net
direct spending or on-budget deficits by more than $2.5 billion
in any of the four consecutive 10-year periods beginning in
2028.
Mandates: H.R. 1116 contains no intergovernmental mandates
as defined in UMRA.
CBO expects that the financial regulators would increase
premiums or fees to offset the costs of implementing the
additional regulatory activities required by the bill. Any
increase in premiums or fees would increase the cost of the
existing mandate on entities required to pay those assessments.
Using information from the federal banking regulators and the
SEC, CBO estimates that the incremental cost to comply with the
mandate would fall well below the annual threshold established
in UMRA for private-sector mandates ($156 million in 2017,
adjusted for inflation).
Estimate prepared by: Federal costs: Sarah Puro and Stephen
Rabent; Revenues: Nathaniel Frentz; Mandates: Logan Smith.
Estimate approved by: H. Samuel Papenfuss, Deputy Assistant
Director for Budget Analysis.
FEDERAL MANDATES STATEMENT
This information is provided in accordance with section 423
of the Unfunded Mandates Reform Act of 1995.
The Committee has determined that the bill does not contain
Federal mandates on the private sector. The Committee has
determined that the bill does not impose a Federal
intergovernmental mandate on State, local, or tribal
governments.
ADVISORY COMMITTEE STATEMENT
No advisory committees within the meaning of section 5(b)
of the Federal Advisory Committee Act were created by this
legislation.
APPLICABILITY TO LEGISLATIVE BRANCH
The Committee finds that the legislation does not relate to
the terms and conditions of employment or access to public
services or accommodations within the meaning of the section
102(b)(3) of the Congressional Accountability Act.
EARMARK IDENTIFICATION
With respect to clause 9 of rule XXI of the Rules of the
House of Representatives, the Committee has carefully reviewed
the provisions of the bill and states that the provisions of
the bill do not contain any congressional earmarks, limited tax
benefits, or limited tariff benefits within the meaning of the
rule.
DUPLICATION OF FEDERAL PROGRAMS
In compliance with clause 3(c)(5) of rule XIII of the Rules
of the House of Representatives, the Committee states that no
provision of the bill establishes or reauthorizes: (1) a
program of the Federal Government known to be duplicative of
another Federal program; (2) a program included in any report
from the Government Accountability Office to Congress pursuant
to section 21 of Public Law 111-139; or (3) a program related
to a program identified in the most recent Catalog of Federal
Domestic Assistance, published pursuant to the Federal Program
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No.
98-169).
DISCLOSURE OF DIRECTED RULEMAKING
Pursuant to section 3(i) of H. Res. 5, (115th Congress),
the following statement is made concerning directed
rulemakings: The Committee estimates that the bill requires no
directed rulemakings within the meaning of such section.
SECTION-BY-SECTION ANALYSIS OF THE LEGISLATION
Section 1. Short title
This section cites H.R. 1116 as the ``Taking Account of
Institutions with Low Operation Risk Act of 2017''
Section 2. Regulations appropriate to business models
This section states the directives that the federal
financial institutions regulatory agencies (Office of the
Comptroller of the Currency (OCC), the Board of Governors of
the Federal Reserve System (Fed), the Federal Deposit Insurance
Corporation (FDIC), the National Credit Union Administration
(NCUA), and the Consumer Financial Protection Bureau (CFPB)
must consider when imposing regulations on institutions.
CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED
H.R. 1116 does not repeal or amend any section of a
statute. Therefore, the Office of Legislative Counsel did not
prepare the report contemplated by clause 3(e)(1)(B) of rule
XIII of the House of Representatives.
MINORITY VIEWS
H.R. 1116, the ``Taking Account of Institutions with Low
Operation Risk (TAILOR) Act,'' would take a major step
backwards on the progress made since the 2008 Financial Crisis
to ensure our financial markets are stronger, more resilient,
and more protective of consumers.
The Dodd-Frank Wall Street Reform and Consumer Protection
Act (Dodd-Frank Act) establishes a tiered and tailored
regulatory framework for financial institutions. Instead of
imposing a one-size-fits-all approach for regulating all firms,
the Dodd-Frank Act focuses the toughest rules on the largest
and most complex financial firms that, as evidenced in the
2007-2009 financial crisis, can destabilize the financial
system and inflict long-lasting damage to the economy and the
constituents we serve.
Congress has carefully monitored the implementation of the
Dodd-Frank Act and, when warranted, has passed targeted
legislation or encouraged regulators to further tailor rules to
reduce unnecessary compliance requirements on community
financial institutions while maintaining robust standards and
appropriate protections that are in the public interest.
If enacted, H.R. 1116 would undo these efforts by providing
every financial institution overseen by agencies like the
Federal Deposit Insurance Corporation (FDIC) or the Consumer
Financial Protection Bureau with new opportunities to challenge
rulemakings in court if they felt a regulation was not uniquely
tailored to their individual firm. Moreover, the bill would not
require regulators to consider the benefits of certain
rulemakings, including the promotion of financial stability or
the protection of consumers.
H.R. 1116 would ignore the mandates and requirements of all
other laws passed by Congress and would override decades of
well-established administrative law requirements by subjecting
all new financial rules to a vague, if not an impossible
standard, to meet. This would include the determination of an
undefined standard of ``appropriateness''' for each rule and
how it would apply to every single institution. The bill would
also require each regulatory action to be analyzed ``both by
itself and in conjunction with the aggregate effect of other
regulations''' for its impact on how each and every firm can
``serve evolving and diverse customer needs.''
Additionally, we are concerned that the level of
institution-specific tailoring under the bill could result in a
severe weakening of the nation's anti-money laundering and Bank
Secrecy Act rules. By requiring that compliance costs and
liability risk be considered a higher priority than protecting
the integrity of the financial system, the bill could create a
class of institutions with lowered compliance standards that
might become an ideal target for drug cartel money laundering
or terrorist financing.
Finally, the TAILOR Act would ignore the substantial amount
of work that agencies have done to ensure that rules are
adopted in a way that considers the needs of smaller financial
institutions. For example, the federal prudential banking
agencies have worked to minimize supervision and compliance
burdens for smaller sized institutions. After completing an
extensive review that is required every 10 years, the federal
prudential banking agencies recently issued a sweeping report
under the Economic Growth and Regulatory Paperwork Reduction
Act and are making further modifications to better tailor rules
for smaller, less risky firms.
We share the belief that regulators must take into account,
and tailor rules, for smaller sized institutions when
appropriate. Unfortunately, the TAILOR Act would only serve to
put consumers and the financial system at risk by subjecting
important regulations to endless litigation.
For the foregoing reasons, we oppose H.R. 1116.
Maxine Waters.
Gregory W. Meeks.
Keith Ellison.
Al Green.
Michael E. Capuano.
Carolyn B. Maloney.
Nydia M. Velazquez.
Gwen Moore.
Wm. Lacy Clay.
Emanuel Cleaver.
Brad Sherman.
Joyce Beatty.
Bill Foster.
[all]