Position Summary
Many regulatory thresholds are static and have not kept pace with inflation, economic growth, or broader changes to the industry. As community banks grow and cross these static thresholds, they become subject to more complex and costly compliance requirements that divert resources away from lending and community investment. Updating these thresholds, and then indexing them going forward, would ensure that regulations continue to meet their intended scope and purpose.
COMMENT LETTER
Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework