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Dodd-Frank Act Implementation Issues and Mitigation Efforts

Oversight by Congress of the implementation of the Dodd-Frank Act is essential. Some reforms from the Dodd-Frank Act have positive effects on many GBA members, such as the new FDIC assessment structure, a permanent increase in maximum FDIC insurance coverage for deposits up to $250,000 and a mechanism to wind down large, complex financial institutions as a means to end the concept any institution is too big to fail. However, efforts must be made to ensure the flow of proposed new regulations requiring thoughtful comments does not overwhelm an already over-regulated industry. There also needs to be coordination among the agencies proposing new regulations to prevent duplicated and wasteful results. Consideration of possible changes to the Act is also appropriate.  We encourage Congress to carefully reconsider the structure, size, scope and funding of the Consumer Financial Protection Bureau and make adjustments in the derivatives and trading provisions. We also encourage Congress to continue oversight hearings holding the federal banking regulators accountable for their role in Dodd-Frank Act implementation. We are supportive of and are monitoring the following associated legislation although we expect neither to pass

S. 712 (DeMint, R-SC), The Financial Takeover Repeal Act of 2011. Twenty-four Republicans cosponsored the bill including U.S. Senators Saxby Chambliss and Johnny Isakson to repeal the Dodd-Frank Act.

H.R. 1315 (Duffy, R-WI), The Consumer Financial Protection Safety and Soundness Improvement Act of 2011. The U.S. House of Representatives recently passed this bill which would enable the Financial Services Oversight Council -- composed of the nation’s top regulators -- to overrule a Consumer Financial Protection Bureau regulation with a simple majority vote, instead of the two-thirds vote required by current law. The bill also would replace the director of the CFPB with a five-person commission similar to how the FDIC, SEC and other regulators are governed. Similar legislation has been proposed in the Senate
(
S. 737).

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GBA's professional staff represents the membership at the both the state and federal levels. Contact any of them with questions about issues:

Joe Brannen
President & CEO

Elizabeth Chandler
SVP, Government Relations

David Oliver
SVP, Communications & Marketing