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Banking Associations Question Legality of Capital Requirements

Banking Associations Question Legality of Capital Requirements

by Starling Insights

Starling Insights Editorial Board

Sep 25, 2023


Earlier this month, a group of US banking trade associations — including the  Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Institute of International Bankers, and others — published a letter to regulators. The trade associations claim that the US Federal Reserve, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation violated the law by failing to publish the analysis and data supporting their proposed changes to the capital requirements regime.

"The proposed regulations would significantly increase capital requirements for larger banks," the letter reads. "Yet in support of these substantial new requirements, the proposed rule repeatedly relies on data and analyses that the agencies have not made available to the public. This reliance on non-public information violates clear requirements under the Administrative Procedure Act that agencies must publicly disclose the data and analyses on which their rulemaking is based."

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