Letter to the Federal Reserve and FDIC on the Proposals to Amend Regulation O

Ladies and Gentlemen:

The American Bankers Association ("ABA") and the ABA Securities Association ("ABASA") welcome the opportunity to comment on the notices of proposed rulemaking issued by the Federal
Reserve (the "Federal Reserve Proposal") to modernize Regulation O, and by the FDIC (the "FDIC Proposal", and together with the "Federal Reserve Proposal, the "Proposals").

We appreciate the efforts of the Federal Reserve and the FDIC (together, the "Agencies") to modernize, clarify and streamline, on a comprehensive basis, the rules governing extensions of credit to insiders, which the Agencies have not significantly updated for decades. We note that the Federal Reserve's proposal contains "extensive proposed changes and reorganization" to Regulation O, and that it is "restating Regulation O in its entirety as amended, rather than proposing revised regulation text only for the portions of Regulation O that would change". We also note that the FDIC's proposal seeks to align certain thresholds under the FDIC's rules governing extensions of credit to insiders with those included in the Federal Reserve Proposal, and would use the same methodology to update the thresholds going forward.

At the outset, we believe that the Bank Policy Institute ("BPI") will be or have submitted two separate comment letters on the Proposals. While we are not co-signatories to the letters, we are aware of the substance of the comments made in the letters and are fully supportive of them.

Download the comment letter to read the full text.