The American Bankers Association and the undersigned state bankers associations welcome the efforts of the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Board of Governors of the Federal Reserve System to simplify the generally applicable risk-based capital standards, particularly the Agencies’ work to address unnecessary complexity and provisions that needlessly inhibit economic growth or constrain banks in fulfilling their core functions in service to their customers. We view the Agencies’ final rule, entitled “Simplifications to the Capital Rule Pursuant to the Economic Growth and Regulatory Paperwork Reduction Act of 1996” (Simplification Rule), as an important early step to achieving a simpler and improved regulatory capital framework. It is important to many of our member banks. We request that the Agencies allow banks to engage in early adoption of the Simplification Rule prior to the April 1, 2020, effective date.
