Comments to FDIC re: State Nonmember Banks' Disclosure

Dear Mr. Feldman:

The American Bankers Association (ABA) appreciates the opportunity to comment on theFederal Deposit Insurance Corporation’s (FDIC) Notice of Proposed Rulemaking RIN 3064–AE65: Disclosure of Financial and Other Information by FDIC-Insured State Nonmember Banks(the Proposal). The Proposal rescinds and removes regulations relating to certain disclosures offinancial and other information by FDIC-insured state nonmember banks. The ABA supports theFDIC’s efforts to simplify regulations and remove unnecessary or redundant regulations.

With respect to the specific changes articulated in the proposal, the ABA agrees with the FDIC’sconclusion that 12 CFR part 350 is unnecessary due to the wide spread public availability of theinformation through other means including the FDIC’s website. For example, the informationrequired in part 350 is already available online through Call Reports and the Uniform BusinessPerformance Report. Therefore, the ABA fully supports this proposal and would like to thankthe FDIC for its efforts in removing this unnecessary regulation.

If you have any questions about these comments, please contact me at (202) 663-5318 or throughemail at [email protected].

Sincerely,

Joshua Stein