State Bankers Association Letter to President-Elect Trump Requesting Pause on Active Regulations

Dear President-Elect Trump:

We are reaching out to offer our congratulations once again on your election victory and to take this opportunity to highlight an important issue for your administration as you prepare for your second term in office. The American Bankers Association (ABA) represents banks of all sizes and business models across every community in the United States, and through our alliance with 52 state bankers associations, we serve as the collective voice of the banking industry. Together, ABA and these state associations are committed to fostering a highly competitive, resilient, and safe financial services industry to ensure the strength of America's banks and thereby the communities and the consumers they serve.

For the past several years, the federal banking agencies, the Consumer Financial Protection Bureau (CFPB), and the capital markets regulators have pursued an aggressive and misguided regulatory agenda, upending longstanding, tested banking practices with questionable and unnecessary policy actions that undermine our members' ability to provide capital and credit to Main Street. A new, commonsense approach to financial regulation is urgently needed, and that process can begin quickly by announcing an immediate regulatory pause and review.

From the CFPB's campaign against highly regulated, well-disclosed bank fees, which negatively impacts basic banking services like deposit accounts and credit cards, to the banking agencies' attempt to create a restrictive capital regime that would harm manufacturing, agriculture, and local governments, and M&A guidance designed to freeze and disincentivize transactions, over-regulation has created headwinds for banks, their customers, and our economy.

ABA and our member banks have participated in good faith in the regulatory process, offering data-driven feedback through comment letters and hundreds of banker meetings in an effort to shape reasonable, economically grounded regulatory outcomes. But all too often, the input from 4,500 banks was ignored, and in some cases, regulators made decisions to overshoot their legal authority altogether. This has led ABA and some state associations to file an unprecedented seven lawsuits challenging statutory overreach and process failures.

To ensure that the incoming teams in each of these agencies has the time and opportunity to review years of rulemaking, guidance, and other policy actions that have the effect of constraining market participants, we respectfully request that on January 20, your administration will direct all financial regulators – including independent agencies – to halt work on all open regulatory actions and to extend effective dates for final regulations until such time as new personnel are able to assess each action and determine next steps.

Download the letter to read the full text.