Statement for the Record before the House Financial Services Committee on the Hearing Entitled "Dodd-Frank Turns 15"

The American Bankers Association (ABA) appreciates the opportunity to provide a Statement for the Record for this hearing entitled, "Dodd-Frank Turns 15: Lessons Learned and the Road Ahead." ABA is the voice of the nation's $24.5 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2.1 million people, safeguard $19.5 trillion in deposits and extend $12.8 trillion in loans.

Introduction

The Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA) (P.L. 111-203) was signed into law on July 21, 2010. This broad, complex legislation created a sweeping new financial services regime that ushered in significant regulatory and legal changes for the banking industry, impacting banks, the consumers and communities they serve, and the US economy for the last fifteen years. ABA believes a holistic review is needed to assess the costs and benefits of the Dodd-Frank Act (DFA) regulatory framework on banks of all sizes, mitigate burdens, and ensure that the laws and regulations have kept up with the fast pace of change over the 15 years since enactment.

DFA was enacted in response to the 2007-2009 global financial crisis, which highlighted gaps in the regulatory framework. ABA believes a robust legal and regulatory framework is essential to a strong banking system, financial markets, and the US economy. However, the complexity of DFA and the volume of regulations issued pursuant to that law include static regulations that often work at cross purposes, arbitrary asset thresholds, and redundant rules. Over the 15 years since the passage of DFA, there has been ongoing debate in Congress, among regulatory agencies, and in the private sector over the efficacy of the fundamental regulatory changes that resulted. This debate includes a robust discussion of the legislation's unintended consequences and the impact on the state of the U.S. banking industry and its ability to serve consumers and investors.

For example, Federal Reserve Governor Michelle Bowman, speaking at the ABA's Conference for Community Bankers in February 2025, called for a review of Dodd-Frank reforms, arguing that the regulations are outdated and overly restrictive.

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