affect community banks as well. That’s why ABA has been so vocal in calling on regulators to conduct a thorough quantitative impact study to determine the full extent of potential economic consequences, which they agreed to do in mid-October, alongside an extension of the comment period. However, simply collecting the data is not enough. Regulators and the public need ample time to review and evaluate the data to understand the full picture. The current timeline, even with the comment deadline extension, does not allow for that. Given the wide-ranging effect this rulemaking could have, the only appropriate course of action is for regulators to withdraw and repropose the rule after the data can be fully assessed. Changes to capital rules, even if they are only intended for the largest banks, will inevitably affect all parts of the banking system. This is too important to get wrong. Rob Nichols has been president and CEO of the American Bankers Association since 2015 after 10 years at the helm of the Financial Services Forum, a nonpartisan economic policy and advocacy organization. He also served in the George W. Bush administration as assistant secretary for public affairs at the Treasury Department. Robert S. Nichols President and CEO American Bankers Association RNichols@ABA.com Learn how budgeting for top-tier support and guidance can save your program money. That’s Bankers Alliance. info@bankersalliance.org or (833) 683-0701. Holding Company of Compliance Alliance and Review Alliance How would you use a Targeted Audit every month? Explore how monthly audits are tailored to fit your budget and your requirements. C M Y CM MY CY CMY K JANUARY/FEBRUARY2024 17
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