1.
Respondent complains that banks receive "way too much stuff from
regulators." This "stuff" includes numerous reports from economists,
journalists, reporters, and legal personnel. Respondent suggests there should be a
one-year moratorium on written material from the regulatory agencies.
I certainly agree that the material received by banks these days can be overwhelming. The
financial services industry has become such a competitive and dynamic business that it
seems like there is a never-ending supply of new studies, analysis, regulations and
policies. Once those have been issued, then along come interpretations of the regulations
and policies together with warnings of one type or another. I know that bankers receive
large amounts of material from their federal and state regulators, trade associations, and
other banking resource groups. Most of it is important to one sector of the industry or
another but not necessarily to all sectors. We all know that managing information
effectively is a major objective for everyone. The
difficulty for the FDIC is trying to determine when information is important to everyone
and when it is not. Sometimes we know the material is only relevant to a limited number of
banks, but it is difficult to know which banks. And even if we can say it doesn’t
apply to a bank or group of banks today, it might tomorrow. Thus, to be on the safe side
we normally send the material to all banks or at least to the state nonmember banks we
directly supervise. The FDIC is taking some positive steps to reduce at least some of the
hardcopy material. For example, we have upgraded our website to include a wealth of
material that bankers can review and determine for themselves if it is relevant and they
need a copy. In the past, much of this information would have been routinely mailed to the
banks. Now it is available for those who really want it or need it.
All the agencies are trying to do a better job coordinating
publications of new rules and policies on an interagency basis to ensure that banks
don’t receive multiple copies of the same document from different regulators. I know
we have a long way to go before we can truly cut down on excessive mailings, but we are
reviewing the problem and making a concerted effort to keep the mailings to a minimum.
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