CBA Letter of Support re S.1893, the Systemic Risk Designation Improvement Act

September 29, 2017


The Honorable Claire McCaskill                                             The Honorable David Perdue

U.S. Senate                                                                              U.S. Senate

503 Hart Senate Office Building                                             383 Russell Senate Office Building

Washington, D.C.  20002                                                        Washington, D.C.  20002


Dear Senators McCaskill and Perdue:


On behalf of the Consumer Bankers Association (CBA), I write in support of S. 1893, the

Systemic Risk Designation Improvement Act.  CBA is the voice of the retail banking industry whose products and services provide access to credit for consumers and small businesses.  Our members operate in all 50 states, serve more than 150 million Americans, and collectively hold two-thirds of the country’s total depository assets.


Currently, the Dodd-Frank Act designates a financial institution as systemically important if it meets or exceeds an arbitrary $50 billion asset threshold.  This asset threshold is a flawed approach used by the Financial Stability Oversight Council (FSOC) to assess the risk an institution poses to the American financial system.  S. 1893 would more appropriately gauge the systemic risk of an institution by measuring the complexity, scale, and activities of the institution. 


Requiring the evaluation of multiple risk factors, as opposed to the use of a simple asset size calculation, will provide regulators a more accurate systemic risk profile of an institution and can reduce unnecessary and burdensome compliance measures that increase operating costs and limit credit availability to consumers.  CBA strongly supports S. 1893 and encourages the Senate to pass this important legislation.





Richard Hunt

President and CEO

Consumer Bankers Association