CBA Letter Supporting H.R. 3312, Systemic Risk Designation Improvement Act

The Honorable Paul Ryan                                                   The Honorable Nancy Pelosi

Speaker                                                                                   Minority Leader

House of Representatives                                                   House of Representatives

232 U.S. Capitol                                                                      204 U.S. Capitol

Washington, D.C. 20004                                                       Washington, D.C.  20004


Dear Speaker Ryan and Minority Leader Pelosi:


On behalf of the Consumer Bankers Association (CBA), I write in strong support of H.R. 3312, 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.  H.R. 3312 would 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 encourages the House to pass H.R. 3312.





Richard Hunt

President and CEO

Consumer Bankers Association