CBA Support Letter for SIFI H.R. 6392

Dear Speaker Ryan and Leader Pelosi,

On behalf of the Consumer Bankers Association (CBA) I write in support of H.R. 6392, the “Systemic Risk Designation Improvement Act of 2016,” sponsored by Representative Blaine Luetkemeyer (R-MO). 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 by an arbitrary $50 billion asset threshold. This approach is a flawed measurement tool used by the Financial Stability Oversight Council (FSOC) to assess the risk an institution poses to the American financial infrastructure.  H.R. 6392 appropriately changes the method used to determine if banks are “systemically important” by evaluating the complexity, scale, and activities of the individual institution.

Requiring FSOC to evaluate a number of factors, beyond asset size, will provide a more accurate risk profile of the bank and depiction as to whether an institution could be declared systemically important.  CBA supports passage of H.R. 6392 and encourages Members to vote in favor of this legislation.


Richard Hunt

President and CEO

Consumer Bankers Association


cc:        The Honorable Jeb Hensarling, Chairman, House Financial Services Committee   

            The Honorable Maxine Waters, Ranking Member, House Financial Services Committee  

            Members of the House of Representatives