Americans for Tax Reform released a letter of support for S. 2155, Chairman Crapo’s banking bill that reduces regulatory barriers and increases Americans access to credit. This legislation in an important step in rolling back Dodd-Frank. 

The full letter can be found here and below. 


February 5th, 2018

The Honorable Mike Crapo
Chairman Senate Banking Committee
239 Dirksen Senate Office Building
Washington, DC 20510


Dear Chairman Crapo:

On behalf of Americans for Tax Reform I write to express support of S. 2155, the Economic Growth, Regulatory Relief and Consumer Protection Act, while the legislation can be improved, we feel it is an important step in the right direction.

Since the enactment of Dodd-Frank in 2010, US banks have disappeared at a rate faster than one per business day and fewer than 10 new banks have formed nationwide. The banks that have shouldered much of the regulatory burden are the regional and community banks. As a result, many of these banks have restricted mortgage lending and access to credit for small businesses and rural communities.

Under S. 2155, banking entities that meet certain capital requirements will be partially exempt from the Volcker Rule, which has hindered how institutions engaging in market marking activities. The legislation will also increase the threshold in which bank holding companies are subject to enhanced regulation from the current $50 billion in assets to $250 billion in assets. The bill also provides a path for banks between $100 billion to $250 billion in assets to be exempt from regulatory red tape after 18 months of the bills enactment or sooner. As a result, many of these banks will be able to provide more access to capital for their customers instead of spending more to comply with onerous regulations.

While the bill overall represents an important step forward, we have a concern over an amendment to be added to Title III of the Act which mandates credit reporting agencies provide their proprietary credit monitoring products “free of charge” and then opens them up to new liability which the trial bar will certainly try to exploit. Ultimately, these resources are not the governments to give away. Credit agencies should not bear financial burdens unless shown to be at fault in the case of a data breach or other negligence or malfeasance. Congress should also create market certainty through legislation instead of delegating rule making authority to agency administrators. 

The legislation can also be improved by extending regulatory relief to large financial institutions that consistently meet the enhanced prudential standards.

S. 2155 provides much needed relief to community and regional financial institutions while jumpstarting small businesses and hopeful homeowners access to capital. While there is still more work to be done, it is a positive step in the right direction, and we are encouraged by the Senate to continue to work and reform Dodd-Frank.


Grover G. Norquist
Americans for Tax Reform