The Economic Impact of the Bank Policy Institute Members
See below on how BPI members create jobs, grow small businesses, foster innovation and drive economic growth to power your every day.
BPI Members' National Economic Contributions
Collectively, BPI members employ nearly 2 million Americans, make 72% of all loans and nearly half of the nation’s small business loans, and serve as an engine for financial innovation and economic growth.
member branches nationally
in deposits held by BPI members in the U.S.
workers employed
in aggregate municipal loans and securities
in loans to businesses
in loans to households for things like mortgages, auto loans and credit cards
of small business loans are made by BPI members
Learn More About BPI Priorities
Data Privacy
Banks already comply with a range of domestic and international privacy and data protection laws. The overlapping and growing patchwork of state laws create complicated, duplicative and often conflicting rules.
While proper provisioning for loan loss reserves is an important accounting and regulatory policy objective, CECL’s approach would not accurately reflect banks’ credit losses, and CECL’s flaws would have significant negative consequences.
Stress testing is an important tool to evaluate risk and to serve as validation of the strength of the system. However, the current approach to CCAR inhibits economic growth and lacks appropriate levels of transparency, predictability, and accountability.
Anti-Money Laundering
The current AML/CFT framework is outdated and ill-suited to apprehending criminals and countering illicit financial activity.
Countercyclical Capital Buffer
CCyB is an unnecessary and counterproductive policy tool. Stress tests, which simulate how banks would fare under a severe economic downturn, already ensure that the largest banks have sufficient capital to deal with financial imbalances during a crisis.
Operational Risk
The current advanced measurement approach (AMA) for operational risk capital requires banks to develop an internal model that looks at both internal and external historical loss data to estimate operational risk. This approach to operational risk capital is flawed and unreliable, inherently backward-looking, and produced widely varying and highly volatile estimates.
Guidance on Guidance
The examination process for banks should be exclusively focused on practices that are material to their financial condition and based on statutory requirements and regulations. BPI encourages greater legal certainty around the examination process and supports the Interagency Guidance as a clear commitment to the rule of law.
GSIB Surcharge
GSIB surcharge framework has numerous weaknesses that should be addressed. Fundamentally, the methodology used to determine its calculation is not appropriately tied to empirical data, and ignores significant progress made by banks and regulators to reduce the impact of failure on the broader financial system.
International Banks
One of the key issues for regulating the local operations of international banks is making sure there is appropriate tailoring, consistent with sound principles of “national treatment” – that is, ensuring that non-U.S. banks are treated comparably to U.S. banks and that U.S. regulations do not discriminate against them.
S. 2155 Tailoring
The Bank Policy Institute supports S. 2155’s directive to better calibrate the financial regulatory system through tailoring. This new law should compel a variety of other regulatory changes and serve as a catalyst to recalibrate the regulatory framework for banks of all sizes.
Real-Time Payments
The private sector has met regulators’ demands to develop a safe, efficient and equitable real-time payment system accessible to all financial institutions. A government-run real-time payment system is unnecessary and will harm, rather than advance, regulators’ goal of faster payments by 2020.
Ending Anonymous Shell Companies
Congress should enact legislation to require FinCEN to collect ownership information at the time of incorporation and whenever such information changes and ensure such information is accessible to relevant stakeholders, such as FinCEN, law enforcement and financial institutions.
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