Promontory Chief Executive Officer Gene Ludwig published a column in American Banker on four key changes to the regulatory regime that would enhance the safety of the banking system. They include a penalty-free right to appeal regulatory enforcement actions, streamlining the regulatory agencies, simplifying Volcker Rule compliance, and putting the allowance for loan and lease losses back in the hands of banks.
“This is not an exhaustive list, but if these specific reforms are considered, we could reasonably expect they would reduce burden while not harming safety and soundness,” Ludwig said. “Indeed, I would argue that these changes would enhance the safety of the banking system. On the other hand, going too far in rolling back regulations and straying into areas that could weaken safety and soundness would again place our financial system and economy in a vulnerable state.”