Pub. 6 2011-2012 Issue 3

www.nebankers.org 10 Extraordinary Service for Extraordinary Members. O N THAT DAY, THE CONSUMER Financial Protection Bu- reau (CFPB) became re- s p o n s i b l e f o r c e r t a i n consumer protection rules formerly housed in seven other federal agen- cies. The Office of Thrift Supervi- sion closed, and the supervisory responsibility for federal savings as- sociations now rests with the Office of the Comptroller of the Currency. Regulation Q, which had prohibited the payment of interest on demand deposits, was repealed. Several other provisions also became effective on the one-year anniversary, and many more will be implemented over the next several months and years in what amounts to the largest-ever overhaul of financial services industry regulation. In marriage terms, a one-year anniversary is described as a paper anniversary. This is fitting for the Dodd-Frank Act: a paper anniversary for a lot of paper. To put things in scale, let’s look at some numbers. As of the date of its enactment, the Dodd-Frank Act (DFA) has resulted in: • 78 proposed banking rules totaling 2,845 Federal Register pages—which if laid end-to-end would be almost twice the height of the Empire State Building or almost four times the height of First National Tower in downtown Omaha. • 42 final rules spanning 1,097 Federal Register pages—roughly twice the height of theWashingtonMonument. • 552 estimated employees. • 28 new DFA-related offices created at 10 federal agencies. • $1.26 billion in funding through fiscal year 2012 to implement DFA at 10 federal agencies. We need to put the significance of these numbers to work in telling our story about what has clearly been a huge legislative and regulatory over-reaction. Toomany policymakers inWashington appear to have forgotten—or are over- looking—the indispensible role that banks play in a market economy. They have forgotten what banks do for their constituents and their communities. It’s up to all of us to remind them about the devastating impact that excessively burdensome laws and regulations have on banks, their com- munities, and our national economy. Z Washington Update While July 21 marked the one-year anniversary of the enactment of the Dodd-Frank Act, as well as the effective date for some of its major provisions, it’s no cause for celebration. Reach Frank Keating by e-mail at fkeating@aba.com. Dodd-Frank By the Numbers Frank Keating , President & CEO, American Bankers Association visit us online! www.nebankers.org