Pub. 6 2011-2012 Issue 4

www.nebankers.org 12 Extraordinary Service for Extraordinary Members. I AM TROUBLED BY WHAT I SEE TODAY in our regulatory system. Regula- tors hold all the cards, from the smallest operational details to the very survival of a bank. Banks are sworn to secrecy and as such each bank is on an island, relatively powerless to fight back. Most banks have deter- mined that fighting with their regula- tor is futile and foolish. But there are times when a fight, and the balance it would provide, is needed—not just for our banks but for the communities we serve and the economy in general. To that end, the Alliance of State Bankers Associations has created a tool that will hopefully lead to some balance and accountability. We call it the Regulatory Feedback Initiative. The tool consists of a confidential electronic platform where banks can anonymously provide details on their most recent examination or visita- tion. The information will be ag- gregated and analyzed on a national level so we can begin to identify dis- crepancies in how bank regulations are being enforced. These discrep- ancies could exist between different bank agencies, different geographic regions, or different examiners within the same agency. The timing of this initiative is critical considering the avalanche of new regulations that will be enforced for the first time in the coming months. In addition, banks in each par- ticipating state will be able to request a report from their state bankers associa- tion that summarizes the feedback of similarly situated banks to help them prepare for an upcoming exam. The goal is to avoid surprises and identify any inconsistencies. Finally, the initiative will arm the Nebraska Bankers Association with a statistically significant amount of hard data as the association strives to promote a better environment for its members. This data will be used to make our case with the regulators as well as members of Congress and the Administration. Everyone will have enough information to knowwhether a member financial institution is receiv- ing unfair treatment or appropriate and consistent regulatory scrutiny. With the support of the ABA and state bankers associations throughout the country, the survey is powered by Allegiance Inc., an independent third party with a reputation and track re- cord of collecting anonymous and pro- tected feedback from bank customers and employees. This will allow banks to shed their isolationwithout violating confidentiality or exposing themselves competitively. Time for Regulatory Transparency Kendell Holthus , Chairman, Nebraska Bankers Association Checks and balances are important. Without them power becomes concentrated and abused. Banks are one of the most heavily regulated businesses in America. Bank regulators have enormous power. Perhaps that is because there are few if any checks and balances on their power.