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The agencies’ decennial review of regulations that burden banks and their directors (due in 2016) so far omits numerous regulations that burden bank directors and entirely ignores hundreds of “guidance” that can overwhelm bank directors and cause them to become managers, not overseers.  AABD’s comment letters and its publication, Bank Director Regulatory Burden Report, 2014 Edition, explain the problem. Read the introduction to the Bank Director Regulatory Burden Report, 2014 Edition here.

9/2/14 AABD Letter to the OCC, Federal Reserve, and FDIC

9/3/15 AABD Letter to the OCC, Federal Reserve, and FDIC

Attachment to 9/3/15 AABD Letter