Summary#
The Financial Institution Regulatory Tailoring Enhancement Act would amend four federal laws: the Consumer Financial Protection Act of 2010, the Bank Holding Company Act of 1956, the Truth in Lending Act, and the Economic Growth, Regulatory Relief, and Consumer Protection Act. Its stated goal is to raise the asset thresholds at which certain financial-institution requirements apply. It has been introduced in the House and is not law; whether it will pass is uncertain.
- It would change four asset thresholds from $10 billion to $50 billion.
- The changes cover CFPB supervision, Volcker Rule requirements, qualified-mortgage rules, and leverage and risk-based capital requirements.
- Institutions with assets between $10 billion and $50 billion are the group most likely to be affected, but other conditions in the laws may also matter.
- The bill does not create a new agency, a new benefit, or a tax or fee.
What it means for you#
- Financial institutions: Some institutions in the $10 billion-to-$50 billion range could receive different regulatory treatment. For CFPB supervision, the change would raise the asset threshold in the relevant provision. The bill does not spell out each institution’s resulting obligations.
- Mortgage borrowers: The bill raises the asset cutoff in a provision about qualified-mortgage treatment. It does not promise changes to mortgage availability, prices, or approval decisions.
- Consumers generally: The bill does not directly change consumer rights or create a new consumer service. The supplied text does not show exactly how supervision or other requirements would change for each institution.
- Taxpayers: The bill does not change taxes or appropriate money.
Money#
No cost information is in the available material.
- The bill does not authorize a stated amount of spending or staffing.
- It could change institutions’ compliance costs or regulators’ workload, but the materials give no estimates.
What is unclear#
- The parent laws are not supplied, so the exact current rules and all effects of changing each threshold could not be verified.
- The bill does not explain how other conditions in those laws interact with the new thresholds.
- It gives no effective date or transition rules.
- It does not define how an institution’s assets are measured for these changes.
- It does not explain how institutions affected by the CFPB supervision threshold would be supervised instead.
Case for#
- A possible argument for the bill is that regulatory treatment should account for an institution’s size, and that $10 billion may be too low a cutoff.
- Raising the thresholds could reduce the number of institutions subject to certain requirements or forms of supervision.
- The bill uses the same higher threshold across four areas, rather than making separate increases for each.
Case against#
- One concern is that institutions with assets as high as $50 billion could receive different treatment under provisions now tied to a $10 billion threshold.
- The bill does not explain why $50 billion is the right cutoff or how the change would affect oversight and compliance.
- Without the parent laws and details about other conditions, it is hard to tell which institutions would change status and what that would mean in practice.