The Regulatory Burdens on Bank Directors May Reach New Highs

Just as the U.S. Congress takes final legislative action whose objective is to provide regulatory relief (but see AABD's position on Section 405 of HR 3505), there is little relief for bank directors. In fact, as the attached documents reflect, the regulatory burdens on bank directors are high and, we believe, are getting higher.

A review of the documents which were prepared by Michael Bleier, General Counsel of Mellon Financial Corp and his staff, gives bank board members (with an emphasis on national bank directors), a valuable checklist on what the various laws, regulations, and policy statements and guidance say about their duties and responsibilities.

AABD urges the federal banking agencies to undertake a review of these laws, regulations and policy statements and guidance with the objective of reducing regulatory burdens on bank directors. Bank directors need to focus on what is important. The breadth and extent of the responsibilities of bank directors as reflected in the chart are so overwhelming that it is essential for the federal banking agencies to narrow down the list to help ensure that bank directors focus on the important issues facing their institution.

Matters to be Addressed by Board of Directors Pursuant to Statute or Regulation

Matters to be Addressed by Board of Directors Pursuant to Agency Guidance