To the editors:

Guy Sims conveniently leaves out the details of S.2155 in his commentary titled Dodd-Frank reform: Oklahoma bankers applaud Senate from March 15. Here are some that should be noted.

It would raise the threshold for enhanced prudential regulation from $50 billion to $250 billion, exempting 25 of the largest 38 banks in the USA from the stricter Dodd-Frank rules that apply to large banks.

It would allow banks that are predominantly engaged in custody, safekeeping and asset servicing activities, specifically JP Morgan and Citibank (as well as Bank of New York, State Street, and Northern Trust), to omit assets held by central banks for purposes of calculating the supplementary leverage ratio, which means they don’t have to hold as much capital, which increases the likelihood of failure.

The CBO report on the bill says that it would “increase the likelihood that a large financial firm with assets of between $100 billion and $250 billion would fail.”

It reduces data collection by exempting banks that make 500 or fewer mortgages annually. This data, the loss of which the Consumer Financial Protection Bureau says would be concentrated in poor neighborhoods, is used to detect discriminatory lending practices.

Sen. Elizabeth Warren (D-Mass.) said, “To commemorate the 10th anniversary of the financial crisis, some Democrats are joining Republicans to pass a bill that will deregulate 30 of the 40 largest banks in the country that received a combined $50 billion in bailout money. This is not the work we should be doing.”

Brian Beuchaw
Oklahoma City

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Dodd-Frank reform: Oklahoma bankers applaud Senate by Guy Sims