This issue of Central Banker contains two articles on the recent Federal Reserve rulemaking that would limit debit interchange fees. (See articles "What if Debit Card Transactions Exchanged at Par?" and "How We Arrived at the Debit Card Interchange Fees and Routing Proposals".) Banks from across the country have voiced their opinions on this controversial rulemaking by using a public comment process that closed in late February. More than 7,000 comments were received by the Board of Governors.
The formal comment process on proposed regulations is one channel open to bankers to express opinions. There are many other channels, as well. Clearly, much communication occurs through the supervisory process. Moreover, it is not uncommon for Fed economists and regulators to speak at community and industry events in which bankers, community groups, academics and members of the general public are in attendance.
More recently, the Board of Governors announced a new communication vehicle for depository institutions, created through the formation of Community Depository Institutions Advisory Councils. (See article.) These councils, which have been established in all 12 Federal Reserve Districts, will be comprised of senior executives from community lending institutions (commercial banks, thrifts and credit unions with less than $10 billion in assets). At least twice per year, council members will meet to discuss a variety of issues, including local economic and banking conditions, and regulatory matters. The leader of each council will travel to Washington, D.C., twice per year to share the view of his or her District council with the Board of Governors.
Information sharing and dialogue is important for bankers and regulators alike. We view it as critical that the voice of “main street” lending institutions be considered in the formulation of good supervisory policy.
We will do our best to improve and grow the dialogue process. We hope you will feel comfortable contributing your voice!
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