H. Rept. 115-589 - FINANCIAL INSTITUTIONS EXAMINATION FAIRNESS AND REFORM ACT115th Congress (2017-2018)
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115th Congress } { Report
HOUSE OF REPRESENTATIVES
2d Session } { 115-589
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FINANCIAL INSTITUTIONS EXAMINATION FAIRNESS AND REFORM ACT
_______
March 6, 2018.--Committed to the Committee of the Whole House on the
State of the Union and ordered to be printed
_______
Mr. Hensarling, from the Committee on Financial Services, submitted the
following
R E P O R T
together with
MINORITY VIEWS
[To accompany H.R. 4545]
[Including cost estimate of the Congressional Budget Office]
The Committee on Financial Services, to whom was referred
the bill (H.R. 4545) to amend the Federal Financial
Institutions Examination Council Act of 1978 to improve the
examination of depository institutions, and for other purposes,
having considered the same, report favorably thereon without
amendment and recommend that the bill do pass.
Purpose and Summary
Introduced by Representative Tipton on December 4, 2017,
the ``Financial Institutions Examination Fairness and Reform
Act'' amends the Federal Financial Institutions Examination
Council Act of 1978 to establish deadlines within which
regulatory agencies must hold exit interviews and issue final
examination reports to financial institutions. The bill would
also provide supervised financial institutions the right to
have material supervisory determinations reviewed by a newly
created Independent Examination Review Director within the
Federal Financial Institutions Examination Council (FFIEC).
Background and Need for Legislation
Currently, federal law mandates a process to appeal
regulatory determinations including examination results. In
1994, to promote fairness and transparency in examinations,
Congress directed the federal regulators of financial
institutions to establish an ``independent intra-agency
appellate process'' by which an institution could seek review
of certain regulatory determinations, including (1) examination
ratings, (2) adequacy of loan loss reserves, and (3)
classifications of loans significant to the institution.\1\
Collectively, these determinations are known as ``material
supervisory determinations.'' Each federal financial regulator
has instituted its own unique process for appeals of material
supervisory determinations.
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\1\12 U.S. Code 4806.
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The Committee has heard testimony that the intra-agency
review to appeal material supervisory determinations provides
financial institutions with limited opportunities to challenge,
that the appeals process is not impartial, and that to either
appeal or oppose examination findings incurs retaliation from
regulators.
In a letter of support for H.R. 4545 dated December 6,
2017, the American Bankers Association wrote:
H.R. 4545 establishes clear standards by giving
supervised financial institutions the right to have
material supervisory determinations reviewed by an
independent Examination Review Director to ensure the
consistency of all examinations. The legislation would
also ensure that financial institutions receive timely
examination reports that include full documentation of
the information the regulators used to make their
determinations; would create an expedited process for
banks to appeal examination decisions; and would impose
safeguards to ensure institutions do not improperly use
the review process.
This legislation takes a major step toward a more
balanced and transparent approach regarding regulators'
decision-making during the examination process.
On December 12, 2017, the Independent Community Bankers
Association wrote in support of H.R. 4545, stating:
H.R. 4545 would create an Office of Independent
Examination Review within the Federal Financial
Institutions Examination Council (FFIEC) and give
financial institutions a right to an expedited,
independent review of a material supervisory
determination before the Office's Director . . .
. . . Taking the appeals process out of the examining
agencies is a positive step. While not completely
independent of the agencies the FFIEC is com posed of
each banking agency we expect that this level of
separation between the appeals process and the agencies
will provide a mea sure of distance and insulation.
Hearings
The Committee on Financial Services held a hearing
examining matters relating to H.R. 4545 on April 26, 2017, and
April 28, 2017.
Committee Consideration
The Committee on Financial Services met in open session on
December 13, 2017, and ordered H.R. 4545 to be reported
favorably to the House without amendment by a recorded vote of
50 yeas to 10 nays (FC-127), a quorum being present.
Committee Votes
Clause 3(b) of rule XIII of the Rules of the House of
Representatives requires the Committee to list the record votes
on the motion to report legislation and amendments thereto. The
first recorded vote (FC-126) was on an amendment offered by
Representative Waters (CA). The amendment failed by a vote of
26 ayes to 34 nays. The second recorded vote was on a motion by
Chairman Hensarling to report the bill favorably to the House
without amendment. The motion was agreed to by a recorded vote
of 50 yeas to 10 nays (FC-127), a quorum being present.
Committee Oversight Findings
Pursuant to clause 3(c)(1) of rule XIII of the Rules of the
House of Representatives, the findings and recommendations of
the Committee based on oversight activities under clause
2(b)(1) of rule X of the Rules of the House of Representatives,
are incorporated in the descriptive portions of this report.
Performance Goals and Objectives
Pursuant to clause 3(c)(4) of rule XIII of the Rules of the
House of Representatives, the Committee states that H.R. 4545
will reform the federal financial regulatory agency examination
process to make it more efficient, responsive, and fair for
financial institutions.
New Budget Authority, Entitlement Authority, and Tax Expenditures
In compliance with clause 3(c)(2) of rule XIII of the Rules
of the House of Representatives, the Committee adopts as its
own the estimate of new budget authority, entitlement
authority, or tax expenditures or revenues contained in the
cost estimate prepared by the Director of the Congressional
Budget Office pursuant to section 402 of the Congressional
Budget Act of 1974.
Congressional Budget Office Estimates
Pursuant to clause 3(c)(3) of rule XIII of the Rules of the
House of Representatives, the following is the cost estimate
provided by the Congressional Budget Office pursuant to section
402 of the Congressional Budget Act of 1974:
U.S. Congress,
Congressional Budget Office,
Washington, DC, February 12, 2018.
Hon. Jeb Hensarling,
Chairman, Committee on Financial Services,
House of Representatives, Washington, DC.
Dear Mr. Chairman: The Congressional Budget Office has
prepared the enclosed cost estimate for H.R. 4545, the
Financial Institutions Examination Fairness and Reform Act.
If you wish further details on this estimate, we will be
pleased to provide them. The CBO staff contact is Stephen
Rabent.
Sincerely,
Keith Hall,
Director.
Enclosure.
H.R. 4545--Financial Institutions Examination Fairness and Reform Act
Summary: H.R. 4545 would establish the Office of
Independent Examination Review within the Federal Financial
Institutions Examination Council (FFIEC). The new office would
investigate complaints from financial institutions about
examinations, regularly review the quality of examinations, and
adjudicate appeals of determinations made within examinations.
CBO estimates that enacting H.R. 4545 would increase net
direct spending by $82 million and reduce revenues by $41
million over the 2018-2027 period. In total, CBO estimates,
enacting H.R. 4545 would increase budget deficits by $123
million over the 2018-2027 period. Implementing H.R. 4545 would
not affect spending subject to appropriation.
Because enacting the bill would affect direct spending and
revenues, pay-as-you-go procedures apply.
CBO estimates that enacting H.R. 4545 would not increase
net direct spending or on-budget deficits by more than $2.5
billion in any of the four consecutive 10-year periods
beginning in 2028.
H.R. 4545 contains no intergovernmental mandates as defined
in the Unfunded Mandates Reform Act (UMRA). If financial
regulators increase fees to offset some of the costs of
implementing the bill, H.R. 4545 would increase the cost of an
existing mandate on private entities required to pay those
fees. Using information from the affected agencies, CBO
estimates that the incremental cost of the mandate would fall
well below the annual threshold for private-sector mandates
established in UMRA ($156 million in 2017, adjusted annually
for inflation).
Estimated cost to the Federal Government: The estimated
budgetary effect of H.R. 4545 is shown in the following table.
The costs of the legislation fall within budget function 370
(commerce and housing credit).
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By fiscal year, in millions of dollars--
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2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018-2022 2018-2027
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INCREASES IN DIRECT SPENDING
Office of Independent Examination Review:
Estimated Budget Authority.............................. 0 6 9 9 9 9 9 9 9 10 34 79
Estimated Outlays....................................... 0 5 8 9 9 9 9 9 9 10 33 78
Other Administrative Costs:
Estimated Budget Authority.............................. 0 * * * 1 1 1 1 1 1 2 5
Estimated Outlays 0 * * * 1 1 1 1 1 1 2 4
Total:
Estimated Budget:
Authority........................................... 0 7 9 9 9 9 10 10 10 10 36 84
Estimated Outlays................................... 0 6 9 9 9 9 10 10 10 10 35 82
DECREASES IN REVENUES
Federal Reserve............................................. 0 -3 -4 -4 -5 -5 -5 -5 -5 -5 -17 -41
NET INCREASE IN THE DEFICIT FROM CHANGES IN DIRECT SPENDING AND REVENUES
Effect on the Deficit....................................... 0 9 13 14 14 14 14 15 15 15 50 123
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Components may not sum to totals because of rounding; * = between zero and $500,000.
Basis of estimate: For this estimate, CBO assumes that H.R.
4545 will be enacted near the end of fiscal year 2018.
Estimated spending is based on historical patterns for similar
regulatory activities.
Background
The FFIEC was established to promote uniformity in
supervision of financial institutions. Generally, the majority
of its operating costs are borne by four financial regulatory
agencies: the Office of the Comptroller of the Currency (OCC),
the Federal Deposit Insurance Corporation (FDIC), the National
Credit Union Administration (NCUA), and the Federal Reserve
System. Some costs currently are covered by the Consumer
Financial Protection Bureau (CFPB) and the Department of
Housing and Urban Development. Of the regulators, the OCC, the
FDIC, and the NCUA collect fees to offset operating costs.
Because of lags between the time costs are incurred by some of
the financial regulators and when additional fees would be
imposed, not all additional costs resulting from the bill would
be recovered within the next 10 years. Costs borne by the CFPB
are recorded in the budget as direct spending because the
agency has permanent authority to spend amounts transferred
from the Federal Reserve. Finally, costs incurred by the
Federal Reserve would reduce remittances to the Treasury (which
are recorded as revenues).
Currently, the FFIEC is supported by 16 people who are
employed by the regulatory agencies but assigned to the
council.
Office of Independent Examination Review
CBO expects that establishing the new office would require
a significant increase in the council's staff. Using
information from the FFIEC, CBO estimates that an additional 60
staff positions would be needed to meet the bill's requirements
to investigate and resolve appeals and to review examination
procedures. Under H.R. 4545, the costs of the office would be
covered by the OCC, the NCUA, the FDIC, the CFPB, and the
Federal Reserve. CBO expects that it would take several years
to reach the new staffing level and that the costs would be
spread evenly among the five regulatory agencies.
Based on the average cost for each employee of $225,000,
CBO estimates that establishing the office would cost $192
million over the 2018-2027 period to supply the FFIEC with
additional people and to cover other operating expenses. That
amount reflects some savings to the regulators because a
portion of the complaints they receive under current law would
instead be handled by FFIEC. CBO estimates that 80 percent of
the net cost, or $154 million, would be spread equally among
the FDIC, the OCC, the NCUA and the CFPB--increasing gross
direct spending by that amount.
Three of those regulators collect fees to offset operating
costs. CBO estimates that over the 10-year period, additional
fees collected from financial institutions would total about
$76 million. On net, CBO estimates, enacting H.R. 4545 would
increase direct spending by $78 million over the 2018-2027
period.
The remaining 20 percent of the costs would be charged to
the Federal Reserve (see ``The Federal Reserve'' below).
Other administrative costs
H.R. 4545 also would establish deadlines for the federal
banking regulators to complete examination reports. Using
information from those agencies, CBO estimates that they would
need to hire additional staff to meet the deadlines established
in the bill, at an estimated net cost of about $4 million over
the 2018-2027 period. That cost accounts for anticipated
increases in fee collections during the period.
The Federal Reserve
Because the Federal Reserve remits its profits to the
Treasury, increasing the costs of operating the Federal Reserve
reduces federal revenues. CBO estimates that the portion of the
costs to establish the Office of Independent Examination Review
that would be allocated to the Federal Reserve, combined with
additional administrative costs to meet deadlines established
under the bill, would average about $4 million per year over
the 2018-2027 period. CBO estimates that revenues would decline
by $42 million over the next 10 years under H.R. 4545.
Pay-As-You-Go considerations: The Statutory Pay-As-You-Go
Act of 2010 establishes budget-reporting and enforcement
procedures for legislation affecting direct spending or
revenues. The net changes in outlays and revenues that are
subject to those pay-as-you-go procedures are shown in the
following table.
CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 4545, AS ORDERED REPORTED BY THE HOUSE COMMITTEE ON FINANCIAL SERVICES ON DECEMBER 13, 2017
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By fiscal year, in millions of dollars--
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2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018-2022 2018-2027
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NET INCREASE IN THE DEFICIT
Statutory Pay-As-You-Go Impact.............................. 0 9 13 14 14 14 14 15 15 15 50 123
Memorandum:
Changes in Outlays...................................... 0 6 9 9 9 9 10 10 10 10 33 82
Changes in Revenues..................................... 0 -3 -4 -4 -5 -5 -5 -5 -5 -5 -17 -41
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Increase in long-term direct spending and deficits: CBO
estimates that enacting H.R. 4545 would not increase net direct
spending or on-budget deficits by more than $2.5 billion in any
of the four consecutive 10-year periods beginning in 2028.
Mandates: H.R. 4545 contains no intergovernmental mandates
as defined in UMRA.
If financial regulators increased fees to offset some of
the costs of implementing the new activities of the FFIEC, the
bill would increase the cost of an existing mandate on private
entities required to pay those fees. Using information from the
affected agencies, CBO estimates that the incremental cost of
the mandate would amount to no more than $25 million over the
2018-2022 period and would fall well below the annual threshold
for private-sector mandates established in UMRA ($156 million
in 2017, adjusted annually for inflation).
Estimate prepared by: Federal costs: Stephen Rabent and
Sarah Puro, Revenues: Nathaniel Frentz, Mandates: Rachel
Austin.
Estimate approved by: H. Samuel Papenfuss, Deputy Assistant
Director for Budget Analysis.
Federal Mandates Statement
This information is provided in accordance with section 423
of the Unfunded Mandates Reform Act of 1995.
The Committee has determined that the bill does not contain
Federal mandates on the private sector. The Committee has
determined that the bill does not impose a Federal
intergovernmental mandate on State, local, or tribal
governments.
Advisory Committee Statement
No advisory committees within the meaning of section 5(b)
of the Federal Advisory Committee Act were created by this
legislation.
Applicability to Legislative Branch
The Committee finds that the legislation does not relate to
the terms and conditions of employment or access to public
services or accommodations within the meaning of the section
102(b)(3) of the Congressional Accountability Act.
Earmark Identification
With respect to clause 9 of rule XXI of the Rules of the
House of Representatives, the Committee has carefully reviewed
the provisions of the bill and states that the provisions of
the bill do not contain any congressional earmarks, limited tax
benefits, or limited tariff benefits within the meaning of the
rule.
Duplication of Federal Programs
In compliance with clause 3(c)(5) of rule XIII of the Rules
of the House of Representatives, the Committee states that no
provision of the bill establishes or reauthorizes: (1) a
program of the Federal Government known to be duplicative of
another Federal program; (2) a program included in any report
from the Government Accountability Office to Congress pursuant
to section 21 of Public Law 111-139; or (3) a program related
to a program identified in the most recent Catalog of Federal
Domestic Assistance, published pursuant to the Federal Program
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No.
98-169).
Disclosure of Directed Rulemaking
Pursuant to section 3(i) of H. Res. 5, (115th Congress),
the following statement is made concerning directed rule
makings: The Committee estimates that the bill requires no
directed rule makings within the meaning of such section.
Section-by-Section Analysis of the Legislation
Section 1. Short title
This section cites H.R. 4545 as the ``Financial
Institutions Examination Fairness and Reform Act.''
Section 2. Amendment to definition of financial institution
This section amends the definition of ``financial
institution'' in the Federal Financial Institutions Examination
Council Act of 1978 to include, for the purposes of sections
1012, 1013, and 1014, a nondepository covered person subject to
supervision by the Bureau of Consumer Financial Protection.
Section 3. Timeliness of examination reports
This section amends the Federal Financial Institutions
Examination Council Act of 1978 to require a federal financial
institutions regulatory agency to make a final examination
report to a financial institution within 60 days after the
later of: (1) the exit interview for an examination of the
institution, or (2) the provision of additional information by
the institution relating to the examination.
Section 4. Independent Examination Review Director
This section establishes in the Federal Financial
Institutions Examination Council (FFIEC) the Office of
Independent Examination Review, headed by a Director appointed
by the FFIEC, but independent from any member agency of the
FFIEC.
Section 5. Right to independent review of material supervisory
determinations
This section entitles a financial institution to appeal a
material supervisory determination contained in a final report
of examination; requires the Director to determine the merits
of the appeal and grants a financial institution the right to
petition for judicial review of the Director's decision.
This section allows for a limited review by the FFIEC if
there is substantial evidence that the Director's decision
would pose an imminent threat to the safety and soundness of
the financial institution.
This section also prohibits a federal financial
institutions regulatory agency from retaliating against a
financial institution or delaying or denying any agency action
that would benefit a financial institution.
Section 6. Additional amendments
This section requires the Consumer Financial Protection
Bureau to establish an independent intra-agency appellate
process in connection with the regulatory appeals process, and
establishes safeguards to protect an insured depository
institution or insured credit union from retaliation by any
federal banking agency for exercising its rights.
Changes in Existing Law Made by the Bill, as Reported
In compliance with clause 3(e) of rule XIII of the Rules of
the House of Representatives, changes in existing law made by
the bill, as reported, are shown as follows (existing law
proposed to be omitted is enclosed in black brackets, new
matter is printed in italic, and existing law in which no
change is proposed is shown in roman):
Changes in Existing Law Made by the Bill, as Reported
In compliance with clause 3(e) of rule XIII of the Rules of
the House of Representatives, changes in existing law made by
the bill, as reported, are shown as follows (existing law
proposed to be omitted is enclosed in black brackets, new
matter is printed in italic, and existing law in which no
change is proposed is shown in roman):
FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL ACT OF 1978
* * * * * * *
TITLE X--FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL
* * * * * * *
definitions
Sec. 1003. As used in this title--
[(1) the term ``Federal financial institutions
regulatory agencies'' means the Office of the
Comptroller of the Currency, the Board of Governors of
the Federal Reserve System, the Federal Deposit
Insurance Corporation, the Office of Thrift
Supervision, and the National Credit Union
Administration;]
(1) the term ``Federal financial institutions
regulatory agencies''--
(A) means the Office of the Comptroller of
the Currency, the Board of Governors of the
Federal Reserve System, the Federal Deposit
Insurance Corporation, and the National Credit
Union Administration; and
(B) for purposes of sections 1012, 1013, and
1014, includes the Bureau of Consumer Financial
Protection;
(2) the term ``Council'' means the Financial
Institutions Examination Council; and
[(3) the term ``financial institution'' means a
commercial bank, a savings bank, a trust company, a
savings association, a building and loan association, a
homestead association, a cooperative bank, or a credit
union;]
(3) the term ``financial institution''--
(A) means a commercial bank, a savings bank,
a trust company, a savings association, a
building and loan association, a homestead
association, a cooperative bank, or a credit
union; and
(B) for purposes of sections 1012, 1013, and
1014, includes a nondepository covered person
subject to supervision by the Bureau of
Consumer Financial Protection under section
1024 of the Consumer Financial Protection Act
of 2010 (12 U.S.C. 5514).
* * * * * * *
expenses of the council
Sec. 1005. [One-fifth] One-fourth of the costs and expenses
of the Council, including the salaries of its employees, shall
be paid by each of the Federal financial institutions
regulatory agencies. Annual assessments for such share shall be
levied by the Council based upon its projected budget for the
year, and additional assessments may be made during the year if
necessary.
* * * * * * *
SEC. 1012. TIMELINESS OF EXAMINATION REPORTS.
(a) In General.--
(1) Final examination report.--A Federal financial
institutions regulatory agency shall provide a final
examination report to a financial institution not later
than 60 days after the later of--
(A) the exit interview for an examination of
the institution; or
(B) the provision of additional information
by the institution relating to the examination.
(2) Exit interview.--If a financial institution is
not subject to a resident examiner program, the exit
interview shall occur not later than the end of the 9-
month period beginning on the commencement of the
examination, except that such period may be extended by
the Federal financial institutions regulatory agency by
providing written notice to the institution and the
Independent Examination Review Director describing with
particularity the reasons that a longer period is
needed to complete the examination.
(b) Examination Materials.--Upon the request of a financial
institution, the Federal financial institutions regulatory
agency shall include with the final report an appendix listing
all examination or other factual information relied upon by the
agency in support of a material supervisory determination.
SEC. 1013. OFFICE OF INDEPENDENT EXAMINATION REVIEW.
(a) Establishment.--There is established in the Council an
Office of Independent Examination Review (the ``Office'').
(b) Head of Office.--There is established the position of the
Independent Examination Review Director (the ``Director''), as
the head of the Office. The Director shall be appointed by the
Council and shall be independent from any member agency of the
Council.
(c) Term.--The Director shall serve for a term of 5 years,
and may be appointed to serve a subsequent 5-year term.
(d) Staffing.--The Director is authorized to hire staff to
support the activities of the Office.
(e) Duties.--The Director shall--
(1) receive and, at the Director's discretion,
investigate complaints from financial institutions,
their representatives, or another entity acting on
behalf of such institutions, concerning examinations,
examination practices, or examination reports;
(2) hold meetings, at least once every three months
and in locations designed to encourage participation
from all sections of the United States, with financial
institutions, their representatives, or another entity
acting on behalf of such institutions, to discuss
examination procedures, examination practices, or
examination policies;
(3) in accordance with subsection (f), review
examination procedures of the Federal financial
institutions regulatory agencies to ensure that the
written examination policies of those agencies are
being followed in practice and adhere to the standards
for consistency established by the Council;
(4) conduct a continuing and regular review of
examination quality assurance for all examination types
conducted by the Federal financial institutions
regulatory agencies;
(5) adjudicate any supervisory appeal initiated under
section 1014; and
(6) report annually to the Committee on Financial
Services of the House of Representatives, the Committee
on Banking, Housing, and Urban Affairs of the Senate,
and the Council, on the reviews carried out pursuant to
paragraphs (3) and (4), including compliance with the
requirements set forth in section 1012 regarding
timeliness of examination reports, and the Council's
recommendations for improvements in examination
procedures, practices, and policies.
(f) Standard for Reviewing Examination Procedures.--In
conducting reviews pursuant to subsection (e)(4), the Director
shall prioritize factors relating to the safety and soundness
of the financial system of the United States.
(g) Removal.--If the Director is removed from office, the
Council shall communicate in writing the reasons for any such
removal to the Committee on Financial Services of the House of
Representatives and the Committee on Banking, Housing, and
Urban Affairs of the Senate not later than 30 days before the
removal.
(h) Confidentiality.--The Director shall keep confidential
all meetings with, discussions with, and information provided
by financial institutions.
SEC. 1014. RIGHT TO INDEPENDENT REVIEW OF MATERIAL SUPERVISORY
DETERMINATIONS.
(a) In General.--A financial institution shall have the right
to obtain an independent review of a material supervisory
determination contained in a final report of examination.
(b) Notice.--
(1) Timing.--A financial institution seeking review
of a material supervisory determination under this
section shall file a written notice with the
Independent Examination Review Director (the
``Director'') within 60 days after receiving the final
report of examination that is the subject of such
review.
(2) Identification of determination.--The written
notice shall identify the material supervisory
determination that is the subject of the independent
examination review, and a statement of the reasons why
the institution believes that the determination is
incorrect or should otherwise be modified.
(3) Information to be provided to institution.--Any
information relied upon by the agency in the final
report that is not in the possession of the financial
institution may be requested by the financial
institution and shall be delivered promptly by the
agency to the financial institution.
(c) Right to Hearing.--
(1) In general.--The Director shall determine the
merits of the appeal on the record or, at the financial
institution's election, shall refer the appeal to an
Administrative Law Judge to conduct a confidential
hearing pursuant to the procedures set forth under
sections 556 and 557 of title 5, United States Code,
which hearing shall take place not later than 60 days
after the petition for review was received by the
Director, and to issue a proposed decision to the
Director based upon the record established at such
hearing.
(2) Standard of review.--In rendering a determination
or recommendation under this subsection, neither the
Administrative Law Judge nor the Director shall defer
to the opinions of the examiner or agency, but shall
conduct a de novo review to independently determine the
appropriateness of the agency's decision based upon the
relevant statutes, regulations, and other appropriate
guidance, as well as evidence adduced at any hearing.
(d) Final Decision.--A decision by the Director on an
independent review under this section shall--
(1) be made not later than 60 days after the record
has been closed; and
(2) subject to subsection (e), be deemed a final
agency action and shall bind the agency whose
supervisory determination was the subject of the review
and the financial institution requesting the review.
(e) Limited Review by FFIEC.--
(1) In general.--If the agency whose supervisory
determination was the subject of the review believes
that the Director's decision under subsection (d) would
pose an imminent threat to the safety and soundness of
the financial institution, such agency may file a
written notice seeking review of the Director's
decision with the Council within 10 days of receiving
the Director's decision.
(2) Standard of review.--In making a determination
under this subsection, the Council shall conduct a
review to determine whether there is substantial
evidence that the Director's decision would pose an
imminent threat to the safety and soundness of the
financial institution.
(3) Final determination.--A determination by the
Council shall--
(A) be made not later than 30 days after the
filing of the notice pursuant to paragraph (1);
and
(B) be deemed a final agency action and shall
bind the agency whose supervisory determination
was the subject of the review and the financial
institution requesting the review.
(f) Right to Judicial Review.--A financial institution shall
have the right to petition for review of final agency action
under this section by filing a Petition for Review within 60
days of the Director's decision or the Council's decision in
the United States Court of Appeals for the District of Columbia
Circuit or the Circuit in which the financial institution is
located.
(g) Report.--The Director shall report annually to the
Committee on Financial Services of the House of Representatives
and the Committee on Banking, Housing, and Urban Affairs of the
Senate on actions taken under this section, including the types
of issues that the Director has reviewed and the results of
those reviews. In no case shall such a report contain
information about individual financial institutions or any
confidential or privileged information shared by financial
institutions.
(h) Retaliation Prohibited.--A Federal financial institutions
regulatory agency may not--
(1) retaliate against a financial institution,
including service providers, or any institution-
affiliated party (as defined under section 3 of the
Federal Deposit Insurance Act), for exercising
appellate rights under this section; or
(2) delay or deny any agency action that would
benefit a financial institution or any institution-
affiliated party on the basis that an appeal under this
section is pending under this section.
(i) Rule of Construction.--Nothing in this section may be
construed--
(1) to affect the right of a Federal financial
institutions regulatory agency to take enforcement or
other supervisory actions related to a material
supervisory determination under review under this
section; or
(2) to prohibit the review under this section of a
material supervisory determination with respect to
which there is an ongoing enforcement or other
supervisory action.
----------
RIEGLE COMMUNITY DEVELOPMENT AND REGULATORY IMPROVEMENT ACT OF 1994
* * * * * * *
TITLE III--PAPERWORK REDUCTION AND REGULATORY IMPROVEMENT
* * * * * * *
SEC. 309. REGULATORY APPEALS PROCESS, OMBUDSMAN, AND ALTERNATIVE
DISPUTE RESOLUTION.
(a) In General.--Not later than 180 days after the date of
enactment of this Act, each appropriate Federal banking agency,
the Bureau of Consumer Financial Protection, and the National
Credit Union Administration Board shall establish an
independent intra-agency appellate process. The process shall
be available to review material supervisory determinations made
at insured depository institutions or at insured credit unions
that the agency supervises.
(b) Review Process.--In establishing the independent
appellate process under subsection (a), each agency shall
ensure that--
(1) any appeal of a material supervisory
determination by an insured depository institution or
insured credit union is heard and decided
expeditiously; and
(2) appropriate safeguards exist for protecting [the
appellant from retaliation by agency examiners] the
insured depository institution or insured credit union
from retaliation by the agencies referred to in
subsection (a) .
For purposes of this subsection and subsection (e), retaliation
includes delaying consideration of, or withholding approval of,
any request, notice, or application that otherwise would have
been approved, but for the exercise of the institution's or
credit union's rights under this section.
(c) Comment Period.--Not later than 90 days after the date of
enactment of this Act, each appropriate Federal banking agency
and the National Credit Union Administration Board shall
provide public notice and opportunity for comment on proposed
guidelines for the establishment of an appellate process under
this section.
(d) Agency Ombudsman.--
(1) Establishment required.--Not later than 180 days
after the date of enactment of this Act, each Federal
banking agency and the National Credit Union
Administration Board shall appoint an ombudsman.
(2) Duties of ombudsman.--The ombudsman appointed in
accordance with paragraph (1) for any agency shall--
(A) act as a liaison between the agency and
any affected person with respect to any problem
such party may have in dealing with the agency
resulting from the regulatory activities of the
agency; and
(B) assure that safeguards exist to encourage
complainants to come forward and preserve
confidentiality.
(e) Alternative Dispute Resolution Pilot Program.--
(1) In general.--Not later than 18 months after the
date of enactment of this Act, each Federal banking
agency and the National Credit Union Administration
Board shall develop and implement a pilot program for
using alternative means of dispute resolution of issues
in controversy (hereafter in this section referred to
as the ``alternative dispute resolution program'') that
is consistent with the requirements of subchapter IV of
chapter 5 of title 5, United States Code, if the
parties to the dispute, including the agency, agree to
such proceeding.
(2) Standards.--An alternative dispute resolution
pilot program developed under paragraph (1) shall--
(A) be fair to all interested parties to a
dispute;
(B) resolve disputes expeditiously; [and]
(C) be less costly than traditional means of
dispute resolution, including litigation[.];
and
(D) ensure that appropriate safeguards exist
for protecting the insured depository
institution or insured credit union from
retaliation by any agency referred to in
subsection (a) for exercising its rights under
this subsection.
(3) Independent evaluation.--Not later than 18 months
after the date on which a pilot program is implemented
under paragraph (1), the Administrative Conference of
the United States shall submit to the Congress a report
containing--
(A) an evaluation of that pilot program;
(B) the extent to which the pilot programs
meet the standards established under paragraph
(2);
(C) the extent to which parties to disputes
were offered alternative means of dispute
resolution and the frequency with which the
parties, including the agencies, accepted or
declined to use such means; and
(D) any recommendations of the Conference to
improve the alternative dispute resolution
procedures of the Federal banking agencies and
the National Credit Union Administration Board.
(4) Implementation of program.--At any time after
completion of the evaluation under paragraph (3)(A),
any Federal banking agency and the National Credit
Union Administration Board may implement an alternative
dispute resolution program throughout the agency,
taking into account the results of that evaluation.
(5) Coordination with existing agency adr programs.--
(A) Evaluation required.--If any Federal
banking agency or the National Credit Union
Administration maintains an alternative dispute
resolution program as of the date of enactment
of this Act under any other provision of law,
the Administrative Conference of the United
States shall include such program in the
evaluation conducted under paragraph (3)(A).
(B) Multiple adr programs.--No provision of
this section shall be construed as precluding
any Federal banking agency or the National
Credit Union Administration Board from
establishing more than 1 alternative means of
dispute resolution.
(f) Definitions.--For purposes of this section, the following
definitions shall apply:
(1) Material supervisory determinations.--The term
``material supervisory determinations''--
(A) includes determinations relating to--
(i) examination ratings;
(ii) the adequacy of loan loss
reserve provisions; [and]
(iii) loan classifications on loans
that are significant to an institution;
[and]
(iv) any issue specifically listed in
an exam report as a matter requiring
attention by the institution's
management or board of directors; and
(v) any suspension or removal of an
institution's status as eligible for
expedited processing of applications,
requests, notices, or filings on the
grounds of a supervisory or compliance
concern, regardless of whether that
concern has been cited as a basis for
another material supervisory
determination or matter requiring
attention in an examination report,
provided that the conduct at issue did
not involve violation of any criminal
law; and
(B) does not include a determination by a
Federal banking agency or the National Credit
Union Administration Board to appoint a
conservator or receiver for an insured
depository institution or a liquidating agent
for an insured credit union, as the case may
be, or a decision to take action pursuant to
section 38 of the Federal Deposit Insurance Act
or section 212 of the Federal Credit Union Act,
as appropriate.
(2) Independent appellate process.--The term
``independent appellate process'' means a review by an
agency official who does not directly or indirectly
report to the agency official who made the material
supervisory determination under review.
(3) Alternative means of dispute resolution.--The
term ``alternative means of dispute resolution'' has
the meaning given to such term in section 571 of title
5, United States Code.
(4) Issues in controversy.--The term ``issues in
controversy'' means--
(A) any final agency decision involving any
claim against an insured depository institution
or insured credit union for which the agency
has been appointed conservator or receiver or
for which a liquidating agent has been
appointed, as the case may be;
(B) any final action taken by an agency in
the agency's capacity as conservator or
receiver for an insured depository institution
or by the liquidating agent appointed for an
insured credit union; and
(C) any other issue for which the appropriate
Federal banking agency or the National Credit
Union Administration Board determines that
alternative means of dispute resolution would
be appropriate.
(g) Effect on Other Authority.--Nothing in this section shall
affect the authority of an appropriate Federal banking agency
or the National Credit Union Administration Board to take
enforcement or supervisory action.
* * * * * * *
----------
FEDERAL CREDIT UNION ACT
* * * * * * *
TITLE II--SHARE INSURANCE
* * * * * * *
requirements governing insured credit unions
Sec. 205. (a) Insurance Logo.--
(1) Insured credit unions.--
(A) In general.--Each insured credit union
shall display at each place of business
maintained by that credit union a sign or signs
relating to the insurance of the share accounts
of the institution, in accordance with
regulations to be prescribed by the Board.
(B) Statement to be included.--Each sign
required under subparagraph (A) shall include a
statement that insured share accounts are
backed by the full faith and credit of the
United States Government.
(2) Regulations.--The Board shall prescribe
regulations to carry out this subsection, including
regulations governing the substance of signs required
by paragraph (1) and the manner of display or use of
such signs.
(3) Penalties.--For each day that an insured credit
union continues to violate this subsection or any
regulation issued under this subsection, it shall be
subject to a penalty of not more than $100, which the
Board may recover for its use.
(b)(1) Except as provided in paragraph (2), no insured credit
union shall, without the prior approval of the Board--
(A) merge or consolidate with any noninsured credit
union or institution;
(B) assume liability to pay any member accounts in,
or similar liabilities of, any noninsured credit union
or institution;
(C) transfer assets to any noninsured credit union or
institution in consideration of the assumption of
liabilities for any portion of the member accounts in
such insured credit union; or
(D) convert into a noninsured credit union or
institution.
(2) Conversion of insured credit unions to mutual
savings banks.--
(A) In general.--Notwithstanding paragraph
(1), an insured credit union may convert to a
mutual savings bank or savings association (if
the savings association is in mutual form), as
those terms are defined in section 3 of the
Federal Deposit Insurance Act, without the
prior approval of the Board, subject to the
requirements and procedures set forth in the
laws and regulations governing mutual savings
banks and savings associations.
(B) Conversion proposal.--A proposal for a
conversion described in subparagraph (A) shall
first be approved, and a date set for a vote
thereon by the members (either at a meeting to
be held on that date or by written ballot to be
filed on or before that date), by a majority of
the directors of the insured credit union.
Approval of the proposal for conversion shall
be by the affirmative vote of a majority of the
members of the insured credit union who vote on
the proposal.
(C) Notice of proposal to members.--An
insured credit union that proposes to convert
to a mutual savings bank or savings association
under subparagraph (A) shall submit notice to
each of its members who is eligible to vote on
the matter of its intent to convert--
(i) 90 days before the date of the
member vote on the conversion;
(ii) 60 days before the date of the
member vote on the conversion; and
(iii) 30 days before the date of the
member vote on the conversion.
(D) Notice of proposal to board.--The Board
may require an insured credit union that
proposes to convert to a mutual savings bank or
savings association under subparagraph (A) to
submit a notice to the Board of its intent to
convert during the 90-day period preceding the
date of the completion of the conversion.
(E) Inapplicability of act upon conversion.--
Upon completion of a conversion described in
subparagraph (A), the credit union shall no
longer be subject to any of the provisions of
this Act.
(F) Limit on compensation of officials.--
(i) In general.--No director or
senior management official of an
insured credit union may receive any
economic benefit in connection with a
conversion of the credit union as
described in subparagraph (A), other
than--
(I) director fees; and
(II) compensation and other
benefits paid to directors or
senior management officials of
the converted institution in
the ordinary course of
business.
(ii) Senior management official.--For
purposes of this subparagraph, the term
``senior management official'' means a
chief executive officer, an assistant
chief executive officer, a chief
financial officer, and any other senior
executive officer (as defined by the
appropriate Federal banking agency
pursuant to section 32 (f) of the
Federal Deposit Insurance Act).
(G) Consistent rules.--
(i) In general.--Not later than 6
months after the date of enactment of
the Credit Union Membership Access Act,
the Administration shall promulgate
final rules applicable to charter
conversions described in this paragraph
that are consistent with rules
promulgated by other financial
regulators, including the Office of the
Comptroller of the Currency. The rules
required by this clause shall provide
that charter conversion by an insured
credit union shall be subject to
regulation that is no more or less
restrictive than that applicable to
charter conversions by other financial
institutions.
(ii) Oversight of member vote.--The
member vote concerning charter
conversion under this paragraph shall
be administered by the Administration,
and shall be verified by the Federal or
State regulatory agency that would have
jurisdiction over the institution after
the conversion. If either the
Administration or that regulatory
agency disapproves of the methods by
which the member vote was taken or
procedures applicable to the member
vote, the member vote shall be taken
again, as directed by the
Administration or the agency.
(3) Except with the prior written approval of the Board, no
insured credit union shall merge or consolidate with any other
insured credit union or, either directly or indirectly, acquire
the assets of, or assume liability to pay any member accounts
in, any other insured credit union.
(c) In granting or withholding approval or consent under
subsection (b) of this section, the Board shall consider--
(1) the history, financial condition, and management
policies of the credit union;
(2) the adequacy of the credit union's reserves;
(3) the economic advisability of the transaction;
(4) the general character and fitness of the credit
union's management;
(5) the convenience and needs of the members to be
served by the credit union; and
(6) whether the credit union is a cooperative
association organized for the purpose of promoting
thrift among its members and creating a source of
credit for provident or productive purposes.
(d) Prohibition.--
(1) In general.--Except with prior written consent of
the Board--
(A) any person who has been convicted of any
criminal offense involving dishonesty or a
breach of trust, or has agreed to enter into a
pretrial diversion or similar program in
connection with a prosecution for such offense,
may not--
(i) become, or continue as, an
institution-affiliated party with
respect to any insured credit union; or
(ii) otherwise participate, directly
or indirectly, in the conduct of the
affairs of any insured credit union;
and
(B) any insured credit union may not permit
any person referred to in subparagraph (A) to
engage in any conduct or continue any
relationship prohibited under such
subparagraph.
(2) Minimum 10-year prohibition period for certain
offenses.--
(A) In general.--If the offense referred to
in paragraph (1)(A) in connection with any
person referred to in such paragraph is--
(i) an offense under--
(I) section 215, 656, 657,
1005, 1006, 1007, 1008, 1014,
1032, 1344, 1517, 1956, or 1957
of title 18, United States
Code; or
(II) section 1341 or 1343 of
such title which affects any
financial institution (as
defined in section 20 of such
title); or
(ii) the offense of conspiring to
commit any such offense,
the Board may not consent to any exception to
the application of paragraph (1) to such person
during the 10-year period beginning on the date
the conviction or the agreement of the person
becomes final.
(B) Exception by order of sentencing court.--
(i) In general.--On motion of the
Board, the court in which the
conviction or the agreement of a person
referred to in subparagraph (A) has
been entered may grant an exception to
the application of paragraph (1) to
such person if granting the exception
is in the interest of justice.
(ii) Period for filing.--A motion may
be filed under clause (i) at any time
during the 10-year period described in
subparagraph (A) with regard to the
person on whose behalf such motion is
made.
(3) Penalty.--Whoever knowingly violates paragraph
(1) or (2) shall be fined not more than $1,000,000 for
each day such prohibition is violated or imprisoned for
not more than 5 years, or both.
(e)(1) The Board shall promulgate rules establishing minimum
standards with which each insured credit union must comply with
respect to the installation, maintenance, and operation of
security devices and procedures, reasonable in cost, to
discourage robberies, burglaries, and larcenies and to assist
in the identification and apprehension of persons who commit
such acts.
(2) The rules shall establish the time limits within which
insured credit unions shall comply with the standards and shall
require the submission of periodic reports with respect to the
installation, maintenance, and operation of security devices
and procedures.
(3) An insured credit union which violates a rule promulgated
pursuant to this subsection shall be subject to a civil penalty
which shall not exceed $100 for each day of the violation.
(f)(1) Every insured credit union is authorized to maintain,
and make loans with respect to, share draft accounts in
accordance with rules and regulations prescribed by the Board.
Except as provided in paragraph (2), an insured credit union
may pay dividends on share draft accounts and may permit the
owners of such share draft accounts to make withdrawals by
negotiable or transferable instruments or other orders for the
purpose of making transfers to third parties.
(2) Paragraph (1) shall apply only with respect to share
draft accounts in which the entire beneficial interest is held
by one or more individuals or members or by an organization
which is operated primarily for religious, philanthropic,
charitable, educational, or other similar purposes and which is
not operated for profit, and with respect to deposits of public
funds by an officer, employee, or agent of the United States,
any State, county, municipality, or political subdivision
thereof, the District of Columbia, the Commonwealth of Puerto
Rico, American Samoa, Guam, any territory or possession of the
United States, or any political subdivision thereof.
(g)(1) If the applicable rate prescribed in this subsection
exceeds the rate an insured credit union would be permitted to
charge in the absence of this subsection, such credit union
may, notwithstanding any State constitution or statute which is
hereby preempted for the purposes of this subsection, take,
receive, reserve, and charge on any loan, interest at a rate of
not more than 1 per centum in excess of the discount rate on
ninety-day commercial paper in effect at the Federal Reserve
bank in the Federal Reserve district where such insured credit
union is located or at the rate allowed by the laws of the
State, territory, or district where such credit union is
located, whichever may be greater.
(2) If the rate prescribed in paragraph (1) exceeds the rate
such credit union would be permitted to charge in the absence
of this subsection, and such State fixed rate is thereby
preempted by the rate described in paragraph (1), the taking,
receiving, reserving, or charging a greater rate than is
allowed by paragraph (1), when knowingly done, shall be deemed
a forfeiture of the entire interest which the loan carries with
it, or which has been agreed to be paid thereon. If such
greater rate of interest has been paid, the person who paid it
may recover, in a civil action commenced in a court of
appropriate jurisdiction not later than two years after the
date of such payment, an amount equal to twice the amount of
interest paid from the credit union taking or receiving such
interest.
(h) Notwithstanding any other provision of law, the Board may
authorize a merger or consolidation of an insured credit union
which is insolvent or is in danger of insolvency with any other
insured credit union or may authorize an insured credit union
to purchase any of the assets of, or assume any of the
liabilities of, any other insured credit union which is
insolvent or in danger of insolvency if the Board is satisfied
that--
(1) an emergency requiring expeditious action exists
with respect to such other insured credit union;
(2) other alternatives are not reasonably available;
and
(3) the public interest would best be served by
approval of such merger, consolidation, purchase, or
assumption.
(i)(1) Notwithstanding any other provision of this Act or of
State law, the Board may authorize an institution whose
deposits or accounts are insured by the Federal Deposit
Insurance Corporation to purchase any of the assets of or
assume any of the liabilities of an insured credit union which
is insolvent or in danger of insolvency, except that prior to
exercising this authority the Board must attempt to effect the
merger or consolidation of an insured credit union which is
insolvent or in danger of insolvency with another insured
credit union, as provided in subsection (h).
(2) For purposes of the authority contained in paragraph (1),
insured accounts of the credit union may upon consummation of
the purchase and assumption be converted to insured deposits or
other comparable accounts in the acquiring institution, and the
Board and the National Credit Union Share Insurance Fund shall
be absolved of any liability to the credit union's members with
respect to those accounts.
(j) Privileges Not Affected by Disclosure to Banking Agency
or Supervisor.--
(1) In general.--The submission by any person of any
information to the Bureau of Consumer Financial
Protection, the Administration, any State credit union
supervisor, or foreign banking authority for any
purpose in the course of any supervisory or regulatory
process of such Board, supervisor, or authority shall
not be construed as waiving, destroying, or otherwise
affecting any privilege such person may claim with
respect to such information under Federal or State law
as to any person or entity other than such Board,
supervisor, or authority.
(2) Rule of construction.--No provision of paragraph
(1) may be construed as implying or establishing that--
(A) any person waives any privilege
applicable to information that is submitted or
transferred under any circumstance to which
paragraph (1) does not apply; or
(B) any person would waive any privilege
applicable to any information by submitting the
information to the Bureau of Consumer Financial
Protection, the Administration, any State
credit union supervisor, or foreign banking
authority, but for this subsection.
* * * * * * *
MINORITY VIEWS
H.R. 4545 would enable any bank, regardless of size, to
appeal and postpone material supervisory determinations by the
bank's regulator, which include adverse determinations such as
a downgrade of a bank's rating for capital, asset quality,
management, earnings, liquidity, and sensitivity to market
risks (CAMELS); significant deficiencies in the institution's
Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program;
findings related to violations of various regulations; or a
downgrade of a bank's Community Reinvestment Act (CRA) rating.
The bill would create a new Office of Independent Examination
Review within the Federal Financial Institutions Examination
Council (``FFIEC'') and allow depository institutions that
receive such a determination to be able to appeal the
determination to the review office. This bill would make it
more likely that megabanks would be able to escape or delay
accountability for egregious violations of federal laws
protecting consumers and the economy.
Although proponents of this bill contend that it will
provide regulatory relief to community banks and small lenders,
the bill is not tailored for that goal. Rather, H.R. 4545 would
allow any bank, as well as any nonbank under the Consumer
Financial Protection Bureau's (``Consumer Bureau'') supervisory
authority, to appeal negative supervisory determinations made
in the examination process. While targeted improvements to the
exam process could be considered for the smallest banks,
allowing megabanks, as this bill would do, to challenge any
negative supervisory action taken against them is completely
inappropriate, particularly given the light-touch oversight
these large banks have been given. Even when receiving large
enforcement penalties, with fines sometimes reaching billions
of dollars, megabanks often view these fines as just a cost of
doing business. Time and again, megabanks are fined for the
same or similar offense without major consequence. Relatedly,
in November 2017, the Government Accountability Office
(``GAO'') released a report that found the Federal Reserve
needs to strengthen internal controls to more effectively
mitigate the risks of regulatory capture and threats to
supervisory independence across their large bank supervisory
program.\1\ Congress should not advance a measure that
exacerbates this issue. We believe it would be inappropriate to
enable megabanks to circumvent longstanding, deliberative
regulatory due processes by asking an independent office to
repeal adverse supervisory determinations issued by the
prudential regulators tasked with overseeing these entities.
---------------------------------------------------------------------------
\1\See Press Release, ``Waters: GAO Report is More Evidence That
Regulators Need to Get Tougher on Megabanks,'' (Dec. 6, 2017),
available at: https://democrats-financialservices.house.gov/news/
documentsingle.aspx?DocumentID=401001.
---------------------------------------------------------------------------
Furthermore, the independent review office created by this
legislation is not responsible for the safety and soundness of
the banking system as the prudential regulators are. For
example, the Federal Deposit Insurance Corporation (``FDIC'')
is charged with protecting the financial state of the Deposit
Insurance Fund (``DIF''), but the review office's decision in
support of a bank's appeal may result in a bank taking more
risk, which could have a material impact on the soundness of
the DIF.
What's more, the nonpartisan Congressional Budget Office
(``CBO'') estimated that the bill would increase budget
deficits by $123 million over a ten-year window.
Many of the concerns identified here would be largely
mitigated if H.R. 4545 was limited to small, community
depository institutions. Democrats unanimously supported an
amendment to limit the bill to community financial institutions
with less that $10 billion in assets;\2\ however, Committee
Republicans rejected this approach, allowing megabanks like
Wells Fargo to benefit from the bill.
---------------------------------------------------------------------------
\2\https://financialservices.house.gov/uploadedfiles/crpt-115-
hr4545-w000187-amdt-001.pdf.
---------------------------------------------------------------------------
For these reasons, we strongly oppose H.R. 4545.
Maxine Waters.
Daniel Kildee.
Keith Ellison.
Al Green.
Nydia M. Velazquez.
Stephen F. Lynch.
Vicente Gonzalez.
Joyce Beatty.
Emanuel Cleaver.
Wm. Lacy Clay.