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TCH Association President Saltzman Commends Governor Tarullo’s Remarks on Appropriately Tailoring Prudential Regulation

In a letter to Federal Reserve Board Governor Daniel Tarullo, TCH Association President Paul Saltzman commends Governor Tarullo for his May remarks in Chicago, which emphasized the importance of appropriately tailoring the application of prudential regulation based on the size, scope, and range of activities of individual banking organizations.  Governor Tarullo suggested that the universe of bank holding companies currently subject to enhanced prudential standards under Title I of the Dodd-Frank Act, based solely on their asset size, may be overly broad.  TCH has frequently emphasized in comment letters and other public statements that a “one-size-fits-all” approach to regulation, and to macroprudential regulation in particular, is inappropriate and would inherently fail to account for the wide variety of business models and practices that exist among individual institutions.