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Public Input and a Transparent Process Produce Better Regulation, TCH Association President Says in Congressional Testimony

The Clearing House (TCH) Association President Greg Baer testified before the House Financial Services Subcommittee on Financial Institutions and Consumer Credit. The hearing focused on opportunities to reform the financial regulatory system.

“Public input and a transparent process tend to produce better regulation, but the current trend is clearly away from both,” Baer said in his opening statement. “… [A]dministrative procedure in banking regulation and supervision has broken down, with adverse consequences for the quality of rules being administered and the ability of our banking system to support economic growth.”

His testimony included five examples of areas where administrative procedure in banking regulation and supervision has broken down – the Federal Reserve’s Comprehensive Capital Analysis and Review (CCAR), CAMELS ratings, living wills, supervisory involvement in bank corporate governance, and the Community Reinvestment Act.

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