|
|
Comments: What Matters?
You should comment when given the opportunity. But what is most important about your comment? If the letter is going to Congress, remember that Representatives and Senators are vote sensitive. They want to know how many of their constituents support or oppose a measure.
Regulators have very different concerns. Comment letters to agencies should focus on the issues and the reasons rather than the number of letters. Regulators don't run for office. They have a very different job - that of translating laws into action. To do this, they need information - that you can provide.
Substance matters more than sheer numbers when it comes to influencing the regulatory process. Substance includes information and examples of how a proposed rule would work or not work. It is helpful to include information that may seem basic and obvious to a banker but is important to state because the writers of the regulation do not usually get to see how the job is done.
For example, it can be useful to explain when and how disclosures are generated for deposit accounts or loans and how these are given to the customer. It can also be useful to explain who has responsibility for and control over a system and who is or is not authorized to use it. These explanations can have a dramatic and important impact on the final rule. They can also make the difference between a burdensome rule and one that is less difficult to implement.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 13, 11/04
Privacy Policy Disclaimer Recommend This Site ! Contact Us
BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.
|
| |
Print Friendly!
Email This Article!
Discuss NOW!