-----Original Message----- by t0tDMibr


									-----Original Message-----
From: Buz Gorman [mailto:BGorman@csbs.org]
Sent: Wednesday, September 27, 2006 11:48 AM
To: csbs-lawyers@list.webmonster.net
Subject: Final Passage of Reg Relief Bill Expected Today (S. 2856) -- Key CSBS Provisions
Importance: High

The House is expected to approved a bank regulatory relief bill today and final
passage could occur in the Senate as early as tonight. The bill largely reflects
the relatively narrower legislation passed by the Senate earlier this year (S.
2856). Included are three provisions endorsed by CSBS:

1) Establish the chairman of the State Liaison Committee as a full voting
member on the Federal Financial Institutions Examination Councilas
included in the Senate passed bill;

2) increase from $250 million to $500 million the asset size of well-
capitalized, well-managed institutions eligible for the extended 18 month
exam cycle (the original CSBS provision in the House bill would have increased
the cap to $1 billion in assets. The Senate reduced the size to $500
million), and;

3) Recognizes the CSBS interstate cooperative agreements and prohibits
unilateral fees on host state branches in order to improve the coordination of
supervision of multi-state state-chartered banks.

Additionally, a compromise on the Senate bill’s provisions relating to the
SEC's Regulation B was reached that directs the SEC to work with the Federal
Reserve Board to promulgate joint regulations implementing the “push-out”
provisions of the Gramm- Leach-Bliley Act (GLBA), and to consult with the OCC,
Office of Thrift Supervision, and the FDIC on those regulations. The original
Senate provision required the SEC to consult with and obtain concurrence from
the bank regulators on these rules; the bank regulators would have had the
option of going to court to challenge these rules. However, the compromise
language is likely to be a faster and more efficient way to obtain workable
rules. This new, joint rulemaking with the Federal Reserve will protect these
traditional products and activities.

A compromise was also reached on the Senate bill's authorization allowing the
Fed to pay interest on reserve balances. The House accepted this provision but
insisted on a five-year delay in the effective date due to budget concerns.

While significant efforts were made in past few weeks to include a CSBS
provision for multistate state-chartered trust operations, a compromised could not
be reached.

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