79–006 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 115–620 

TRANSPARENCY AND ACCOUNTABILITY FOR BUSINESS 

STANDARDS ACT 

APRIL 5, 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. 3179] 

[Including cost estimate of the Congressional Budget Office] 

The Committee on Financial Services, to whom was referred the 

bill (H.R. 3179) to require the appropriate Federal banking agencies, when issuing certain prudential regulations that are substantively more stringent than a corresponding international prudential standard to publish the rationale for doing so and a costbenefit analysis of the difference, 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 Trey Hollingsworth on July 11, 

2017, H.R. 3179, the ‘‘Transparency and Accountability for Business Standards Act’’ requires Federal banking agencies (the Office 

of the Comptroller of the Currency (OCC), the Board of Governors 

of the Federal Reserve System (Federal Reserve), and the Federal 

Deposit Insurance Corporation (FDIC)) to publish—whenever 

issuing certain prudential regulations which are substantively 

more stringent than corresponding international standards—a rationale and comprehensive cost-benefit analysis of the differences 

between the prudential regulation and the corresponding international prudential standard, for public notice and comment. 

2 

The cost-benefit analysis must include the following metrics: • Any impact on pricing and availability of credit, in the aggregate and for specific types of borrowers • Any impact on liquidity in markets, in the aggregate and 

for specific instruments • Any impact of the effect of the rules on affected institutions, and • Any impact on employment, economic growth and monetary policy execution 

BACKGROUND AND NEED FOR LEGISLATION

In response to the 2008 financial crisis, the Basel Committee on 

Banking Supervision (Basel Committee), of which the United 

States is a member, agreed to modify internationally negotiated 

bank regulatory standards known as the Basel Accords to increase 

bank capital and liquidity requirements and other regulatory measures. 

The Basel Accords are international banking regulations negotiated between participating regulators, but they rely on local implementation to take effect in a nation’s financial regulatory regime. The Basel Committee cannot force individual nations to 

adopt its standards, and agreements made in Basel are subject to 

interpretation, implementation, and enforcement by domestic regulators. Nevertheless, both member and non-member countries 

largely follow the bank supervisory guidance issued by the Basel 

Committee. 

The Dodd-Frank Wall Street Reform and Consumer Protection 

Act (P.L. 111–203) codified the Basel III capital standards and the 

U.S. Federal banking regulators—including the FDIC, Federal Reserve, and OOCC—promulgated rules to implement the standards 

on July 9, 2013. 

Since 2008, U.S. banks have raised more than $400 billion in 

new capital, and regulators in the United States and elsewhere, 

working under the aegis of the Basel Committee and the G–20’s Financial Stability Board, have required those institutions to maintain higher capital buffers than they did before the crisis. Regulators have also—for the first time—adopted liquidity regulations 

that require financial institutions to maintain ‘‘high quality liquid 

assets’’ that they can use to satisfy their funding needs if markets 

seize up as they did in 2008 and 2009. In several instances, U.S. 

regulators have gone beyond the standards set by the Basel Committee and imposed more stringent capital and liquidity requirements on U.S. firms, a practice which has come to be known as 

‘‘gold-plating.’’ 

The practice of ‘‘gold-plating’’ U.S. financial regulation than the 

agreed-to international standards disadvantages the U.S. economy 

and the efficiency of the U.S. credit market for consumers. Capital 

and liquidity standards affect everyone in the economy. Appropriate standards can ensure bank stability, whereas excessive requirements can impede the growth of the domestic economy and 

create competitive disadvantages on the international financial 

stage. The U.S. Treasury Department noted in its June 2017 report 

issued in response to President Trump’s Executive Order 13772 on 

Core Principles for Regulating the United States Financial System, 

‘‘In many instances, the U.S. banking agencies have implemented 

3 

standards for U.S. G–SIBs and other large internationally active 

U.S. banks that are more conservative than the international 

standards established by the Basel Committee or the Financial 

Stability Board.’’ 

As U.S. regulators promulgate rules to require domestic institutions to maintain nearly double the amount of capital of their international counterparts, it puts U.S. institutions at a competitive disadvantage. It further harms consumers by leaving less capital 

available for lending and also reducing the number and types of 

products consumers can choose from. With billions of dollars of equity capital capable of supporting hundreds of billions of dollars in 

lending capital unjustifiably locked away under overly-stringent domestic capital standards, economic growth and consumer welfare 

are stifled. The June 2017 Treasury Report also noted, ‘‘International regulatory standards should only be implemented through 

consideration of their alignment with domestic objectives and 

should be carefully and appropriately tailored to meet the needs of 

the U.S. financial services industry and the American people.’’ 

The Treasury Report also recommended that, ‘‘U.S. rules that exceed international standards that should be recalibrated include (i) 

the U.S. G–SIB risk-based surcharge, including its focus on shortterm wholesale funding reliance; (ii) the mandatory minimum debt 

ratio included in the Federal Reserve’s TLAC and minimum debt 

rules; and (iii) the eSLR.’’ This bill will ensure that if regulators 

determine that domestic standards should be more stringent than 

the standards foreign institutions adopt under the aegis of the 

Basel Committee or any other international standard-setting body, 

they should do so only after careful analysis and a transparent, 

and public process that allows for consideration of the benefits to 

safety and soundness taken together with the potential harm to the 

economy and consumer freedom. 

HEARINGS

The Committee on Financial Services held a hearing examining 

matters relating to H.R. 3179 on December 7, 2017. 

COMMITTEE CONSIDERATION

The Committee on Financial Services met in open session on December 12 and 13, 2017, and ordered H.R. 3179 to be reported favorably to the House as amended by a recorded vote of 34 yeas to 

26 nays (Record vote no. FC–130), 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 sole recorded 

vote was on a motion by Chairman Hensarling to report the bill favorably to the House with amendment. The motion was agreed to 

by a recorded vote of 34 yeas to 26 nays (Record vote no. FC–130), 

a quorum being present. 

4 


Insert offset folio 5 here HR620.001
5 

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. 3179 will require Federal banking agencies (the Office of the Comptroller of the 

Currency (OCC), the Board of Governors of the Federal Reserve 

System (Federal Reserve), and the Federal Deposit Insurance Corporation (FDIC) to publish—whenever issuing certain prudential 

regulations which are substantively more stringent than corresponding international standards—a rationale and comprehensive cost-benefit analysis of the differences between the prudential 

regulation and the corresponding international prudential standard, for public notice and comment. 

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, March 28, 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. 3179, the Transparency 

and Accountability for Business Standards Act. 

If you wish further details on this estimate, we will be pleased 

to provide them. The CBO staff contacts are Sarah Puro and Nathaniel Frentz. 

Sincerely, 

KEITH HALL, Director. 

Enclosure. 

6 

H.R. 3179—Transparency and Accountability for Business Standards Act 

Summary: H.R. 3179 would require three federal banking regulators—the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the Federal Reserve—to conduct and publish cost-benefit analyses of any new regulations they implement related to capital requirements, leverage 

requirements, or liquidity requirements that are substantively 

more stringent than corresponding international standards. The 

bill also would require those regulators to complete cost-benefit 

analyses for any similar regulations they have implemented since 

January 2007. 

CBO estimates that enacting the legislation would increase the 

deficit by $8 million over the 2018–2027 period. That amount comprises an increase in direct spending of $4 million and a reduction 

in revenues of $4 million. Because enacting the bill would affect direct spending and revenues, pay-as-you-go procedures apply. 

CBO estimates that enacting H.R. 3179 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. 3179 contains no intergovernmental mandates as defined in 

the Unfunded Mandates Reform Act (UMRA). Additional fees imposed by the FDIC and the OCC would increase the cost of an existing mandate on private entities required to pay those assessments. However, CBO estimates that the incremental cost of the 

mandate would fall well below the annual threshold established in 

UMRA for private-sector mandates ($156 million in 2017, adjusted 

for inflation). 

Estimated cost to the Federal Government: The estimated budgetary effect of H.R. 3179 is shown in the following table. The costs 

of the legislation fall within budget function 370 (advancement of 

commerce). 

By fiscal year, in millions of dollars— 

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018– 

2022 

2018– 

2027 

INCREASES IN DIRECT SPENDING 

Estimated Budget Authority 0 1 1 * * * * * * * 2 4 

Estimated Outlays ............. 0 1 1 * * * * * * * 2 4 

DECREASES IN REVENUES 

Estimated Revenues .......... 0 ¥1 ¥1 * * * * * * * ¥2 ¥4 

NET INCREASE IN THE DEFICIT FROM CHANGES IN DIRECT SPENDING AND REVENUES 

Impact on Deficit ............... 0 2 2 1 1 1 1 1 1 1 5 8 

Components may not sun to totals because of rounding. 

* = between –$500,000 and $500,000. 

Basis of estimate: Costs incurred by the FDIC and the OCC are 

recorded in the budget as increases in direct spending. Those agencies are authorized to collect premiums and fees from insured depository institutions to fully cover such administrative expenses, although CBO expects that a portion of the costs incurred by the 

FDIC under H.R. 3179 would be recouped after 2027. Regulatory 

costs of the Federal Reserve System have the effect of reducing remittances to the Treasury, which are recorded in the budget as revenues. 

7 

Under current law, a cost-benefit analysis is prepared before a 

federal banking regulator adopts a new regulation. However, CBO 

estimates that the bill’s standards for such analyses would require 

additional work. The bill also would require regulators to prepare 

cost-benefit analyses for certain regulations issued since January 

2007. 

Using information from the financial regulators, CBO estimates 

that between 5 and 10 of the regulations issued since January 1, 

2007, would require cost-benefit analyses under the bill. In addition, CBO estimates that to implement future regulations, the regulators would have to complete an additional cost-benefit analysis 

each year. 

CBO estimates that each affected agency would need the equivalent of one additional full-time employee to complete the additional 

work required under the bill. Depending on the agency, the associated cost of employment would range from $200,000 to $250,000 

annually. As a result, CBO estimates, enacting the bill would increase deficits by $8 million over the 2018–2027 period. That 

amount includes an increase in net direct spending of $4 million 

and a decrease in revenues of $4 million because the increased 

costs for the Federal Reserve would reduce remittances to the 

Treasury. 

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-asyou-go procedures are shown in the following table. 

CBO ESTIMATE OF PAY-AS-YOU-GO EFFECTS FOR H.R. 3179, THE TRANSPARENCY AND ACCOUNTABILITY FOR BUSINESS STANDARDS ACT, AS ORDERED REPORTED BY THE HOUSE COMMITTEE 

ON FINANCIAL SERVICES ON DECEMBER 13, 2017 

By fiscal year, in millions of dollars— 

2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2018– 

2022 

2018– 

2027 

NET INCREASE IN THE DEFICIT 

Statutory Pay-As-You-Go Impact ......... 2 2 1 1 1 1 1 1 1 1 5 8 

Memorandum: 

Changes in Outlays .................... 1 1 0 0 0 0 0 0 0 0 2 4 

Changes in Revenues ................. 1 1 0 0 0 0 0 0 0 0 2 4 

Increase in long-term direct spending and deficits: CBO estimates that enacting H.R. 3179 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. 3179 contains no intergovernmental mandates as 

defined in UMRA. 

CBO expects that the FDIC and the OCC would increase fees to 

offset the costs of implementing the additional regulatory activities 

required by the bill. Any increase in fees would increase the cost 

of an existing mandate on entities required to pay those assessments. Using information from the federal banking regulators, 

CBO estimates that the incremental cost to comply with the mandate would fall well below the annual threshold established in 

UMRA for private-sector mandates ($156 million in 2017, adjusted 

for inflation). 

8 

Estimate prepared by: Federal Costs: Sarah Puro; Revenues: Nathaniel Frentz; Mandates: Jon Sperl. 

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 rulemakings: The 

Committee estimates that the bill requires no directed rulemakings 

within the meaning of such section. 

SECTION-BY-SECTION ANALYSIS OF THE LEGISLATION

Section 1. Short title 

This section cites H.R. 3179 as the ‘‘Transparency and Accountability for Business Standards Act.’’ 

9 

Section 2. Cost-benefit analysis requirement for certain prudential 

regulations 

This section requires that appropriate Federal banking agencies, 

when issuing prudential regulations that are substantively more 

stringent than corresponding international standards, must publish, for public notice and comment, a rationale and comprehensive 

cost-benefit analysis of the differences between the prudential regulation and the corresponding international prudential standard. 

The cost-benefit analysis must include the following metrics: 

• Any impact on pricing and availability of credit, in the aggregate and for specific types of borrowers; 

• Any impact on liquidity in markets, in the aggregate and 

for specific instruments; 

• Any impact on affected institutions; and 

• Any impact on employment, economic growth and monetary policy execution. 

This section also require that in order for a Federal banking 

agency to supersede an extant prudential regulation by adopting an 

international standard, it must first publish, for public notice and 

comment, a proposal to repeal or amend the superseded regulation 

or a description (including a cost-benefit analysis) of why it does 

not intend to repeal or amend the superseded regulation. 

Finally, the section includes a lookback provision requiring Federal banking agencies to report to Congress within 180 days on any 

final rule since January 1, 2007, that would fall into one of the 

above categories. 

This section also defines the various terms utilized within the 

Act. 

CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

H.R. 3179 does not repeal or amend any section of a statute. 

Therefore, the Office of Legislative Counsel did not prepare the report contemplated by clause 3(e)(1)(B) of rule XIII of the Rules of 

the House of Representatives. 

(10) 

1https://www.bis.org/bcbs/about.htm. 

2https://www.bis.org/bcbs/basel3.htm. 

3See CRS Report, ‘‘Overview of the Prudential Regulatory Framework for U.S. Banks: Basel 

III and the Dodd-Frank Act,’’ (July 27, 2016), http://www.crs.gov/Reports/R44573. 4https://www.wsj.com/articles/u-s-banking-industry-annual-profit-hit-record-in-2016- 

1488295836. 5http://money.cnn.com/2017/02/13/investing/bank-business-lending-dodd-frank-trump/ 

index.html. 

MINORITY VIEWS 

H.R. 3179 would impose a new, onerous administrative burden 

on federal banking agencies—specifically the Board of Governors of 

the Federal Reserve System (Federal Reserve), the Federal Deposit 

Insurance Corporation (FDIC), and the Office of the Comptroller of 

the Currency (OCC)—before they could adopt a prudential regulation, such as requirements regarding how much capital a bank 

must maintain, that is more stringent than a corresponding international prudential standard. Under the bill, the agencies would 

first be required to publish for notice and comment their rationale, 

among other things, when issuing a stricter rule than under the 

international standard and conduct a cost-benefit analysis of the 

difference between the proposed regulation and the international 

standard. 

Oddly, H.R. 3179 does not require a similar analysis if U.S. regulators propose a weaker standard than a corresponding international prudential standard. In addition, the cost-benefit analysis 

under H.R. 3179 would require regulators to consider the impact 

on availability of credit and economic growth, but it would not include other important considerations, such as the impact on the 

safety and soundness of the U.S. banking system and financial stability. Thus, we are deeply concerned H.R. 3179 could have the net 

effect of discouraging regulators from pursuing stronger rules that 

could help prevent another financial crisis. 

Federal banking agencies participate in the Basel Committee on 

Banking Supervision (Basel Committee) at the Bank for International Settlement.1 The purpose of the Basel framework generally, and the Basel III framework specifically, is to improve resilience for the banking system during episodes of financial distress.2

Typically, after the Basel Committee agrees to these prudential 

standards, U.S. federal banking agencies implement these standards through the extensive administrative process of modifying existing rules or issuing new proposed rules, considering public comments, conducting extensive analysis and ultimately issuing final 

rules that tailor the Basel standards to the U.S. banking system.3

Despite record profits earned by the banking sector in recent 

years,4 and business lending up more than 75 percent since DoddFrank was signed into law,5 the Trump Administration and Wall 

Street banks have argued that U.S. regulators have gone too far in 

so-called ‘‘gold-plating’’ international standards, which is a term 

11 

6 United States Department of the Treasury, ‘‘A Financial System That Creates Economic Opportunities—Banks and Credit Unions,’’ (June 2017), available at: https://www.treasury.gov/ 

press-center/press-releases/Documents/A%20Financial%20System,pdf. 7https://www.jpmorganchase.com/corporate/investor-relations/document/ar2016-ceoletter 

shareholders.pdf. 8https://www.fdic.gov/about/learn/board/hoenig/hoenigletter07-31-2017.pdf. 

9https://www.americanbanker.com/news/basel-move-makes-the-case-for-gold-plating-capitalstandards. 10For example, see: https://www.federalreserve.gov/econres/feds/files/2017034pap.pdf; https:// 

www.gsb.stanford.edu/faculty-research/books/bankers-new-clothes-whats-wrong-banking-whatdo-about-it; https://www.minneapolisfed.org/publications/special-studies/endingtbtf; https:// 

www.fdic.gov/news/news/speeches/spmar1317.html; and https://www.aei.org/publication/ 

regulation-of-bank-capital-and-liquidity/. 11For example, see https://www.economist.com/news/special-report/21721502-most-europeanbanks-were-slow-mark-after-crisis-american-banks-have-recovered; https://www.economist.com/ 

news/special-report/21721497-international-bank-regulation-grinding-towards-completionorpossibly-halt-basel-3; and https://www.cnbc.com/id/37237500. 12https://obamawhitehouse.archives.gov/blog/2017/01/09/review-why-president-obamareformed-wall-street-and-what-reform-has-accomplished. 13https://financialservices.house.gov/uploadedfiles/hhrg-115-ba15-wstate-mstanley-20171207. 

pdf. 

commonly used to describe the application of stricter standards to 

U.S. banks than what is specified in Basel III or other agreements. 

Many of the positions articulated in a 2017 Treasury report 6 to roll 

back these prudential safeguards have also been echoed by the 

megabank executives. Jamie Dimon, the Chairman and Chief Executive Office for JPMorgan Chase & Co., for instance, wrote in his 

2016 annual letter to shareholders that: ‘‘America should eliminate 

its ‘gold plating’ of international standards. American regulators 

took the new Basel standards across a wide variety of calculations 

and asked for more.’’ 7 This perspective ignores the benefits from 

more stringent rules to promote financial stability, and also ignores 

how large banks may use excess cash to buy back shares, pay dividends or pay out bonuses to executives instead of providing more 

access to credit for consumers.8

While proponents of H.R. 3179 argue the U.S. should not ‘‘gold 

plate’’ international standards, such an effort can lead to other jurisdictions to follow America’s lead in setting higher, not lower, 

prudential standards. According to John Heltman of American 

Banker, ‘‘It’s beginning to look like the rest of the world may follow 

the U.S.’ lead when it comes to tougher capital standards. . . . 

Wall Street critics say it illustrates their long-standing claims that 

‘gold-plating’—that is, setting regulatory standards that exceed 

international standards—can help influence other countries to 

agree to stronger standards.’’ 9

Furthermore, while there are a wide range of views on the appropriate stringency of bank capital requirements,10 the United States 

has been generally recognized as being far more successful compared to other jurisdictions, such as Europe, in re-capitalizing and 

strengthening the resiliency of the banking sector through robust 

stress testing and other enhanced prudential requirements following the financial crisis.11 In fact, U.S. banks have added more 

than $750 billion in capital to absorb potential losses and are much 

less reliant on the kinds of short-term funding that disappeared in 

the 2007–2009 financial crisis.12

According to Dr. Marcus Stanley in testimony before the Committee, ‘‘Subordinating U.S. bank regulations to what is attainable 

in a Basel consensus would be an extremely dangerous move.’’ 13

Experts have also pointed out the shortcomings with the current 

12 

14For example, see https://www.yalelawjournal.org/article/cost-benefit-analysis-of-financialregulation and http://ourfinancialsecurity.org/wp-content/uploads/2012/05/DENNIS-KELLEHERPPT.pdf. 

cost-benefit analysis conducted by federal banking regulators, more 

generally, noting that compliance burdens are easier to calculate 

compared to the more hypothetical and large benefits to the broader public of preventing a catastrophically costly, unrealized financial crisis. The financial industry has repeatedly used these analyses to challenge various rulemakings in court.14

Because the mandatory review process under the bill is only triggered when federal banking regulators seek to adopt stronger prudential regulations, it would create an administrative disincentive 

for regulators to pursue more robust rules that could prevent another financial crisis. At a minimum, the additional administrative 

requirements in the bill would also increase the time-period for certain prudential rulemakings, which could create safety and soundness risks in tying the hands of regulators during times of financial 

stress or dire economic conditions. 

For these reasons, we oppose H.R. 3179. 

MAXINE WATERS. 

NYDIA M. VELA ́ ZQUEZ. 

CAROLYN B. MALONEY. 

JOYCE BEATTY. 

KEITH ELLISON. 

Æ