Even if we do not believe that they actually advance safety and soundness aims for community banks, or produce only a small benefit at a disproportionately large compliance cost, we must still enforce them. It would be worthwhile to consider amendments to these statutory provisions to carve out their applicability to community banks.
In the hope of addressing some of your concerns, I waded through the more than 1,000 pages of reports and notes that the Institute of International Finance (IIF) has produced over the past year.