The banks, including Fifth Third Bancorp, KeyCorp and PNC Financial Services Group Inc., said that not all of the institutions engage in activity that the Dodd-Frank Act is supposed to address, but provisions under the Volcker Rule would subject all of the organizations to comply with the requirements.
“We do not believe that Congress intended the Volcker Rule to unduly restrict the traditional activities conducted by our organizations or impose substantial compliance burdens on regional banking organizations,” the letter said.
The complex regulations and requirements, the banks argue, would force the banks to reallocate resources from customer service to compliance with federal law.
“One paramount initial concern is that the proposal would require each of our organizations in extremely short order to develop and implement compliance, internal controls, record-keeping and reporting regimes simply to ‘prove a negative’ that we are not engaged in impermissible proprietary trading or funds activities,” the letter said. “We also are greatly concerned that the proposal would hamper the ability of our organizations to meet the liquidity needs of our customers.”
The letter was sent in on the last day of the Volcker Rule’s comment period, along with many other letters from financial institutions and interested parties.