CHAMBER OF COMMERCE
OF THE
UNITED STATES OF AMERICA
R . BR U C E J O S T E N
1615 H STREET, N.W.
WASHINGTON, D.C. 20062-2000
202/463-5310
EXECUTIVE VICE PRESIDENT
GOVERNMENT AFFAIRS
May 20, 2015
The Honorable Richard Shelby
Chairman
Committee on Banking, Housing,
and Urban Affairs
United States Senate
Washington, DC 20510
The Honorable Sherrod Brown
Ranking Member
Committee on Banking, Housing,
and Urban Affairs
United States Senate
Washington, DC 20510
Dear Chairman Shelby and Ranking Member Brown:
The U.S. Chamber of Commerce, the worlds largest business federation representing
the interests of more than three million businesses of all sizes, sectors, and regions, as well as
state and local chambers and industry associations, and dedicated to promoting, protecting, and
defending Americas free enterprise system, welcomes the introduction and markup of the
Financial Regulatory Improvement Act of 2015. The Chamber believes this bill is an overdue
effort that would remove unnecessary regulatory burdens that only inhibit the flow of capital to
American businesses. This bill would also begin to address some of the unintended
consequences of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank
Act), while fixing flaws in the financial regulatory structures left unaddressed by the Dodd-Frank
Act. The Chamber hopes that the Financial Regulatory Improvement Act of 2015 can be
considered and passed on a bipartisan basis.
It is important that this bill be taken up now. The unforeseen consequences of the DoddFrank Act are starting to come to the fore, and are impacting the ability of Main Street businesses
to raise the capital needed to operate on a daily basis and grow over the long term. Banks are
now disincentivized from accepting business cash deposits, commercial lines of credit are being
reduced, and normal market making activities have been absent when the corporate debt markets
have undergone a lack of liquidity.
Following the passage of the Dodd-Frank Act in 2010, the Chamber has annually
released our Fix, Add, Replace Agenda, as well as other proposals to ensure that American
businesses have access to efficient and well regulated capital markets in order to grow and create
jobs. The Financial Regulatory Improvement Act of 2015 would address a number of these
issues. For example, this bill would result in greater transparency and due process protections in
the operations of the Financial Stability Oversight Council and rationalize the provision of
privacy notices. This bill would also make it possible for banks that are not systemically
important to avoid regulatory burdens and the associated compliance costs of mandatory SIFI
designation. This would promote the flow of the capital that Main Street businesses need to
operate and grow. The capital formation provisions also build upon the bipartisan success of the
Jumpstart our Business Startups Act (JOBS Act).
No legislation is perfect, and as you prepare this bill for consideration by the full Senate
the Chamber has revisions and additions that would further promote fulsome capital markets and
economic growth. Despite these concerns, the Financial Regulatory Improvement Act of 2015
is an important first step forward in correcting flaws in the financial regulatory architecture, and
the Chamber looks forward to working with Members of the Senate in achieving these goals.
Sincerely,
R. Bruce Josten
cc: Members of the Committee on Banking, Housing, and Urban Affairs