A compliance officer has a leadership responsibility in his or her bank and in the banking industry. This is a particularly important responsibility for compliance officers in community banks. With the recent regulatory changes already made and those being contemplated, it’s imperative for compliance officers to “get in the game” and have their voices heard. One way to do that is with comment letters.
The agencies publish a proposed rule or an interim final rule in the Federal Register for review and public comment prior to its adoption. A proposed rule or an interim final rule describes a new rule or regulation or a change to an existing rule or regulation. Commenting on these is very important as agencies do consider the comments received, and without persuasive comments nothing will change between the proposed rule or interim final rule and the final rule.
Comment letters don’t always work, but effective comment letters can influence the final rule or elicit clarification and additional guidance. They are an avenue you can use to help you become a recognized leader in your bank and an advocate for the community banking industry. Your bank’s senior management and board will be impressed that you took the time to draft an effective comment letter.
So how do you write an effective comment letter? It is much more than saying “This is so unfair and will cost my bank money and will be really hard for me!” In fact, that kind of letter will most likely be ignored as whining. Tone is very important – so the number one rule is to avoid language that is inflammatory or condescending.
Here are some additional tips to consider when writing an effective comment letter.