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  • Comment Detail

  • Date: 07/11/16
    First Name: Travis
    Last Name: Mar
    Organization: Zions Bank
    City: N/A
    State: N/A
    Attachment: N/A
    Number: RIN-2590-AA42

  • Comment

    I want to comment on the following parts of the proposed regulations:

    Deferral of up to 50% of all bonus income
    -Banks should be allowed to adjust their compensations to meet the market. The proposed rule is counter and will force more into non regulated institutions.

    -I foresee many high producers leaving markets and becoming 3rd party referral sources to banks, where they will then collect 100% of the fee upfront. These referral sources will not be regulated. Keeping high bank earners is ideal for the banks.

    -If this proposed action was for the back end of banking such as conduit lending, and the sale of securitized debt and the CDO trade, I understand. But those whose role is to place bank capital into the market as business loans and home loans is a large drag on the economy because of the slowing of capital.

    Income being subject to 10 year claw backs.
    -10 year claw backs is asking loan officers and other banking officials to only make the most solid deal and those deals would increase the tightening of the credit boxes even further retarding the flow of capital into job creating industries and home ownership.

    -The impacts of forcing tighter credit boxes on the source of capital will require the market to find the more expensive capital outside of regulated industries such as VC, and large un-regulated money institutions such as investment banks. Small time players cannot and will never receive loans from those institutions. Can you tell me that the neighborhood bakery is going to stay in business for the next ten years?...how much of your personal money are you willing to risk?

    -As a lender who deals with a large number of SBA guaranteed loans, I am well aware of the goals of the SBA and bringing forward a proposal runs counter to the goals of the SBA.

    -Finally a worry about keeping qualified, and solid underwriters and loan officers in institutions versus having them move companies when the markets turns is not good for the entire banking industry.

    -This market comes with cycles and when the next cycle comes having a large claw back statue is not good for the banking industry.

    -Ultimately allowing for more freedom allows for a more robust economy even it a field such as banking.