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H.R. 10, Financial CHOICE Act of 2017

Floor Situation

On Thursday, June 8, 2017, the House will begin consideration of H.R. 10, the Financial CHOICE Act of 2017, under a structured rule. The bill was introduced on April 26, 2017, by Rep. Jeb Hensarling (R-TX) and was referred to the Committee on Financial Services and in addition to the Committees on Agriculture, Ways and Means, the Judiciary, Oversight and Government Reform, Transportation and Infrastructure, Rules, the Budget, and Education and the Workforce. The Financial Services Committee ordered the bill reported, as amended, by a vote of 34 to 26 on May 4, 2017. The Manager’s Amendment, that is scheduled to be offered in the Rules Committee by the bill sponsor would, among other changes detailed here, remove a provision in the bill, as reported, that would have repealed a provision in the Dodd-Frank Act that requires the Federal Reserve to set a price cap on debit card interchange fees, commonly referred to as the “Durbin Amendment.”


Summary

H.R. 10 would amend the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and other financial regulatory laws. The bill is the product of 145 hearings held since January 2011 in the Financial Services Committee. The bill repeals the Federal Deposit Insurance Corporation’s (FDIC) authority to use Orderly Liquidation Authority (OLA) and the Financial Stability Oversight Council’s (FSOC) ability to designate firms as systemically important financial institutions (SIFIs) and would allow financial institutions, under certain circumstances, to be exempt from a variety of regulations. The bill also includes dozens of bills previously passed by the House to increase capital and credit.  H.R. 10 would make numerous other changes to the authorities of the agencies that regulate the financial industry, and subjects financial regulators to congressional appropriations. The bill also renames, reforms, and restructures the Consumer Financial Protection Bureau (CFPB) as the Consumer Law Enforcement Agency.

According to the Committee, “CHOICE Act ends taxpayer bailouts of financial institutions so that no company can remain too big to fail; holds both Wall Street and Washington accountable;  replaces complexity with simplicity, because complexity can be gamed by the well-connected and abused by the Washington powerful; revitalizes economic growth through competitive, transparent, and innovative capital markets;  allow every American, regardless of their circumstances, to have the opportunity to achieve financial independence;  vigorously protects consumers from fraud and deception as well as the loss of economic liberty; and manage systemic risk through profit and loss not government fiat.” 

For additional information about the Financial CHOICE Act and its underlying provisions, review the comprehensive summary provided by the Financial Services Committee. 

Title I – Financial Stability and Ending “Too Big To Fail”[1]

Orderly Liquidation Authority—The bill repeals the Dodd-Frank Act’s orderly liquidation authority (OLA) which allows the Federal Deposit Insurance Corporation (FDIC) to bail out the creditors and counterparties of a failing non-bank financial institution. OLA enables the FDIC to borrow money from the Treasury Department to place large bank holding companies and significant nonbanks into federal receivership and then requires the FDIC to liquidate the assets of the entity over a specific period of time and requires the FDIC to recoup the cost from the industry. The bill replaces OLA with a bankruptcy procedure, identical to the House-passed Financial Institution Bankruptcy Act, that is handled through the judicial system that is designed for large financial institutions.

Reforms to the Financial Stability Oversight Council (FSOC)—The FSOC monitors threats to the financial stability of the United States, facilitates communication among the heads of financial regulatory agencies, makes nonbinding recommendations to financial regulators to address perceived threats, and designates nonbank firms and financial market utilities for heightened prudential regulation by the Federal Reserve – effectively a new form of “too big to fail.” The bill repeals FSOC’s authority to designate “financial market utilities”[2] and non-bank financial institutions as SIFIs. The bill also makes the FSOC’s funding subject to Congressional appropriations.

Reforms to the Federal Reserve (Fed)—The bill makes a number of changes to the Fed’s nonmonetary regulatory functions. Specifically, the bill abolishes the Fed’s authority to supervise and set regulations for nonbank SIFIs, reduces the frequency that bank holding companies submit “living wills”[3] to the Fed and makes the evaluation process of those wills more transparent, and requires the Fed to increase transparency and accountability when conducting stress tests on financial entities.

Title II—Demanding Accountability from Wall Street[4]

Enhanced Civil Penalties for Financial Law Violations—The bill increases the civil money penalties, and some criminal penalties, that may be sought in administrative and civil actions brought under the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Company Act of 1940, the Investment Advisers Act of 1940, the Sarbanes-Oxley Act, insider trading violations, and the Financial Institutions Reform, Recovery, and Enforcement Act of 1989.

Title III— Demanding Accountability from Financial Regulators and Devolving Power Away from Washington[5]

Regulatory Reform—The bill requires financial regulatory agencies to be more transparent during the rulemaking process, requires financial regulatory agencies to conduct a review of existing regulations, requires the agencies to conduct economic and cost-benefit analysis of regulations, requires the agencies to reduce certain burdens associated with unfunded mandates, and provides a process for Congress to review major rules promulgated by federal financial regulators, similar to the House-passed REINS Act.

Chevron Deference—The bill would overturn the so-called Chevron and Auer doctrines of judicial deference to agency interpretations of statutory and regulatory provisions for the federal financial regulatory agencies. The bill directs the courts reviewing such agency actions to use a de novo standard, meaning the court acts as if it were considering the question for the first time, affording no deference.

Congressional Oversight of Appropriations—The bill brings the FDIC, the Federal Housing Finance Agency (FHFA), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), and the non-monetary regulatory functions of the Federal Reserve onto the regular Congressional appropriations process.  

Settlement Slush Fund Payment Prohibition—The bill would prohibit government officials from entering into or enforcing any settlement agreement for civil actions on behalf of the United States if that agreement requires the other party to the settlement to make a donation to a non-victim third party. That prohibition would not include payments to provide restitution or another remedy that is associated with the basis for the settlement agreement. In recent settlements with the United States, the terms of the settlement require financial institutions, have been required to donate funds to charitable and community institutions as a part of their restitution.[6]

Title IV— Unleashing Opportunities for Small Business, Innovators, and Job Creators by Facilitating Capital Formation[7]

Small Business and Entrepreneur Regulatory Relief—The title includes numerous bills that have previously passed the House in the 113th, the 114th,and the 115th Congresses. These bills make a variety of changes to encourage crowdfunding and to make it easier for entrepreneurs to raise capital and to make it easier for businesses to have an initial public offering.

Senior Safe—The bill encourages financial institutions and their employees to communicate with the appropriate regulatory and law enforcement agencies when there is a suspicion of financial exploitation of their clients, in an attempt to increase identification and reporting of suspected cases of elder financial exploitation.

Proxy Advisors and Shareholder Proposals—Every year, public companies hold shareholder meetings at which the company’s shareholders vote for the company’s directors.  At these meetings, shareholders also vote on significant actions taken by the company that require shareholder approval. Under current regulations, a shareholder can file a proposal to be included in the annual proxy, and voted on pursuant if they have held either (1) $2,000 in market value, or (2) at least 1 percent of the company’s securities for at least one year before submitting the proposal.  According to the Committee, “the shareholder proposal process has become a favorite vehicle for special interest activists to advance their social, environmental, or political agendas.” The bill changes the proposal rule to only allow shareholders who own at least 1 percent of the company’s securities and have held such securities for at least three years to submit a shareholder proposal to better align the process with long-term value creation for shareholders. The bill also enables companies to respond to proxy advisor firm recommendations on certain shareholder proposals.[8]

Title V—Regulatory Relief for Main Street and Community Financial Institutions[9]

Community Financial Institution Regulatory Relief—The title includes numerous bills that have previously passed the House in the 113th, the 114th,and the 115th Congresses to provide regulatory relief for community financial institutions on Main Streets. 

Preserving Access to Manufactured Housing—The bill amends the Truth in Lending Act to change the definition of a “high cost” mortgage to allow mortgages under $75,000[10] that do not exceed an annual percentage rate (APR) of more than 10 percent of the average prime offer rate (APOR)[11] to not be applicable to some restrictions and special reporting requirements associated with the Home Ownership and Equity Protection Act (HOEPA). Lifting these requirements could increase access to credit for consumers of small-balance mortgages that are often used to purchase manufactured homes.

Mortgage Access and Customer Protection—The bill makes a variety of changes to certain mortgage rules to enable lenders to increase access to affordable credit. The bill also requires federal regulators to have material reasons before ordering depository institutions to terminate a customer accounts.

Title VI—Regulatory Relief for Strongly Capitalized, Well-Managed Banking Organizations[12]

Regulatory Relief for Well-Capitalized Banks and Credit Unions—This title provides an “off ramp” for well-capitalized banks and credit unions from the most onerous requirements of the Dodd-Frank Act and Basel regulatory regimes.  The bill provides that a banking organization may be exempt from federal laws and regulations that set capital and liquidity requirements and federal laws and regulations that permit federal banking agencies to object to capital distributions, and regulations that deal with systemic risk and financial stability, if the bank makes voluntary election to maintain an average leverage ratio of at least 10 percent.  A 10 percent leverage ratio would imply $10 of capital for every $100 of assets – as opposed to other capital metrics, such as risk-based capital, which allows government officials to supplement market discipline in determining the riskiness of assets.  According to CBO and other independent analysis, this title will most benefit community financial institutions as opposed to larger financial institutions.[13]

Title VII—Empowering Americans to Achieve Financial Independence[14]

Consumer Law Enforcement Agency—The bill renames the Consumer Financial Protection Bureau (CFPB) to the Consumer Law Enforcement Agency (CLEA) and provides the director of the CLEA serves at the pleasure of the President. Under current law, the Director can only be fired by the President for cause. The bill also brings the CLEA onto the regular Congressional appropriations process.

Changes to the Authority of the CLEA—The bill removes CLEA’s authority to supervise and examine financial institutions, removes the agency’s authority to exercising rulemaking or enforcement authority over small-dollar loans, including payday loans and vehicle title loans, prohibits the agency from issuing guidance related to indirect auto financing and nullifies previously issued guidance related to indirect auto financing[15], removes the agency’s authority related to enforcing “unfair, deceptive, or abusive acts or practices,”[16] and removes the agency’s authority to restrict agreements requiring pre-dispute arbitration[17] in connection with the offering or providing of consumer financial products or services. For background information about these provisions, please see the footnotes.

Title VIII—Capital Markets Improvements[18]

SEC Funding—The bill reauthorizes the SEC through 2022, abolishes the SEC’s Reserve Fund[19],  and prohibits the SEC from constructing a new headquarters.

SEC Organizational Changes—The bill makes a variety of changes to several offices, committees, and divisions within the SEC to make the agency more efficient and more accountable to Congress and businesses.

Repeal of Department of Labor Fiduciary Rule—The bill repeals the Department of Labor’s Fiduciary rule and provides that the Department of Labor (DOL) may not issue a rule defining a “fiduciary” until 60 days after the SEC issues a rule relating to standards of conduct for brokers and dealers.

Under the Employee Retirement Income Security Act of 1974 (ERISA), which governs employee benefit plans, anyone that exercises discretionary authority over a benefit plan's management, assets, or administration, or renders "investment advice" for a fee to the plan is a “fiduciary”.  A fiduciary must act “solely in the interest of the participants and beneficiaries” for the “exclusive purpose” of providing benefits and defraying expenses. On April 20, 2015, DOL proposed a new regulation which was finalized on April 6, 2016, and will be effective on June 9, 2017.  This rule has raised concerns that individuals could lose access to trusted financial advisors, raise the cost of receiving advice, and lead to fewer small business offering retirement plans.

Risk-Retention Changes—The bill exempts asset-backed securities made up of non-residential mortgages from the Dodd-Frank Act’s risk retention requirements. The Dodd-Frank Act required the securitizer of asset-backed securities to retain not less than 5 percent of the credit risk of the assets collateralizing the security. Asset-backed securities are created by buying and bundling loans and creating securities backed by those assets, which are then sold to investors.[20]

Changes to the SEC’s Authority—The bill repeals various provisions in Title IX of the Dodd-Frank Act to the SEC’s authority to restrict mandatory pre-dispute arbitration, repeals the agency’s authority to disclose certain executive compensation levels, repeals the SEC’s authority to require specialized, politically-motivated public company disclosure requirements, repeals several requirements for the SEC to conduct studies, and various other provisions.

Definition of Accredited Investor—Similar to legislation passed by the House in the 114th Congress, the bill amends the definition of “accredited investor” to include natural persons whose individual or joint net worth with a spouse exceeds $1 million; a natural person having an individual income greater than $200,000 or joint income with a spouse greater than $300,000 in the two years prior; a natural person licensed as a broker or investment adviser; and any natural person the SEC determines has the education or job experience to qualify as having professional knowledge related to investment.

Under the Securities Act of 1933, a company that offers or sells its securities must register the securities with the SEC or find an exemption from the registration requirements. The Act provides companies with a number of exemptions, including an exemption for a company that sells securities to what are known as "accredited investors."

Private Equity Fund Advisers—The bill exempts the advisers to private equity funds, but not hedge funds, from the registration and reporting requirements imposed by the Dodd-Frank Act. Historically, many of the investment advisers to private funds had been exempt from registration with the SEC under the so-called “private adviser” exemption.

The Dodd-Frank Act replaced the old “private adviser” exemption with narrower exemptions for advisers that advise exclusively venture capital funds and advisers solely to private funds with less than $150 million in assets under management in the United States. As a result of the Dodd-Frank Act, many previously unregistered advisers to private funds are now required to register with the SEC or the states.[21] The bill restores this exemption, similar to legislation passed by the House in the 113th Congress.

Title IX—Repeal of the Volcker Rule[22]

Repeal of the Volcker Rule—Despite the fact that proprietary trading was not a cause of the financial crisis, the Dodd-Frank Act imposed the so-called Volcker Rule to prohibit "banking entities" from engaging in "proprietary trading" and from making investments in or having relationships with hedge and similar "covered funds" that fall are exempt from registering with the Commodity Futures Trading Commission (CFTC) or with the SEC. However, the Act required the five regulators charged with implementing the Volcker Rule to carry out numerous activities considered essential to the safety and soundness of banking institutions or to the maintenance of liquid capital markets, like market making.[23] During the implementation of the Volcker Rule, significant market distortions have developed as firms have struggled to determine what activities qualify as “proprietary trading” and which constitute permitted “market making”, most concerning being the significant decrease of liquidity in the fixed income markets.  The bill repeals the Volcker Rule.

Title X—Federal Reserve Oversight Reform and Modernization[24]

Rules Based Monetary Policy—The bill requires the Fed to generate a monetary policy rule to provide added transparency about the factors leading to future rate recommendations. A monetary policy rule is an equation that empirically shows why the Fed recommends a particular monetary policy course and allows the public to predict how the Fed will change course in the future depending on changes in the economy.[25] Note: this provision legislates how the Fed communicates monetary policy to make it more transparent, but this section does not legislate any particular monetary policy course.

Federal Open Market Committee (FOMC) “Blackout Period”—The bill specifies that the blackout period associated with meetings of the FOMC–a Federal Reserve policy that prohibits Fed Governors and officials from speaking in public on any matter during the week prior to an FOMC meeting and immediately following an FOMC meeting–begins immediately after midnight on the day that is one week before the meeting and ends at midnight on the day after the meeting takes place.[26]

Fed’s Emergency Lending Authority—The bill provides that the Federal Reserve may exercise its emergency lending authority only if the “unusual and exigent circumstances” identified as the basis for the exercise of such authority also “pose a threat to the financial stability of the United States”; to require the affirmative vote of at least nine presidents of the regional Federal Reserve Banks in addition to the affirmative vote of five members of the Federal Reserve Board to exercise the emergency lending authority.

Fed Audits—The bill requires the Government Accountability Office (GAO) to conduct annual audits Federal Reserve Board and Federal Reserve Banks and report to Congress on the results of its audit.

Title XI—Improving Insurance Coordination through an Independent Advocate[27]

Repeal of the Federal Insurance Office; Creation of the Office of the Independent Insurance Advocate—The bill abolishes the Federal Insurance Office and establishes the Office of the Independent Insurance Advocate to act as an independent advocate on behalf of U.S. policyholders on prudential aspects of insurance matters.

Title XII – Technical Corrections


Background

In response to problems raised by the 2007-2009 financial crisis, Congress enacted the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the Dodd-Frank Act) was enacted on July 21, 2010. The Dodd-Frank Act mandated the promulgation of more than 400 rules, created a new regulatory umbrella group chaired by the Treasury Secretary—the Financial Stability Oversight Council (FSOC)—with authority to designate certain financial firms as systemically important and subjecting them and all banks with more than $50 billion in assets to heightened prudential regulation. Financial firms were also subjected to a special resolution process (called "Orderly Liquidation Authority") similar to that used in the past to address failing depository institutions following a finding that their failure would pose systemic risk.[28]

The Dodd-Frank Act made other changes to the regulatory structure. It created the Office of Financial Research to support FSOC. The Act consolidated consumer protection responsibilities in a new Bureau of Consumer Financial Protection (CFPB). It consolidated bank regulation by reassigning the Office of Thrift Supervision's (OTS's) responsibilities to the Office of the Comptroller of the Currency. A federal office was created to monitor insurance. The Federal Reserve's emergency authority was amended, and some of its activities were subjected to greater public disclosure and oversight by the GAO.[29]

Other aspects of the Dodd-Frank Act addressed particular sectors of the financial system or selected classes of market participants. The Dodd-Frank Act required more derivatives to at central counterparties and registered and traded on regulated exchanges overseen by the SEC and CFTC, reporting for derivatives that remain in the over-the-counter market, and registration with appropriate regulators for certain derivatives dealers and large traders. Advisers to private funds and private equity funds were subject to new reporting and registration requirements. Credit rating agencies were subject to greater government controls, disclosure and legal liability provisions, and references to credit ratings were required to be removed from federal statute and regulation. Executive compensation, corporate governance mandates for all public companies, and securitization reforms attempted to reduce incentives to take excessive risks. Securitizers were subject to risk retention requirements, popularly called "skin in the game." It made changes to bank regulation to make bank failures less likely in the future, including prohibitions on certain forms of bank and bank affiliate trading (known as the "Volcker Rule"). It created new mortgage standards in response to practices that caused problems in the foreclosure crisis.[30]  Dodd-Frank also required the SEC to issue rules to require new and burdensome disclosure requirements for all public companies on conflict minerals, resource extraction payments and mine safety violations.

According to the bill sponsor: “The Financial CHOICE Act offers economic opportunity for all and bank bailouts for none.  The era of ‘too big to fail’ will end and we will replace Dodd-Frank’s growth-strangling regulations on community banks and credit unions with reforms that expand access to capital so small businesses can create jobs and consumers have more choices and options when it comes to credit. With the Financial CHOICE Act, we will unleash America’s economic potential and give Main Street job creators desperately needed help so more Americans can find work, have good careers and give their families a better life.”[31]


Amendments

  1. Rep. Jeb Hensarling (R-TX) –The Manager’s Amendment revises provisions subjecting certain FDIC and NCUA functions to congressional appropriations, relating to appointments of positions created by the Act, and providing congressional access to non-public FSOC information. The bill also removes a provision in the bill, as reported, that would have repealed a provision in the Dodd-Frank Act that requires the Federal Reserve to set a price cap on debit card interchange fees, commonly referred to as the “Durbin Amendment.” For a more detailed summary of the changes to the underlying bill in the amendment, click here.
     

  2. Rep. Trey Hollingsworth (R-IN)—The amendment allows closed-end funds that are listed on a national securities exchange, and that meet certain requirements to be considered “well-known seasoned issuers” or “WKSIs”.
     

  3. Rep. Lloyd Smucker (R-PA)—This amendment expresses the sense of Congress that consumer reporting agencies and their subsidiaries should implement stronger multi-factor authentication procedures when providing access to personal information files to more adequately protect consumer information from identity theft.
     

  4. Rep. John Faso (R-NY)—The amendment allows Mutual Holding Companies (MHCs) to waive the receipt of dividends.
     

  5. Rep. Martha McSally (R-AZ)—This amendment requires the Department of Treasury to submit a report to Congress regarding its efforts to work with Federal bank regulators, financial institutions, and money service businesses to ensure that legitimate financial transactions along the southern border move freely.
     

  6. Rep. Ken Buck (R-CO)—This amendment requires the GSA to study CLEA’s real estate needs due to changes in the Agency’s structure. It then authorizes the GSA to sell the current CLEA building if CLEA’s real estate needs have changed and there is no government department or agency that can utilize the building.


     

Cost

The Congressional Budget Office (CBO) estimates that enacting H.R. 10 would reduce federal deficits by $24.1 billion over the 2017-2027 period. Direct spending would be reduced by $30.1 billion, and revenues would be reduced by $5.9 billion.


Staff Contact

For questions or further information please contact John Huston with the House Republican Policy Committee by email or at 6-5539.


[1] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[2] Financial market utilities (FMUs) are multilateral systems that provide the infrastructure for transferring, clearing, and settling payments, securities, and other financial transactions among financial institutions or between financial institutions and the system.  Title VIII of the Dodd-Frank Act provides FSOC the authority to designate systemically important FMUs, which among other requirements, grants the FMUs access to the Federal Reserve’s discount window.   

[3] The Dodd-Frank Act requires that bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated by the FSOC for supervision by the Federal Reserve annually submit resolution plans or “living wills” to the Fed and the FDIC. Each plan, commonly known as a living will, must describe the company's strategy for rapid and orderly resolution in the event of material financial distress or failure of the company, and include both public and confidential sections.

[4] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[5] Id.

[6] See House Report 114-694 at 2.

[7] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[8] Some of the provisions highlighted in this paragraph are included in Section 844 of Title VIII.

[9] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[10] Under current law, this value is $50,000. 

[11]As defined in 15 U.S.C. 1639c(b)(2)(b) , the term "average prime offer rate" (APOR) means the average prime offer interest rate for U.S. Treasury securities with a comparable maturity on the date the interest rate for the transaction is set.

[12] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[13] See Congressional Budget Office Cost Estimate, H.R. 10, the Financial CHOICE Act of 2017. 

[14] Id.

[15] When consumers finance automobile purchases from an auto dealership, the dealer often facilitates indirect financing through a third party lender. The dealer helps by originating the loan and finding financing sources. In this indirect auto financing process, the lender usually provides the dealer with an interest rate that the lender will accept for a given consumer. The CFPB issued Guidance to indirect auto financers on March 21, 2013, creating certain standards for indirect auto financers.

[16] Under the Dodd-Frank Act, the CFPB has the authority to establish rules and guidance for unfair, deceptive and abusive acts or practices across consumer financial service providers. The standard for "abusive" practices could expose banks and nonbanks to extensive uncertainty and litigation risk.

[17] On May 5, 2016, the CFPB published a proposed rule substantially curtailing the ability of financial services providers and consumers to enter into voluntary pre-dispute arbitration clauses in contracts. A pre-dispute arbitration agreement is an agreement made by parties in a contract before any issues or problems arise. The agreement mandates that any disputes that the parties have will be handled not in a court system, but through binding arbitration. Such contracts are extremely common in business transactions. Insurance companies, cell phone providers, car companies or any other corporation or business entity may include an arbitration agreement with customers. Businesses also sometimes include arbitration agreements when they are doing business with each other. (Read more: http://law.freeadvice.com/litigation/arbitration/pre_dispute_arbitration.htm#ixzz4irO8952n) The proposed rule would not prohibit agreements that require individual claims to be addressed through arbitration; rather, the proposal would bar covered consumer financial service providers from contractually prohibiting consumers from initiating or joining class action lawsuits.

[18] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[19] The Dodd-Frank Act established the SEC Reserve Fund” (Reserve Fund or Fund) to be used as the SEC determines is necessary to carry out the functions of the Commission, without Congressional approval. The SEC is authorized to deposit into the Fund up to $50 million per year from registration fees collected from SEC registrants, with a Fund balance limit of $100 million

[20] See SEC website, Asset-Backed Securities

[21] See SEC website, Private Fund Adviser Resources

[22] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[23] See CRS Report, “The Volcker Rule: A Legal Analysis,” March 27, 2014.

[24] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[25] See House Report 114-332 Part 1 at 20.

[26] Id. at 18.

[27] See Section-by-Section Analysis of H.R. 10, as reported, provided by the House Financial Services Committee

[29] Id.

[30] Id.

[31] See House Financial Services Press Release, “House to Vote on Financial CHOICE Act Next Week,” June 2, 2017.

 

115th Congress