The many requirements of the Dodd-Frank Act, and international Basel III accord, added to a lengthy list of existing requirements, give banks an ever-growing list of regulations to abide by. They will soon have the chance to tell regulators which of the many rules that govern them are the most burdensome and, in their eyes, unnecessary.

This week, the federal bank regulators published the first of a series of public comment requests with the goal of identifying outdated, unnecessary, or unduly burdensome rules.The Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA), passed in 1996, requires the Federal Financial Institutions Examination Council, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and Federal Reserve to review their regulations at least every 10 years.They are required to categorize their regulations, publish each category for comment, and report to Congress on any significant issues raised by those comments that may require legislative action.

In anticipation of that periodic review, the regulators have divided their regulations into 12 categories. Over the next two years, they will jointly publish Federal Register notices for public comment, each initiating a 90-day comment period to address specific categories.The first notice, published in the Federal Register this week, seeks comments on three categories: applications and reporting; powers and activities; and international operations.  Banks and the public will have until Sept. 2, 2014 to comment on these regulations. A series of roundtable discussions with bankers and interested parties are also planned, but those dates have not yet been set.

EGRPRA requires regulators to publish a summary of the comments received, identifying significant issues raised and commenting on these issues, and, if possible, to eliminate unnecessary regulations. Comments may be submitted through the Federal eRulemaking Portal, as well as by e-mail, and traditional mail.

Among the questions posed to banks during the review:

Have there been changes in the financial services industry, consumer behavior, or other circumstances that cause any regulations in these categories to be outdated, unnecessary, or unduly burdensome? If so, how should these regulations be amended?

Are any of the regulations or underlying statutes unnecessarily inflexible?

Do any regulations create a competitive disadvantage for one part of the financial services industry compared to another?

Do any regulations impose unnecessarily burdensome reporting, recordkeeping, or disclosure requirements on insured depository institutions and their holding companies? Could the agencies consolidate or eliminate any of these requirements? Could a financial institution fulfill any of these requirements electronically and reduce their burden?

Do any regulations impose requirements that are unwarranted by the unique characteristics of a particular type of insured depository institution or holding company?

Are regulations clear and easy to understand? Are there specific regulations or underlying statutes in need of clarification?

The ongoing review process does not encompass banking rules issued by, or overseen by, the Consumer Financial Protection Bureau and Treasury Department's Financial Crimes Enforcement Network.

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