Skip navigation

Insight

One great thing in OCC's GENIUS Act proposal

One thing in the OCC's GENIUS Act proposed rule that I can wholeheartedly endorse:

"The OCC proposes to use the term 'Federal Reserve' in place of 'Board' for greater clarity because the proposed rule refers separately to boards of directors in various sections."

This practice should be adopted across the bank regulatory ecosystem. The prevailing practice of using "the Board" on second reference to the Federal Reserve decreases the accessibility of regulatory documents and increases cognitive load for anyone who has to read them -- even us experts.

Related