I'm going to share with you excerpts from a report that was sent to the Consumer Financial Protection Bureau explaining why it should practice an asset size-based exemption for its regulations. The executive summary opens:
This paper contends the Consumer Financial Protection Bureau (CFPB) should exempt or provide targeted compliance requirements for small federally insured depository institutions based on asset-based thresholds. Without asset-based exemptions, the smallest and most vulnerable banks and credit unions, termed micro depository institutions (MDIs), are likely to exit critical product lines, become less financially sound and ultimately provide fewer services to customers and members. The use of asset-based exemptions for MDIs will not meaningfully disadvantage consumers.
The report continues on to mention that MDIs have "limited managerial and financial capacity" but may offer a wide variety of products and services that require them to check their compliance across the spectrum as opposed to larger, single-service financial providers.
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