The below testimony was published as an op-ed in the American Banker on December 9, 2025: “Bank regulation is in chaos, and ‘paperwork reduction’ won’t fix that.”
Woodstock Institute Senior Director of Policy and Advocacy Brent Adams delivered the following statement at a public outreach meeting regarding the Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) at the Federal Reserve Bank of Kansas City on October 30, 2025. In alignment with the goals of EGRPRA, the meeting gathered “public comments on agency regulations that may be outdated, unnecessary, or unduly burdensome.” Woodstock’s comments specifically address the Community Reinvestment Act (CRA), one of the topics under review at the meeting.
I’m here today as a representative of Woodstock Institute, which is a national organization based in Chicago that does consumer financial protection and community economic development. Our specialty areas include the Community Reinvestment Act (CRA) and issues related to consumer and small business financing. Our core constituents include Black, Brown, and low-to-moderate income (LMI) people. I am also here today representing my boss, Horacio Mendez. Horacio has worn several hats over the years, including as a banker and an economist and a stint at the Federal Reserve Bank of San Francisco. Horacio prepared a statement for today’s conference, but my words today are my own unless otherwise indicated, and I am going to share a couple of nuggets from his statement.
I have worked in the consumer financial protection space for nearly 20 years and was introduced to EGRPRA about 10 years ago. My boss at the time, who introduced me to EGRPRA, essentially told me that EGRPRA was the enemy – a sideshow intended to bog us down and to prevent us from doing substantive work. This was the EGRPRA’s illicit intent – to prevent do-gooder groups from doing their work while fulfilling EGRPRA’s mandates. When thinking about EGRPRA, I like to use a soup kitchen analogy. EGRPRA forces us to stop serving soup while we consider outdated, unnecessary, or unduly burdensome regulations governing how we serve soup. Arguably, a soup kitchen could fulfill its EGRPRA mandates and serve soup at the same time, but small nonprofits like Woodstock Institute simply don’t have sufficient resources to do both at the same time.
I was surprised that EGRPRA has its own conference, and it made me wonder whether EGRPRA has been subjected to its own EGRPRA analysis. EGRPRA is nearly 30 years old and is its own bureaucracy. There may be inefficiencies within that bureaucracy that EGRPRA was designed to root out.
Turning to whether EGRPRA calls for regulatory changes in the present day, in Horacio’s statement he says the guiding regulatory principle of the current Administration seems to “vary from a Mr. Burns-esque tactic to ‘release the hounds’ to the Silicon Valley commandment to break things fast.”
He goes on to say that “If it weren’t for the fact that low- and moderate-income communities will bear the brunt of [the Administration’s] questionable principles and that taxpayers will foot the bill when the eventual bailout occurs, this would make excellent theater. Over 70% of American families live paycheck-to-paycheck, so they cannot afford to withstand the ‘hounds’ of predatory financial products or have their consumer financial protections ‘broken.’”
In a vacuum, there are likely EGRPRA changes to the CRA, for example, that both industry and some consumer groups could agree upon. But we are not in vacuum. One could say our regulatory environment is super-charged and overheated and what is needed more than anything is stability. EGRPRA does not, as far as I know, account for these externalities despite their significance. Says Horacio: “The uncertainty that this environment has created for the financial industry will manifest itself in greater wealth disparities as financial predators are emboldened in this new deregulatory regime, new products are released into the economic ecosystem without safeguards, and bank compliance officers struggle to keep up with constantly shifting regulatory changes.”
The conclusion recommended in light of this is to stop changing things. In Horacio’s words: “Prioritizing stability is the only sensible path forward right now. Recently enacted regulatory changes have hindered the industry’s ability to support small businesses, build affordable housing, or to assist those who have been historically excluded. At this rate, the harm done will take a generation to undo. While much of the consumer advocacy industry could be thanking you for ensuring our prolonged existence by giving us so much to fix, I am certain that we would celebrate the day when we are no longer needed because consumer financial protection works, discrimination in lending is a thing of the past, and communities come first.”
