In 2017, the Senate Committee on Banking, Housing, and Urban Affairs held a hearing,

listening to the mid-sized, regional and large institution perspective.

Harris Simmons is CEO of Salt Lake City-based Zion's Bank Corporation.

It was a $65 billion bank back in 2017, and he voiced a concern common among those mid-sized

institutions.

We have felt, I think, perhaps disproportionately the brunt of the burden of complying with

enhanced potential standards and other requirements of Dodd-Frank.

Dodd-Frank being, of course, the Dodd-Frank Wall Street Reform and Consumer Protection Act

passed in 2010 after the 2008 financial crisis.

The original act imposed all manner of regulations on banks, including minimal capital requirements.

The goal, of course, was for banks to insulate themselves against the kinds of failures that

triggered the 08 financial crisis.

But Simmons, representing the Regional Bank Coalition, argued that the high cost of oversight

slowed down the growth of these smaller banks.

The Banking Regulatory Apparatus has become a rubegoldberg contraption, with overlapping

regulators redundant regulations, such as the various capital regimes.

Scores of compliance, trip wires that cumulatively are overly expensive, sometimes conflicting

in their objectives, and they consume an enormous amount of management and board time and resources.

It's true.

Zion's Bank is orders of magnitude smaller than the three trillion juggernauts like JP Morgan

Chase.

But right now, Zion's Bank is also the nation's 36th largest bank, current value, $89.5

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