The shift to financial modernization which has inched along since the early 1990s is slowly gathering steam. Since the publication of the "Building Better Banks" report from BAI and McKinsey & Company, Inc. last year making the case for performance-based regulation, policymakers and regulators have continued to embrace and support the concept. Congress passed the Economic Growth and Regulatory Relief Act which frees well- managed and well-capitalized banks from filing applications to set up ATMs (which used to take six weeks), expand headquarters, and other activities. The Office of the Comptroller of the Currency (OCC) published Part 5, which defines the corporate activities of national banks. The message was similar: a well-managed bank would become an OCC-eligible bank and be rewarded for its efforts. Other regulatory examples suggest similar reinforcement for the effort.

A break in the barriers

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