Got an Idea for a Banking Rule? Here’s Where To Send It

So you’ve got a brilliant idea for a banking rule. Maybe it’s a fix for overdraft fees that feel like a surprise boss battle.
Maybe it’s a clearer disclosure so regular humans don’t need a law degree to open a savings account. Or maybe you’ve spotted a
loophole big enough to drive a Brinks truck through.

Here’s the good news: in the U.S., you’re not stuck yelling into the void (or into your phone while stuck on hold).
There are real, official ways to get your idea in front of the agencies that write and enforce banking rules.
The trick is sending it to the right place, at the right time, in a format that actually gets read.

This guide walks you through the main “send it here” optionspublic comments, petitions for rulemaking, and agency-specific
submission channelsplus how to write something regulators can use (not just something that feels satisfying to type).

First, Know What “Banking Rules” Really Means (Because It’s a Group Project)

“Banking rules” can cover everything from how banks hold capital, to how they advertise deposit insurance,
to how credit decisions are explained, to anti-money-laundering requirements. And in the U.S., different regulators own
different slices of that pie. Sometimes they even co-author rules togetherwhich is great for consistency, and terrible for
anyone who likes simple org charts.

Common “rule owners” you’ll run into

• Federal banking regulators (often writing rules for banks’ safety, soundness, and operations)
• Consumer protection regulators (focused on credit cards, mortgages, disclosures, and fair lending)
• Credit union regulators (rules specific to credit unions)
• Financial crime/AML regulators (rules about reporting and compliance to fight illicit finance)

You don’t have to memorize the entire alphabet soup today, but you do need one key insight:
the best submission channel depends on whether an agency is already asking for comments or whether you’re trying
to persuade them to start a new rulemaking.

Option A: Comment on a Proposed Rule (This Is the Fastest Legit Path)

If an agency has a proposed rule open for public input, that’s your moment. This is the classic U.S. “notice-and-comment”
process: agencies publish a proposal, the public submits comments, and the agency reviews them before finalizing a rule.

Your mission: find the proposal that matches your idea and submit a comment during the open comment period.
Think of it like showing up to the town hall meeting while the microphone is actually on.

Where to submit public comments

1. Regulations.gov the main federal docket system. Many banking-related proposals accept comments here.
   You’ll typically see a “Comment” button and a docket ID (which is basically the rule’s tracking number).
2. FederalRegister.gov where proposals are published. Many entries include a built-in “Submit a Formal Comment”
   button that routes you to the official docket.
3. Agency-specific portals some agencies prefer (or also accept) comments through their own “Submit Comment”
   pages for specific proposals.

Agency channels you’ll see often (banking + finance)

• Federal Reserve: often has a “Proposals for Comment” page with direct submission links.
• FDIC: frequently accepts comments through a public submissions page and also via email for certain notices.
• OCC: commonly uses Regulations.gov dockets for proposed rules and requests for information.
• CFPB: posts “notice and opportunities to comment” and routes many proposed rule comments through Regulations.gov.
• NCUA: points commenters to Regulations.gov for proposed credit-union-related rules and proposals.
• FinCEN: accepts many comments via Regulations.gov and sometimes also by mail (especially for certain AML items).

How to find the right proposal in 5 minutes

1. Start with your topic in plain English: “overdraft,” “deposit insurance advertising,” “capital requirements,” “credit reporting,”
   “fair lending,” “debit interchange,” “AML reporting,” etc.
2. Search on FederalRegister.gov and Regulations.gov for your keyword.
3. Open the item and read two things first: (1) the summary and (2) the ADDRESSES section.
   The ADDRESSES section tells you exactly where comments go and what identifier to include.
4. Check the comment deadline. If the comment period is closed, jump to Option B or Option C below.

Before you hit “Submit”: don’t accidentally publish your personal info

Public comments are often posted as-is. Translation: if you include account numbers, addresses, or anything you wouldn’t want
printed on a billboard, you may regret it. Treat your comment like a public documentbecause it usually is.

Option B: File a Petition for Rulemaking (Yes, You Can Ask for a New Rule)

What if there’s no open proposal that fits your idea? You can still ask an agency to create, change, or repeal a rule by
submitting a petition for rulemaking.

Under the Administrative Procedure Act, agencies must give interested people a way to petition for rulemaking. Practically,
this means you can submit a structured request explaining:
what rule you want, why it’s needed, and what problem it solves.

When a petition makes sense

• Your issue is real and recurring, but there’s no active proposal (example: a disclosure gap that keeps confusing consumers).
• The industry changed (new payment tech, new fraud patterns), and the current rules don’t match reality.
• You have evidence that a current rule causes unintended harm or excessive cost without meaningful benefit.
• You can propose workable language, a framework, or at least a clear direction for the agency to explore.

How to structure a petition so it looks serious (and not like a rant with headings)

1. Title: “Petition for Rulemaking: [Topic]”
2. Requested action: “We request the agency issue/amend/repeal a rule to…”
3. Problem statement: what’s happening now and who is affected (consumers, community banks, credit unions, small businesses).
4. Evidence: complaints data, studies, enforcement trends, operational examples, or even a well-documented pattern.
5. Proposed solution: the rule concept, a safe harbor, a disclosure model, thresholds, timelines, or example text.
6. Impact analysis: benefits, costs, implementation steps, and how to minimize unintended consequences.
7. Alternatives: show you considered other paths (guidance, supervision, industry standards) and why a rule is needed.

If you want to increase your odds: partner with others. Trade groups, consumer advocacy orgs, community bank associations,
fintech coalitions, and academics can add data and credibility. Regulators tend to take “this affects many people and here’s proof”
more seriously than “this annoyed me last Tuesday.”

Option C: Respond to Requests for Information (RFIs) and Other “We’re Listening” Notices

Agencies don’t only ask for feedback through proposed rules. They also publish Requests for Information (RFIs),
guidance drafts, and notices that seek public input before a formal proposal exists.

RFIs are underrated. They’re often where agencies decide what problems to prioritizeand what data they need. If you have a
novel idea, an RFI can be the perfect doorway because agencies are actively gathering real-world examples.

What to submit for an RFI

• A clear description of the problem (who, what, how often)
• Real examples (anonymized where needed)
• What outcome you want (clarity, lower risk, fewer disputes, lower compliance cost, less consumer harm)
• Specific questions the agency should ask in a future proposal
• Any data you can share responsibly

How to Write a Banking Comment That Doesn’t Get Ignored

Let’s be blunt: agencies get a lot of comments. Some are brilliant. Some are copy-paste campaigns. Some are… passionate.
The comments most likely to matter share one trait:
they help the agency build a better rule and defend it legally.

The “regulator-friendly” comment checklist

• Start with your bottom line in the first paragraph.
• Use the docket ID / RIN / proposal title so it’s filed correctly.
• Respond to the agency’s questions (most proposals list specific questions).
• Be specific: “Change X to Y” beats “do better.”
• Bring evidence: data, operational impact, consumer outcomes, compliance steps, real-world constraints.
• Offer alternatives: if you hate a requirement, propose a workable substitute.
• Keep it readable: headings, bullets, short paragraphs. Make it easy to quote.

Examples of comments that land well

Example 1: Deposit insurance advertising clarity
“The proposed statement requirement would reduce confusion, but the current draft leaves a gap for mobile UI layouts.
We recommend allowing a compact disclosure format for screens under X inches, with a standardized icon and tap-to-expand language.
This preserves the intent of the rule while making compliance feasible for mobile-first banks.”

Example 2: Overdraft fee fairness with a workable rule design
“We support reducing surprise overdraft fees. However, a hard fee cap alone may push costs into less transparent categories.
We recommend: (1) a required real-time balance warning before transaction authorization, (2) a grace window for small-dollar negatives,
and (3) a monthly fee limit tied to account activity, with clear consumer opt-in for overdraft coverage.”

Example 3: AML reporting burden reduction without weakening enforcement
“Small institutions spend disproportionate time on low-value alerts. We propose a tiered threshold approach and safe-harbor
for certain low-risk transaction patterns, combined with stronger reporting triggers for high-risk typologies.
This reallocates resources toward higher-impact cases.”

Where To Send It: A Practical “Choose Your Path” Map

If you found an open proposal

• Submit through Regulations.gov when the docket supports it.
• Use FederalRegister.gov’s comment button when available (it usually routes correctly).
• Use an agency’s submission portal if they provide one for the proposal.

If there’s no open proposal

• Submit a petition for rulemaking to the most relevant agency.
• Watch for RFIs and submit your idea when agencies are gathering input.
• Engage through stakeholder channels (industry associations, consumer groups, academic comments) to strengthen evidence.

If your idea affects a specific type of institution

• Credit unions: look to NCUA dockets and proposals.
• Deposit insurance and bank supervision: FDIC often plays a central role.
• National banks: OCC is frequently involved.
• Holding companies and certain payments rules: the Federal Reserve is often involved.
• Consumer financial products: CFPB is often the main rulemaker.
• AML/BSA: FinCEN is a key destination for ideas and comments.

Timing Tricks: When Your Idea Has the Best Chance

Timing matters. A great idea submitted after the deadline is like a perfect joke told after everyone leaves the room.
Here are moments when agencies are most receptive:

• During an open comment period for a related proposal
• During an RFI or a pre-rule inquiry
• After a major industry change (new fraud pattern, new tech, new market structure)
• After a court decision that changes the legal landscape
• After a major incident (systemic outages, widespread consumer harm, new risk exposures)

What Not To Do (Unless Your Goal Is to Become a Cautionary Tale)

• Don’t include sensitive personal info (account numbers, Social Security numbers, private addresses).
• Don’t paste a wall of text. If it can’t be skimmed, it won’t be used.
• Don’t ignore feasibility. If your idea can’t be implemented, propose a phased approach.
• Don’t assume regulators know your business model. Explain the workflow like you’re onboarding a smart new hire.
• Don’t just complain. Pair your critique with a fix.

Frequently Asked Questions

Do agencies actually read comments?

Yesespecially the ones that contain evidence, address the proposal’s questions, and propose workable alternatives.
Many final rules include responses to key issues raised by commenters.

Should I submit as an individual or an organization?

Either works. Organizations can add scale and data; individuals can add concrete lived impacts.
The best submissions often include both: data plus real-world stories.

Can I submit the same comment to multiple agencies?

If a rule is joint (multiple agencies), follow the instructions in the proposal. Often a single docket submission is sufficient,
but sometimes each agency has its own docket. When in doubt, mirror the submission to each listed channelcleanly labeled and consistent.

Real-World Experiences: What It Feels Like to Send a Banking Rule Idea (and What Actually Helps)

The internet loves a myth: “Regulators don’t listen.” The truth is more nuancedand honestly more human.
People who submit comments often describe the process like writing a very polite, very organized message in a bottle.
You might not get a direct reply, but your idea can show up later in the way a rule is clarified, softened, phased in, or rewritten.

One common experience comes from small business owners who’ve been burned by bank account holds or confusing funds availability policies.
They’ll say something like, “I don’t mind rulesjust make them clear.” The strongest submissions from this group usually include a timeline:
what happened on day 1, what the bank communicated (or didn’t), what the financial impact was, and what rule change would have prevented the mess.
When commenters pair that story with a simple fixlike standardized notice language, minimum disclosure requirements, or a short required explanation
when an automated hold triggersthe comment becomes something an agency can actually translate into a requirement.

Another recurring story comes from community bankers and compliance staff. Their experience often sounds like:
“We support the goal, but the operational steps don’t match the size of our institution.”
These comments carry weight when they’re specific about implementation. Instead of saying “this is hard,” they’ll break down:
the number of hours, the systems involved, vendor constraints, how long testing takes, and what a realistic timeline looks like.
A surprisingly effective move is proposing a tiered approachlike delayed compliance dates or simplified reporting for smaller institutionswhile still
preserving the core consumer or safety objective. Agencies regularly have to balance protections with practical adoption, and detailed operational notes
help them do that without guessing.

Consumers who write about overdraft or fee issues often report a different emotion: frustration mixed with “Is anyone even listening?”
The comments that stand out tend to avoid broad accusations and focus on mechanics: how the fee was triggered, what the app showed,
whether the customer had a real chance to avoid it, and what kind of warning would have changed behavior. A pattern that repeatedly helps:
proposing “pre-transaction clarity” ruleswarnings before authorization, grace periods for small negatives, and clearer opt-in/opt-out controls.
Those suggestions are actionable, measurable, and easy to evaluate for unintended consequences.

Fintech teams and product managers often describe the comment process like translating app design into regulatory language.
Their best submissions usually include mock flows (“screen A shows X; user taps; disclosure appears; consent is logged”), risk controls,
and suggested definitions (because half of rulemaking is defining terms so everyone stops arguing). If you’re in this camp, the most powerful
thing you can submit is clarity: proposed definition language, examples of what is and isn’t covered, and how to prevent loopholes.
Regulators don’t need your entire product roadmapthey need a rule boundary that works in the real world.

There’s also a “group effort” experience: coalitions. When advocates, industry members, and researchers coordinate,
they often submit a shared core comment plus specialized attachments (data appendix, legal analysis, operational appendix, consumer stories).
People involved in these coalitions consistently say the same thing: organization wins. A clean executive summary, a numbered list of requested changes,
and evidence tied to each change can turn a comment into a tool the agency can quote and respond to.

And then there’s the most underrated experience: the “small tweak” victory. Sometimes the win isn’t a massive policy reversal.
It’s a clarified definition, an extended deadline, an added exemption for rare cases, or a requirement that banks provide a clearer notice.
These are the kinds of changes that often come directly from high-quality comments. So if you submit something thoughtful and specificeven if it feels small
you may be improving the rule in a way that benefits thousands or millions of people who will never know your name. Which is kind of the point.

Conclusion

If you’ve got an idea for a banking rule, don’t just vent about itroute it. The fastest path is commenting on an open proposal
through the official docket channels. If there’s no active proposal, a petition for rulemaking (with evidence and a workable solution)
can put your issue on the agency’s radar. And if you want to maximize your impact, write like someone who wants to be quoted:
clear asks, real examples, feasible alternatives, and clean structure.

Banking rules shape what people pay, what they understand, and how safely the system runs. Your idea might not become a headline,
but it can become a better definition, a smarter disclosure, or a fairer process. And that’s how policy actually gets builtone well-aimed submission at a time.