In a letter to the regulators, CBAI raised concerns about the intended and unintended consequences of regulations promulgated by multiple agencies to address the same regulatory concerns. CBAI is concerned that the increased capital required under Basel III, higher proposed FDIC assessments, expected increases in ALLL from the CECL, increased disallowance of “excess” ALLL, and the increased QM and TRID compliance burden will make commercial and real estate lending overly burdensome, prohibitively costly, and harmful to community banks, the financial system and our economy. CBAI requested assurances from Chair Yellen, Chairman Gruenberg and Comptroller Curry that the regulators are frequently and rigorously communicating and coordinating their activities, and considering the combined impact of their individual rulemaking. Read Letter to Regulators.
November 13, 2015