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CBAI Thanks Congressman Hultgren for Urging Delay in CECL Implementation

The Community Bankers Association of Illinois (CBAI) thanks Illinois Congressman Randy Hultgren (R-14th) for joining with 25 members of the United States House of Representatives in urging the Financial Accounting Standards Board (FASB) and the Securities and Exchange Commission (SEC) to delay the implementation of the Current Expected Credit Loss (CECL) model. The letter urged “steps be taken to address the economic risks arising from the implementation of the new standards” as the final accounting rule has the “potential to negatively affect the cost and availability of credit, add volatility to the balance sheets of banks, and impact the ability of financial institutions to continue lending in stressful economic environments.” The letter requested the reevaluation of the accounting standard “be undertaken immediately” and that there be a delay in the implementation of CECL pending this important review.

CBAI and the ICBA actively participated in commenting on FASB’s proposed CECL model. While the final Rule, which was issued in 2016, reflected input from community bankers and their associations, a reevaluation of the accounting standard is warranted. CBAI appreciates Congressman Hultgern’s continued leadership on this important issue. Read Letter to FASB and SEC.

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Senate Votes to Overturn the CFPB Arbitration Rule!

In a major victory for community banks, the United States Senate voted Tuesday evening to overturn the Consumer Financial Protection Bureau’s (CFPB) controversial Arbitration Rule (Rule) which was set to take effect in March. The United States House of Representatives voted to rescind the Rule in July. Both votes in the House and Senate were generally along party lines with Republicans voting in favor and Democrats voting against the repeal.

The Rule would have prohibited financial institutions from including a clause in their agreements which would require consumers to use binding arbitration versus litigating their grievances in class-action lawsuits. Proponents of the repeal highlighted the more than one-hundred year tradition of arbitration, which is an alternate dispute resolution process that was cited as resolving differences more quickly and with greater financial gain to consumers. The Senate vote was deadlocked with 50 voting in favor and 50 voting against; so Vice President Mike Pence cast the deciding vote to repeal the Rule.

In July of 2017, the Community Bankers Association of Illinois (CBAI) joined with forty-one state banking trade associations in a letter to the Senate urging support for the repeal of the Arbitration Rule.The letter stated that “If the rule is allowed to stand, it will encourage the filing of frivolous class action lawsuits which have the potential to devastate community banks.” The letter concluded "With your support for S.J. Res. 47 [repeal of the Rule], arbitration will be preserved as a fair, and cost effective tool of dispute resolution. This is the best outcome for consumers, community banks, and the broader economy.” Read Joint Letter to the Senate.

October 25, 2017

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CFPB Adopts CBAI Recommendations in Final Payday Lending Rule

On October 5, 2017, the Consumer Financial Protection Bureau CFPB or Bureau) finalized its payday lending rule. While the complete analysis of the 1,700 page Final Rule continues, it does include Community Bankers Association of Illinois (CBAI) and Independent Community Bankers of America (ICBA)-advocated exemptions from the onerous full-payment test and the principal-payoff option for lenders that make 2,500 or fewer covered short-term or balloon-payment loans per year and derive no more than 10 percent of their receipts from such loans. These exemptions benefit hundreds of Illinois community banks.

Exactly one year ago, in a comment letter to the CFPB, CBAI urged the Bureau to broadly exempt community banks from their proposed payday lending rules. CBAI recommended the proposed rules be directed at the unfair and abusive practices of other lenders and not community banks. CBAI expressed concern that the rules, as proposed, would harm community bank small-dollar consumer lending and provided the Bureau with numerous recommendations to mitigate the harmful impact of the proposed rules on community banks. Read Comment Letter.

CBAI is encouraged by the Bureau’s recognition in the Final Rule that community banks treat their customers honestly and with respect. The Rule will take effect 21 months after it is published in the Federal Register. Read More.

October 10, 2017

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CBAI Urges Exemption from CFPB Small Business Data Collection Rule

In a September 12, 2017 comment letter to the Consumer Financial Protection Bureau, the Community Bankers Association of Illinois (CBAI) urged an exemption for community banks from the upcoming small business data collection rule. CBAI acknowledged that Section 1071 of the Dodd-Frank Act requires financial institutions to report information concerning credit applications made by women-owned, minority-owned, and small businesses in part to facilitate the enforcement of fair lending laws, and that the Bureau is currently focused on outreach to further its understanding of the small business lending market.

Community banks currently control less than 20% of the nation’s deposits yet make approximately 50% of the small business loans. This large percentage of lending activity clearly indicates a high level of satisfaction by small businesses with community banks whose hallmark is treating their customers and communities fairly and with respect. This exemplary behavior by community banks in small business lending clearly requires that the Bureau focus its attention on the bad actors and the wrongdoers – not community banks.

CBAI called on the Bureau to use its authority under the Dodd-Frank Act to exempt any class of entity from its rulemaking. Community banks are deserving of broad exemptions that the Bureau is able to grant to them under the law and CBAI urged the Bureau to exempt all community banks under the forthcoming small business data collection rule. Read Comment Letter.

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CBAI Urges Community Bank Exemption to the Volcker Rule

In a September 21, 2017 comment letter to the Office of the Comptroller of the Currency (OCC), the Community Bankers Association of Illinois (CBAI) urged the agencies to completely exempt community banks from the Volcker Rule. CBAI appreciated the OCC’s statement that there is broad recognition that the final Volcker Rule should be improved both in design and application, and that many [including the U.S. Department of the Treasury] have argued that the final rule is overly complex and vague. CBAI stated that the community bank business model does not include the risky practices now prohibited by the Volcker Rule; it was the risky behavior of the largest banks and financial firms that led to the financial crisis; and a complete exemption for community banks is justified. Read Comment Letter.