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CBAI Makes Recommendations to Expand Small-Dollar Consumer Lending

In a comment letter dated January 19, 2019, the Community Bankers Association of Illinois (CBAI) responded to the Federal Deposit Insurance Corporation (FDIC) request for information (RFI) on small-dollar lending. CBAI highlighted challenges in this area that included: the increased costs of loan origination, underwriting, funding and administration; barriers to charging sufficient interest rates and fees; and higher loan charge-offs. CBAI stressed that the understanding and cooperation of the FDIC will be required, particularly regarding the differences in underwriting and loan features between community banks and other lenders, and the important role “character” plays in community bank lending decisions. Flexibility will be needed both on the part of the FDIC and community banks to encourage an expansion of small-dollar consumer lending. Read CBAI’s Comment Letter.

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The Baker Group - Important Outage News

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Baker Status Update


December 28, 2018


We are currently experiencing a partial outage with our phone lines due to the nationwide CenturyLink outage. We’ve been hopeful that CenturyLink would have this resolved at this time, unfortunately it appears as they are still struggling in getting their system up and operational.

We wanted to let you know that we can accept your phone calls, however, our 1-800 numbers are not currently functional. To contact anyone at The Baker Group, please call us direct. If you are unsure of a direct number, you can always call our main line at 405-415-7200. Additionally, our emails systems are fully functional as well and serves as an alternative communication method.

We are sorry for any inconvenience this may have caused you. We will communicate with you as soon as we know the CenturyLink systems are fully functional and our 1-800 numbers are back online.

Best Regards,
The Baker Group

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CBAI Urges Fed Involvement in Faster Payments System Improvements

In its December 13, 2018 comment letter, CBAI highlighted the importance of the Federal Reserve remaining an essential access point to the payments system for community banks regardless of size, charter type or location so they can meet the existing and evolving payment needs of their customers and communities. Read CBAI’s Comment Letter.

A fair and secure payments system is at the very foundation of our financial services industry and economy. The number of payment options and the speed of development within the financial system have increased dramatically and the pace of change is unlikely to abate in the future. The importance of the payments system to community banks cannot be overstated and a system which disadvantages community banks will have a devastating impact on the nations consumers, small businesses and agriculture.

CBAI is rightly concerned with payments system improvements which are owned and operated by the nation’s largest banks/financial firms and non-bank fintechs. Only the Federal Reserve is able to provide solutions that will: increase competition; reduce concentration risks; be less likely to disadvantage community banks, and reduce the negative impact of future large bank and financial firm missteps and misdeeds on millions of consumers, small businesses and many thousands of urban and rural communities across the nation.

In its comment letter, CBAI specifically recommends that the Federal Reserve:

  • Use its connectivity to provide all financial institutions with access to real-time payments;
  • Provide central bank settlement (i.e., Real Time Gross Settlement or (RTGS);
  • Provide a Liquidity Management Tool (LMT) to support services for real-time interbank settlement for faster payments;
  • Serve as an operator for real-time payments as it does for checks, ACH, and wire transfers; and
  • Operate as a payments directory that would link to financial and other private sector directories.
While CBAI appreciates the thoughtful and inclusive approach the Federal Reserve has taken in the exploration of faster and more secure payments, NOW is the time for the Fed to move forward with implementing the proposed improvements. Read CBAI’s Comment Letter.

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CBAI Urges Modernization of the CRA

CBAI responded to the Office of the Comptroller of the Currency’s (OCC) Advance Notice of Proposed Rulemaking (ANPR) on reforming the Community Reinvestment Act (CRA or Act) regulatory framework. The CRA was enacted by Congress in 1977 to encourage insured depository institutions to help meet the credit needs of their communities, including low- and moderate-income (LMI) neighborhoods, consistent with the safe and sound operation, but has been little changed since then. This modernization effort is a historic opportunity to highlight and retain parts of the Act, identify missed opportunities for additional credit, reduce the regulatory burden on community banks and include many other financial service providers for compliance.

CBAI included in its comprehensive comment letter numerous observations and recommendations for improvement related to:

  • increasing lending and services to people and in areas that need it most, including in LMI areas;
  • clarifying and expanding the types of activities eligible for CRA consideration;
  • revisiting how assessment areas are defined and used;
  • establishing metric-based thresholds for CRA ratings;
  • making bank CRA performance more transparent;
  • improving the timeliness of regulatory decisions related to CRA; and
  • reducing the cost and burden related to evaluating performance under the CRA.
CBAI looks forward to working with the OCC and the other regulators in their joint rulemaking to modernize the CRA. Read CBAI’s Comment Letter.

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Wubben and Estes Re-elected as ICBA State Delegates

Bill Wubben of Apple River State Bank (District 1) and Mike Estes of The Fisher National Bank (District 2) were both re-elected in their respective districts.

Messrs. Wubben and Estes are both former CBAI Chairmen and have already served one three-year term on the ICBA Board of Delegates. Their second and final three-year term will begin in March 2019 at the ICBA Convention in Nashville, Tennessee. CBAI endorsed Wubben and Estes and we congratulate them on their re-election. We look forward to working with them for three more years.