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CBAI FedPac Fundraiser – Another Base-clearing Home Run!

CBAI extends a BIG THANK YOU! to the many community bankers, associate members, and staff for stepping up to the plate and supporting CBAI FedPac!

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A capacity crowd of CBAI FedPac supports popped-up to the Redbird Row suite to watch the St. Louis Cardinals beat the Central Division rival Pittsburgh Pirates. This was a great opportunity to take off the banker pinstripes, get comfortable, and have some fun in support of a great cause. Many brought their teammates which made for a great mix of veteran players and rookies which made this FedPac fundraiser another base-clearing home run.

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CBAI FedPac was created to enhance the voice of Illinois community banks in Washington, D.C. CBAI FedPac is an important tool for community bankers to exert a strong and proactive influence by supporting those Members of Congress who believe in our mission to compete and serve our customers and communities.

Participation in fundraisers like this event is an enjoyable and effective way to contribute to CBAI FedPac and get involved. CBAI sincerely thanks all of our team members for their contributions to CBAI FedPac.

July 7, 2016

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Community Bankers’ Petition Spurs FFIEC to Pursue Call Report Relief

In August of 2014, approximately 15,000 community bankers (more than 1,000 of which were from Illinois) signed an ICBA petition to the Federal Financial Institutions Examination Council (FFIEC) calling for relief from increasingly onerous quarterly Call Report requirements. CBAI is pleased to report that, in reaction to this impressive grassroots effort, FFIEC has announced the steps regulators are taking to reduce the regulatory burden by streamlining and simplifying Call Report requirements for community banks.

As an initial step to streamline some reporting requirements, FFIEC is seeking comments on proposals to, in part, eliminate or revise several Call Report data items. In evaluating changes to the Call Report, FFIEC reports it is seeking ways to balance the reporting burden against the regulators’ need for reliable data to ensure banks and savings associations operate in a safe and sound manner and are able to meet the financial needs of the communities they serve.

In addition to the proposed reporting changes, FFIEC is accelerating the start of a review of the appropriateness of Call Report data, evaluating the feasibility of a streamlined quarterly Call Report for community banks, and reaching out to banks and savings associations through teleconferences and webinars to explain upcoming reporting changes.

Comments on the proposed data reporting requirements will be accepted within 60 days of publication in the Federal Register. Individual reporting changes are proposed to take effect with the Call Reports for December 2015 or March 2016. Read More About Proposed Changes.

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CBAI Comments on FDIC’s Proposed Assessments for Small Banks

September 11, 2015 - CBAI commented on the Federal Deposit Insurance Corporation’s Notice of Proposed Rulemaking to refine the deposit insurance assessment system for small depository institutions ($10 billion in assets and under). The Federal Deposit Insurance Act requires the FDIC Board to establish a risk-based deposit insurance system applicable to small depository institutions to more accurately reflect risk. CBAI requested the FDIC consider our observations and incorporate our recommendations into the revised assessment system.

CBAI’s observations and recommendations included the following.

  • The greatest risk to the Deposit Insurance Fund disturbingly remains the largest too-big-to-fail banks, and addressing that risk should be the FDIC’s number one priority.

  • Every opportunity needs to be embraced that reduces the massive and growing regulatory burden on community banks. The FDIC and other banking regulators must recognize that their current regulatory reform efforts are insufficient to stem the harmful tides of consolidation and concentration, and much more needs to be done.

  • CBAI remains concerned about FDIC picking winners and losers in the financial system, and the potential for harmful consequences of the proposed assessment system on residential mortgage, C&D, C&I, and Lease lending, particularly where community banks now have a natural competitive advantage in originating and servicing these loans in their communities.

  • CBAI recommended the FDIC incorporate the proposed core deposit/asset ratio in the assessment system, but continue separate treatment for reciprocal deposits from traditional brokered deposits by defining core deposits to include reciprocal deposits.

  • CBAI recommended that a formal review, outreach and modification process be included in the rule, after several quarters of actual experience with the new system, so that community banks are aware of the FDIC’s recognition of the potential for, and that there is a mechanism to raise and for the FDIC to address, harmful consequences.

  • Finally, CBAI recommended a period of restrained enforcement for banks significantly impacted by the new system so they will have time to address and the resolve the issue of raising additional capital to maintain their capital ratios. Read Comment Letter.
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CBAI Calls on the NCUA to Withdraw its Misguided Member Business Lending Proposal

In a comment letter to the National Credit Union Administration (NCUA), the Community Bankers Association of Illinois (CBAI) expressed its unequivocal objection to their unprecedented proposal, which would comprehensively rewrite the credit union member business lending (MBL) rule, and recommended its withdrawal.

The NCUA proposal would circumvent the plain language of the Federal Credit Union Act, strip away critical prudential safeguards, and create new exceptions to the MBL cap. The NCUA proposal amounts to an end-run around Congress by a “cheerleader” regulator that is captive to the most aggressive, multi-billion dollar credit unions.

Credit union MBL powers are highly controversial. Any sweeping changes to the MBL rule should invoke vigorous Congressional oversight, including hearings. If any form of this proposal is enacted it should trigger an immediate review of the credit union tax exemption. Read Comment Letter.

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CBAI Meets with Senate Banking Committee Member Joe Donnelly (D-IN)

CBAI Vice President Federal Governmental Relations, David Schroeder, participated in an outreach meeting with U. S. Senate Banking Committee member Joe Donnelly D-Aug15-Joe DonnellyIndiana) on August 12, 2015.

The meeting was arranged by CBAI member William Smith, General Counsel of HomeStar Bank and Financial Services in Manteno, and attended by Shawn O’Brien, Director of the National Bank of St. Anne. During the constructive meeting O’Brien and Schroeder emphasized the dire need for immediate and meaningful community bank regulatory relief, discussed the state of the current regulatory environment, and cited the importance of authorizing de novo banking charters to maintain a vibrant and growing community banking sector of the financial services profession.

CBAI thanks Senator Donnelly for meeting to discuss these topics of great interest to Illinois community banks.