Dear Illinois Community Banker: CBAI urges you to contact your primary regulator to request a 90-day extension of the public comment period for the joint-agency Basel III capital standard proposal. We have attached a copy of CBAI's comment letter for you to use as a guide. CBAI strongly opposes subjecting community banks to the same capital standards as the nation's largest too-big-to-fail financial institutions. We are actively engaged with the various banking regulators in representing your interests and protecting your franchise value. Your cooperation is needed to extend the comment period which expires on September 7th. We recommend that your personalized comment letter be organized as follows.
o An introductory sentence should include your name, title, the name of your bank, and a statement that the Fed/FDIC/OCC is your primary regulator.
o Next should be a brief description of your bank's location, asset size, and business model or area of concentration (i.e.,
agriculture, small business lending, residential mortgage lending).
o You should express your concern for the impact of the proposed NPRs on your bank’s capital position and thus your ability to serve your community.
o The paragraph should conclude with your request for a 90-day extension to the comment period to properly assess the impact of the NPRs on your bank.
2. Body Paragraph
o The body paragraph should detail the areas of Basel III that most concern you (based on the information you have read
so far) and the difficulty in analyzing the impact of the proposed NPRs on your bank within the comment period that expires on September 7th.
3. Concluding Paragraph
o The final paragraph should restate your request for a 90-day extension and provide your contact number and e-mail address for questions or additional information.
Please do not personally sign the letter, or reveal confidential data, as letters will be posted by the regulators for anyone to view. Use the e-signature convention /s/ instead of your actual signature.
Comments may be submitted within the body of your e-mail or as an attached letter. CBAI's letter was sent as a PDF attachment.
Please make sure to include the Docket or RIN Numbers in the subject line so the regulators can properly direct the comments to the appropriate area. Here are the detailed instructions for each of the three primary regulators: • FDIC-supervised banks: Send comments to comments@FDIC.gov. Include “Basel III FDIC RIN 3064-AD95, RIN 3064-AD96, and RIN 3064-D97” in the subject line.
• Federal Reserve-supervised banks: Send comments to firstname.lastname@example.org. Include “Basel III Docket No.1442” in the subject line.
• OCC-supervised national banks: Send comments to email@example.com. Include “Basel III OCC Docket ID OCC-2012-0008, 0009, and 0010” in the subject line. Thank you very much! Click here to access CBAI’s comment letter.