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CBAI Comment Letters

  • CBAI urges the Farm Credit Administration to withdraw a misguided proposal to allow Farm Credit System lenders to make virtually any type of loan as long as the loan is labeled as a "bond" or an "investment."  Read Comment Letter.
  • CBAI requests the FHFA grant additional time for community banks to comment on a Notice of Proposed Rulemaking regarding Federal Home Loan Bank membership. Read Comment Letter.
  • CBAI urges federal regulators to address outdated, unnecessary, or unduly burdensome regulation of community banks. Read Comment Letter.
  • CBAI urges the CFPB to exempt community banks from the regulatory burden of the annual mailing of redundant privacy notices. Read Comment Letter.
  • CBAI urges CFPB to exempt community banks from new debt collection rules. Read Comment Letter.
  • CBAI urges the Financial Accounting Standards Board to withdraw the current accounting standards proposal that would require every community bank to revise the way they accout for loan loss reserves (ALLL), loans and securities and re-propose a simpler and more straightforward method of analysis that would not harm Illinois community banks. Read Comment Letter
  • CBAI requests guidance and clarity from the Department of Housing and Urban Development and the Consumer Financial Protection Bureau regarding HUD's Disparate Impact Regulation and the CFPB Mortgage Standards. Read Comment Letter
  • CBAI urges the Consumer Financial Protection Bureau to expand the Qualified Mortgage (QM) exemptions by creating a new category of QMs for community banks which would benefit from a conclusive safe harbor presumption with the ability-to-repay rules. Read Comment Letter
  • CBAI's final comment letter to the Federal Reserve Board/FDIC/OCC highlights several specific proposals in the Capital NPRs which threaten the survival of community banks, and continues to urge a community bank exemption from Basel III. Read Comment Letter
  • CBAI's interim comment letter urges the Federal Reserve Bank/FDIC/OCC to exempt community banks from the proposed implementation of the Capital NPRs and allow community banks to continue to operate under Basel I capital requirements. Read Comment Letter
  • CBAI Urges the Federal Reserve Bank/FDIC/OCC to grant more time for community banks to comment on the Proposed Rulemaking on Minimum Regulatory Capital (Basel III NPR) and the Standardized Approach for Risk-weighed Assets (Standardized Approach NPR). Read Comment Letter
  • CBAI Urges the Financial Accounting Standards Board (FASB) to exempt community banks from the application of full fair value or mark-to-market accounting to their balance sheets. Read Comment Letter
  • CBAI urges the U.S. Department of Treasury (regarding the Small Business Lending Fund (SBLF) to reconsider its decision to assess the penalty and adopt a less rigid response to reasonable requests for more time to submit audited financial statements/certifications. Read Comment Letter
  • CBAI urges the CFPB to adopt a balanced approach in rulemaking on overdraft protection programs. Read Comment Letter
  • CBAI urges FDIC Chairman Gruenberg to reduce the regulatory burden on and be a more vocal supporter of community banks. Read Comment Letter
  • CBAI urges FinCEN to adopt a less burdensome rule regarding customer due diligence (CDD) requirements. Read Comment Letter
  • CBAI urges the Securities and Exchange Commission to issue guidance to include thrifts and thrift holding companies in the definition of banks and bank holding companies in Section 6019a) of the JOBS Act. Read Comment Letter
  • CBAI urges CFPB to adopt a Rule specifically stating that information provided by community banks will not waive or otherwise affect any privelege(s) with respect to such information under Federal or State law. Read Comment Letter
  • CBAI urges banking regulators to shield community banks from unnecessary and unwarranted regulatory burden from the implementation of the Volker Rule. Read Comment Letter