In separate comment letters to the Board of Governors of the Federal Reserve System, CBAI urged the prompt implementation of H.R. 3329 (“Act”) which would increase the Small Bank Holding Company Policy Statement asset threshold from $500 million to $1 billion, expand the scope to include previously excluded small savings and loan holding companies, and make the appropriate technical changes to regulatory capital-reporting requirements.
CBAI appreciates the Board’s recognition that these small holding companies have less access to capital than larger ones. We have consistently advocated for an increase in the Policy Statement asset threshold and supported a threshold increase in the Act. The current proposed increase to $1 billion will include 600 more bank and savings and loan holding companies under the Policy Statement and is a significant step in the right direction to make it easier for these holding companies to issue debt or equity and reduce their regulatory-reporting burden. Read First Comment Letter. Read Second Comment Letter.