CBAI urged broad regulatory relief for community banks in its final Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) comment letter. The EGRPRA Act of 1996 requires that banking regulations be reviewed by the agencies at least once every 10 years. The purpose of this review is to identify outdated, unnecessary, or unduly burdensome regulations and consider how to reduce regulatory burden on insured depository institutions. CBAI urged regulators to act swiftly to identify and implement changes in regulations that will help ease the regulatory burden which threatens the survival of many community banks.
CBAI made a number of specific recommendations including: increasing CTR threshold and greater FinCEN transparency and accountability, increasing CRA examination thresholds and applying the CRA to credit unions, greater recognition of managements’ efforts in repeat examination findings to accurately reflect effort and progress, including reciprocal deposits as core deposits for Call Report purposes and exempting them from restrictions for less than well capitalized banks, and eliminating the requirement to consistently file an FY Y-8 when a bank holding company is limited in its activity so as to have no covered transactions. Read CBAI Comment Letter.
March 21, 2016