In a September 21, 2017 comment letter to the Office of the Comptroller of the Currency (OCC), the Community Bankers Association of Illinois (CBAI) urged the agencies to completely exempt community banks from the Volcker Rule. CBAI appreciated the OCC’s statement that there is broad recognition that the final Volcker Rule should be improved both in design and application, and that many [including the U.S. Department of the Treasury] have argued that the final rule is overly complex and vague. CBAI stated that the community bank business model does not include the risky practices now prohibited by the Volcker Rule; it was the risky behavior of the largest banks and financial firms that led to the financial crisis; and a complete exemption for community banks is justified. Read Comment Letter.
The Community Bankers Association of Illinois (CBAI) joined with the National Association of Home Builders, American Bar Association, American Medical Association, Consumer Technology Association, the Chicagoland Chamber of Commerce, and others to attend the AdvocacyTech Conference in Chicago on September 20, 2017. AdvocacyTech is a premier event for advocacy professionals to receive information on the latest and most innovative technologies designed to engage grassroots support and move their organization’s agenda forward.
The AdvocacyTech conference was hosted by the Grassroots Professional Network (GPN). The GPN was founded by the Independent Community Bankers of America’s (ICBA) Vice President of Advocacy, Joshua Habursky, and is a community of public affairs professionals who exchange innovative ideas. The GPN encourages advocacy executives at all levels to work together in shaping their profession; and with the common goal of providing professional development and networking opportunities, the group has quickly grown to hundreds of participants.
On September 18, 2017, Anthony Sisto, CBAI’s First Vice Chairman and Chairman & CEO of STC Capital Bank in St. Charles, and David Schroeder, CBAI’s Vice President Federal Governmental Relations, participated in a housing finance roundtable discussion hosted by Illinois Congressman Randy Hultgren (R-14th). Reform of the housing Government Sponsored Entities (GSEs) will hopefully be revisited by Congress in the coming months. This roundtable, which was also attended by several other stakeholders, provided an opportunity to discuss a variety of priorities, objectives, and concerns so that reform efforts result in appropriate support for affordable home ownership and protect American taxpayers from unnecessary risks.
Housing finance reform has been a CBAI Federal Policy Priorities (FPP) since housing GSE were placed into conservatorship. CBAI stated in its 2017 FPP:
- “As it considers reforms to the housing GSEs, Congress should recognize that community banks and our economy need the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable. Fannie and Freddie may not survive in their current form; however, the financial crisis demonstrated the need for some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress.”
CBAI supports the Independent Community Bankers of America’s (ICBA) Principles for GSE Reform which include the following:
- The GSEs must be allowed to rebuild their capital buffers.
- Lenders should have competitive, equal, direct access on a single loan basis.
- The GSEs must be adequately capitalized, liquid, and reliable enough to effectively serve the entire mortgage industry in all markets, at all times, including challenging economic circumstances.
- Credit risk transfers must meet targeted economic returns.
- An explicit government guarantee on GSE MBS is needed.
- The TBA market for GSE MBS must be preserved.
- Strong oversight from a single regulator will promote sound operation.
- Originators must have the option to retain servicing, and servicing fees must be reasonable.
- Complexity of structure and operations should not force consolidation.
- GSE assets (automated underwriting technology, loan delivery portals, Common Securitization Platform, and multi-family housing businesses) must not be sold or transferred to the private market.
- The purpose and activities of the GSEs should be appropriately limited and must be focused on supporting residential and multifamily housing. They must not be allowed to compete with originators at the retail level, where they would enjoy an unfair advantage.
- GSE shareholder rights must be upheld.
CBAI appreciated the opportunity to provide input during Congressman Hultgren’s roundtable discussion on these important issues and looks forward to working with Congress and the agencies as GSE reform measures progress through legislation.
September 20, 2017
In a comment letter dated August 28, 2017, CBAI again urged the OCC, FDIC and the Federal Reserve (Agencies) to provide meaningful Call Report regulatory relief for community banks. CBAI’s letter was in response to the Agencies proposed revisions primarily related to deleting or consolidating items, raising certain thresholds, and reducing the reporting frequency for several items. However, these changes will impact only 7% of Call Report data items. This is certainly not meaningful regulatory relief for community banks and the Agencies were urged to do significantly more.
In addition, CBAI urged the Agencies to increase the asset exemption threshold for Eligible Institutions to a minimum of $10 billion so that all community banks will be eligible for Call Report relief. Finally, CBAI urged the Agencies to implement a true short-form or streamlined Call Report which would be available to well-capitalized and highly-rated community banks for the first and third quarters of the year and that this Call Report should consist only of a simple the balance sheet, income statement, and changes in capital. Read Comment Letter.
ICBA released a customizable letter community banks can use to inform their customers about the Equifax data breach. The template, which community banks can update with their identifying information, discusses the extent of the breach, where consumers can go for additional resources and tips for protecting their identity. The letter makes clear that community banks were not compromised but want to help customers following the unprecedented breach.