Setting Goals


ICBA updates its policy priority resolutions for 2016

By Alan Keller

ICBA’s credibility and effectiveness in Washington rests on our ability to faithfully and accurately represent the interests of the nation’s more than 6,000 community banks in all their diversity—a diversity of charter types, business models, geographies, local economies and customer demographics.

How does ICBA meet that challenge? First, we are in daily contact with community bankers, discussing their concerns. In addition to these informal conversations, we conduct an annual review and update of our comprehensive policy resolutions and select from among these our priority resolutions—the front-burner issues that require constant vigilance.

The process of crafting these resolutions is led by community bankers for community banks, with the assistance of ICBA staff policy experts. It’s a democratic process designed to capture core principles and goals, as well as current issues before Congress and the agencies in which community banks have so much at stake.

ICBA has a dedicated Policy Development Committee which prepares a draft of the policy resolutions, and the final resolutions. The association’s board of directors reviews and approves the final resolutions at the annual convention.

But, really, the substance of the resolutions is informed by thousands of interactions between community bankers and ICBA staff in meetings of the standing committees, the Federal Delegate Board, councils and task forces, as well as through informal phone calls and conversations that occur throughout the year.

The association’s 2016 policy resolutions, a package of more than 49 resolutions spanning policymaking and educational and product-and-service member initiatives, were formally approved by ICBA’s board of directors at the Community Banking LIVE national convention in New Orleans in March.

The policy resolutions and their full explanations set clear goals to guide ICBA’s efforts as the only national trade association that exclusively represents the interests of community banks.

“ICBA’s advocacy priorities will continue to focus on common-sense policy reforms that will help ensure community banks can continue meeting the needs of local communities,” says ICBA Chairman Rebeca Romero Rainey, chairman and CEO of Centinel Bank of Taos, in Taos, N.M.

Here is a brief listing and summary of ICBA’s 14 legislative and regulatory policy priority resolutions for 2016. The complete set of the association’s resolutions, each accompanied by a background discussion, is available online at

Relief from crushing regulatory burden: Enact targeted regulatory relief via ICBA’s Plan for Prosperity platform to help community banks support the credit needs of their customers, serve their communities, and contribute to their local economies.

Mortgage lending reform: Reform Consumer Financial Protection Bureau mortgage rules to protect responsible loan products that meet consumers’ diverse needs.

Consumer Financial Protection Bureau: Support legislation that ensures accountability at the CFPB by replacing single-director governance with a five-member commission and promoting greater participation by the prudential banking regulators.

Data security and fraud: Advocate data security principles that deter retailer data breaches, such as requiring the costs to be borne by the party that incurs the breach and implementing robust processes like those already mandated for banks.

Cybersecurity: Balance voluntary cybersecurity information sharing with the need to secure customer information while ensuring that federal cybersecurity legislation, regulatory frameworks, or guidance recognize existing community bank mandates.

Current Expected Credit Loss model: Overhaul the Financial Accounting Standards Board’s costly and onerous Current Expected Credit Loss model and advocate a more workable alternative for community banks.

Fair lending: Call for consistent and transparent standards for evaluating community bank fair-lending practices and oppose any cause of action under the Fair Housing Act for disparate impact without a finding of intentional discrimination.

Payments systems access and governance: Support payment systems that are competitive, progressive, and secure and that offer fair and open access to all community banks so they can meet the evolving global payment needs of their customers.

Tax-exempt credit unions: Urge Congress to end the credit union industry’s unwarranted federal tax subsidy and oppose expanded powers for the industry as long as it remains exempt from taxation and the Community Reinvestment Act.

Tax-advantaged Farm Credit System: Urge Congress to abolish the Farm Credit System or, at minimum, restrict it to its historical mission of serving the agricultural marketplace.

“Pay-for” taxes and fees targeting the banking sector: Strongly oppose the recent trend of targeting the banking sector with revenue-raising measures, such as taxes and fees, to fund new government spending unrelated to banking.

Community bank access to capital: Support legislative and regulatory changes that would improve the ability of community banks to raise capital to meet the credit and banking needs of their local communities.

Tax policy: Advocate tax laws that promote robust economic activity and a vibrant community banking sector and foster saving and investment.

End Too-Big-To-Fail: Curb or end the advantages enjoyed by too-big-to-fail banks that have resulted in a financial system plagued by excessive concentration, systemic risk, moral hazard and distorted free markets.

Alan Keller ( is ICBA’s vice president for legislative policy.