Keeping community banking interests front and center
By Courtney Schoenborn
With congressional candidates and incumbents across the nation in full campaign mode this summer, this is an excellent opportunity to share how ICBA is affecting what is already a dramatic election season. Here’s an outline of the key activities ICBA’s advocacy team in Washington, D.C., is focusing on to make sure that community banking issues are front and center come this November:
- Ensure that candidates and incumbent members of Congress have a keen understanding of the crucial issues affecting community banks, such as the crushing weight of burdensome regulations and the expansion of tax-advantaged credit unions and Farm Credit System lenders. Once a lawmaker or candidate who understands the important role of community banking is identified, ICBA’s advocacy team makes sure we can provide the critical funds needed to help support his or her election efforts.
- Rally more than 3,000 community bankers each year who support ICBPAC, ICBA’s federal political action committee for community banking. That’s a lot of voices united behind the common goal of electing and reelecting federal lawmakers who understand the issues facing our industry.
- Support those who support us. With more than $1.4 million disbursed to federal election campaigns by
ICBPAC so far this election cycle, ICBPAC has supported more than 290 candidates and committees.
- Meet with dozens of candidates from across the country and attend hundreds of events in Washington and in congressional districts so that we can get to know these important decision makers. Attending these events helps drive home the importance of a vibrant community banking sector and lets lawmakers know that community bankers want to work with them when the 115th Congress kicks off in January.
ICBA’s Plan for Prosperity is a legislative platform to provide targeted, practical regulatory relief for community banks for the 114th Congress. As a package of legislation with more than 30 provisions, the plan is a set of specific, detailed legislative priorities positioned for advancement in Congress.
The Plan for Prosperity is a flexible, living document that can be adapted to a rapidly changing regulatory and legislative environment to maximize its influence and likelihood of enactment. Although many provisions directly seek to relieve unnecessary regulatory burdens, some of the plan’s provisions are specifically designed to create new options for community banks to raise and preserve vital institutional capital.
Four provisions in the plan were signed into law in 2015. Its remaining provisions are best represented by the House and Senate versions of the CLEAR Relief Act (H.R. 1233 and S. 812) and the Community Bank Access to Capital Act (H.R. 1523 and S. 1816). The Financial Regulatory Improvement Act, S. 1484, which passed the Senate Banking Committee in May, includes a number of provisions from the plan.
ICBA is committed to advancing and enacting the provisions of the Plan for Prosperity with all due vigilance and the aggressive use of every resource at our disposal.
For more information, visit www.icba.org/advocacy.
Be Heard Website
To help community bankers get involved and stay informed in advocacy issues, ICBA developed the grassroots advocacy Be Heard website as a member’s primary source for community bank advocacy information and resources.
For more information, visit www.icba.org/beheard.
Washington Policy Summit
Every spring ICBA holds its Washington Policy Summit where hundreds of community bankers from across the country visit with their congressional members and with federal regulators. Any community banker is welcome and encouraged to attend. The next summit takes place April 30–May 3, 2017.
The Independent Community Bankers Political Action Committee is the nonpartisan political action committee of the ICBA. ICBPAC is the only federal PAC dedicated exclusively to representing the community banking industry.
For more information, visit www.icba.org/icbpac.
Recent ICBA Legislative and Regulatory Successes
Accounting rules. Following a multiyear advocacy campaign, ICBA and community banks won significant changes in a newly revised draft of the Financial Accounting Standards Board’s current expected credit loss model. The revised draft will allow community banks to rely on their judgment, knowledge of local economic conditions and currently used systems and tools.
Regulatory relief and crop insurance funding. In December, President Obama signed a highway bill into law, which includes four significant community bank regulatory relief provisions. Those include an 18-month exam cycle for CAMELS 1 and 2 banks with assets of less than $1 billion; expanded access to “rural lender” status under Ability to Repay mortgage rules; stopping annual privacy notice mailings for banks that have not changed their privacy policies; and new SEC registration and deregistration thresholds for thrift holding companies.
Expanded rural lender benefits. A statutory change at year-end 2015 gave the Consumer Financial Protection Bureau discretion to expand access to “rural lender” benefits for “small creditors” (with less than $2 billion in assets that originate fewer than 2,000 mortgages, excluding portfolio loans) by eliminating the requirement that a small creditor lend predominantly in rural areas to qualify. Rural lender benefits now include qualified mortgage status for balloon loans held in portfolio and an exemption from escrow requirements on higher-priced mortgages. The CFPB responded by allowing small creditors that originate a single loan per year in a rural area to qualify as rural lenders.
Dividends on Federal Reserve stock. As a direct result of ICBA advocacy, Congress eliminated a higher guarantee fee provision for loans sold to Fannie Mae and Freddie Mac, and exempted banks with assets of less than $10 billion from a steep Federal Reserve dividend cut.
FDIC Assessment Rules. Responding to ICBA’s advocacy, the FDIC scrapped the core deposit ratio for determining deposit insurance assessments of banks with assets less than $10 billion, substituting the brokered deposit ratio. Reciprocal deposits remain treated as core deposits. Only brokered deposits in excess of 10 percent of total assets will impact assessment rates.
FHLBanks membership test. The Federal Housing Finance Agency withdrew a proposed rule that would have imposed an ongoing mortgage assets test for member banks of the Federal Home Loan Bank System.
Call report simplification. In response to ICBA advocacy, including a petition with nearly 15,000 signatures, the Federal Financial Institutions Examination Council proposes to simplify the call report and to evaluate the creation of a streamlined call report for community banks.
Cyberthreat legislation. In December, President Obama signed into law the Cybersecurity Act of 2015, permitting the federal government and private sector entities, including community banks, to share cyberthreat information.
Fair lending ruling. In March, the U.S. Supreme Court upheld an ICBA-supported lower court ruling that found that spouses who guarantee bank loans cannot bring discrimination claims against creditors under the Equal Credit Opportunity Act.
De novo formations. In April, the FDIC decided to reduce from seven to three years the period of heightened supervisory monitoring of newly formed banks.
Information reporting mandate. ICBA led a successful effort to strip onerous new reporting mandates from a trade bill that would have required new reporting mandates on accounts that pay less than $10 in interest-bearing and on noninterest-bearing accounts.
Federal Reserve Board representation. In January 2015, President Obama signed legislation requiring that at least one member of the Federal Reserve Board have experience as a community banker or a community bank supervisor.
Courtney Schoenborn (email@example.com) is ICBA’s vice president, political programs.