Finer Points Blog

    ICBA Convention Recognizes America’s Financial Foundation

    Mar 29, 2011
    Last week several thousand community bankers met in San Diego at the national convention of the Independent Community Bankers of America. It is always a reminder to me of the honor and privilege it is to represent the interests of these fine people here in Washington, D.C. They never forget who they are or the relationship banking model they follow. They are the financial foundation of our great country, because they lay that foundation, brick by brick, community by community every day. We here at ICBA are proud to say we represent community bankers exclusively.

    Community bankers are the men and women of Main Street America. We are the backbone of this nation’s entrepreneurial spirit. We are the engines of change, prosperity and jobs in America. We are the fabric of which the American Dream is made. We are community banks. We are ICBA.

    Love is in the Air for Community Banks

    Mar 08, 2011
    I’m not one for schmaltzy dramas. For those of you who don’t know, I’m more likely to take in a movie with scenes from Gettysburg or Omaha Beach. But this past Valentine’s Day, ICBA got downright sentimental with a marketing campaign that allows community bank customers to express why they love their community bank.

    ICBA’s “I Love My Community Bank” campaign allows customers and small businesses to share their experiences with their community banks. On the “I Love My Community Bank” website, consumers can post comments, photos and video testimonials about their community banking experiences. A special Twitter handle (@iLuvMyCB) will highlight the entries.

    The nation’s community bankers have earned a sterling reputation for outstanding customer service, smart banking policies and commitment to their communities. At ICBA, we’re just happy to help community bank customers spread the love.

    ICBA Convention on Pace for Banner Year

    Feb 23, 2011
    When I was still running my community bank in Missouri, it was always important to me to find a way to get away for a week in March to attend ICBA’s National Convention and Techworld. The annual convention offers community bankers an opportunity to come together for the largest community banking event in the world.

    This year, on the heels of a crippling financial crisis, a relentless battle over Wall Street reform and now new regulatory battles, it is more important than ever for community bankers to gather among their own to network, gain perspective and just enjoy the camaraderie of their fellow community bankers. Everyone needs to get away and among “family” from time to time. And ICBA is a family.

    The 2011 ICBA National Convention and Techworld is on pace to break registration records. Scheduled for March 20-24 in San Diego, this year’s convention will again feature top industry speakers, nationally known leaders and valuable educational workshops. The number of registrations to date is a testament to the value of ICBA’s convention and the resilience and spirit of community bankers.

    This industry has been through a lot these past few years, and I look forward to seeing as many community bankers as possible in what promises to be a great week in San Diego.

    Will you be there? I certainly hope so.

    Stop Punishing Main Street Banks and Their Customers

    Feb 17, 2011
    Hey, here’s an idea. Let’s punish the thousands of small community banks that played by the rules and stuck by their customers during the financial crisis by making it impossible for them to issue debit cards to their customers!

    The terribly flawed and misguided debit interchange rule proposed by the Federal Reserve to implement the Durbin interchange amendment to the Dodd-Frank Act will do just that. Millions of good Main Street customers of community banks will see their debit transaction costs rise. Or worse, they will not even be able to get a debit card from their local bank if this boneheaded rule, which will line the pockets of the big-box retail stores with billions in profits, is implemented. Write the Federal Reserve and your congressional delegation and tell them that Main Street community banks and their customers should not have to pay to pump up the profits of the big-box retailers. Make your voice heard—don’t subsidize the profits of the mega-retailers!

    If Congress and the Fed thought they could get this harmful interchange plan through without a fight, they should think again.

    “Wall Street: Money Never Sleeps,” and Neither Does ICBA

    Feb 09, 2011
    Usually the time I spend on a plane is a way to lose myself in a book, reflect, catch up on work or perhaps enjoy a movie. On a recent trip, the in-flight movie was Wall Street: Money Never Sleeps.

    Watching this movie was like reliving the past few years of my life dealing with the financial crisis. I lived through several of those meetings referred to or shown in the movie. I knew those players from Wall Street and the government officials (formerly from Wall Street) portrayed in the movie—and I remember what I was doing during the meetings and who said what.

    I am proud to say that ICBA made a strong and positive difference for community banks during the darkest days of the crisis. And I agree with the movie's "Godfather," the now-wrinkled prophet of Wall Street, Gordon Gekko, when he says in a speech to business students that the greed of Wall Street leading up to the crisis was the “greatest transfer of money from Main Street to Wall Street [in the nation's history], and it’s going to happen again.”

    Another observation Gekko makes is that “right now it’s ugly times ugly, and that's when the ugly get going.”

    We can all learn from the observations of Mr. Gekko. See the movie and learn what really happened and how and who really triggered the worst financial crisis in generations.

    Big Day for Community Banks: Finally Assessment Parity!

    Feb 07, 2011
    It’s been years coming. Some said it would never happen, some laughed at our attempts and some heaped scorn on us for even trying. But ICBA and the community banking industry’s long quest for parity in deposit-insurance assessments became a reality today.

    The FDIC board of directors approved a final plan to base deposit-insurance assessments on total assets minus tangible capital instead of domestic deposits. ICBA has long advocated for this change, which will bolster the FDIC Deposit Insurance Fund and lower premiums for most community banks.

    ICBA and the nation’s community bank fought an uphill battle for deposit-insurance fairness against fierce opposition, and we prevailed. Today’s FDIC vote shows that  by fighting for what is fair for the community banking industry, ICBA and its member banks can achieve results that will have a significant positive impact on your bank for years to come.

    Regulatory Review Must Deliver Results

    Jan 25, 2011
    It sounds like a step in the right direction. President Obama recently ordered federal agencies and departments to review regulations and to consider ways to reduce the regulatory burden on small businesses. For community banks drowning in a sea of regulations and struggling under the excessively harsh regulatory environment, this is good news. But as former Rep. Willard Duncan Vandiver (1897-1903) from my home state famously quipped: “I am from Missouri. You have got to show me.”

    In other words, prove it.

    ICBA and the nation’s community bankers have led a high-profile campaign to address the regulatory burden on our industry. In meetings and public hearings, policymakers have voiced sympathy and echoed our concerns, yet the burdens remain.

    The White House initiative to address excessive regulation is a positive development, but we need to see real results. As the regulatory review proceeds, ICBA will continue working with policymakers to ensure that our concerns are addressed and that the president’s plan has a positive impact on the nation’s community banks.

    ICBA United to Work with Divided Congress

    Jan 04, 2011
    Congress will have a new look when it returns to Washington this week. With a Republican House and Democratic Senate following November’s elections, many pundits have predicted a return to gridlock on Capitol Hill in 2011.

    While a split Congress will surely face new challenges in reaching consensus on various issues, I believe our nation often works best under a split government. Divided government has resulted in some of our nation’s greatest accomplishments and frequently has tempered the push for undesirable policies, as laws tend to be more balanced and moderate when both parties are forced to come together.

    We do not yet know how Congress will proceed in 2011, but we do know that ICBA will be there every step of the way vigorously advocating on behalf of the nation’s community banks. The association looks forward to continuing to work with both parties on a variety of issues critical to the community banking industry. And something upon which we can all agree is that ICBA is never divided in its singular mission to promote and advance the interests of Main Street America’s community banks.

    Recalling the Harsh Lessons of the Past

    Dec 21, 2010
    More than three years ago I wrote the following article on the dangers of uncontrolled competition and overconcentration in the financial markets. Having witnessed the financial crisis that unfolded shortly after this article was written, I thought I’d republish it again today as a matter of interest and, well, fact. Happy holidays to all and best wishes in 2011.

    Uncontrolled Competition and Financial PanicsThen and Now”

    It is said that human nature never changes. A favorite quote of mine is Voltaire’s maxim that “history never repeats itself; man always does.” In 483 A.D., the Emperor Zeno directed Constantinople’s Praetorian Prefect that “no one may presume to exercise a monopoly of any kind.”  In more modern times, the famed British philosopher Benjamin Kidd argued in Social Evolution that laissez-faire might be appropriate in one stage of a nation’s life but not necessarily in following stages.  In the landmark 1902 case Northern Securities v. U.S., United States Attorney General Philander Knox argued, “Uncontrolled competition, like unregulated liberty, is not really free.” Today, Knox’s words ring especially true as we now know the cost of “uncontrolled competition.”

    The U. S. Congress passed the Sherman Act for good reason.  By the early 1890s, unrestrained competition had created a group of financial oligopolies that threatened to undue the very fabric of our nation’s economic system.  A decade later, President Theodore Roosevelt directed his attorney general to bring suit against the three most powerful businessmen of his time—James J. Hill, J. Pierpont Morgan and E. H. Harriman—because he feared the nation’s consumers and economy were in peril from the dangerous over-concentration of financial and economic assets.

    And just five years after the Roosevelt administration sued to break up the Northern Securities monopoly, the nation’s financial system collapsed and the Panic of 1907 ensued, in large part due to the overwhelming concentration of financial assets in a handful of Wall Street banks and brokerage houses run by the most powerful “money men” of their day. A generation later, our nation’s financial and economic marketplace suffered again from the dangerous overconcentration of financial assets in the hands of a few highly interconnected Wall Street financial houses. The result was The Great Depression.

    How long does it take for our collective public consciousness to fade?  Few memories remain of the financial and commercial combinations that spawned the Great Depression. As the consolidation of financial system assets accelerated over the past 10 years, the “Wall Street elite” and their think tanks and allied associations put forth the same old arguments made by earlier titans of Wall Street—greater efficiency, greater value to society, easier for the consumer and greater international stature. Any person or groups expressing doubts or concerns about more and more assets in fewer and fewer hands were labeled as “backward thinkers” or “stuck in the past looking backward”—just as had been the case a century earlier. Some financial groups even said that “too big to fail” did not exist and could never happen in today’s sophisticated financial world. Similar statements preceded earlier financial panics.

    In recent times, opponents of overwhelming financial concentration have warned repeatedly of the catastrophic cost of unrestrained concentration. In both 1907 and 2007, the voices of caution were ignored, and the cost of dismissing these voices was a financial panic. The financial and economic collapse struck the nation like a thunder clap and shook the very foundations of our economy and free enterprise system. Like those of times past, now a new generation of financial elites have experienced the end result of unrestrained financial asset concentration. Wall Street has witnessed the destructive power that is unleashed by the creation of massive business combinations—financial oligopolies—that hold taxpayers and consumers captive to management business decisions, no matter how misguided, greedy or destructive.

    Teddy Roosevelt had the courage to act on his beliefs and worked to restore equilibrium to our nation’s economic system. It took the Panic of 1907 to put an exclamation point on his efforts—and to create the Federal Reserve System. Now, a century later, the current financial and economic crisis has again painfully revealed the true price of unrestrained financial and economic concentration—at a ruinous cost to the nation’s taxpayers and to our cherished private enterprise system.

    Now it is up to us to either recall the harsh lessons of the past, or continue to relive them. Let us hope that the current administration and Congress have the same courage to restore equilibrium to our financial and economic system by unwinding these unwieldy, unmanageable and “unable to regulate” financial beasts as did Teddy Roosevelt and the Congress of his time. If we do not, future taxpayers, consumers and small businesses will be devoured by these insatiable beasts that to this day still roam on Broad and Wall Streets.

    Deal on Tax Extenders Could Offer Holiday Cheer

    Dec 07, 2010
    Bipartisanship can be hard to come by in Washington, but there are encouraging signs that Congress and the administration have heard the voice of reason when it comes to extending important tax measures that are set to expire. Democratic and Republican leaders have announced a tentative compromise that would extend the 2001 and 2003 tax cuts for two years to ensure American small businesses and families do not face a tax increase in the middle of the current economic downturn.

    Throughout the debate, the community banking industry has done its part. ICBA and the nation’s community bankers have urged Congress to vote to extend current income tax rates across the board and address the estate tax and other expiring tax measures by the end of the year. In addition to ICBA’s Washington advocacy, countless community bankers have used ICBA’s customizable letter and tax information to make their voices heard in Congress.

    While we need to learn more about the deal, the prospect for a compromise that avoids tax hikes offers a little more cheer this holiday season. However, Congress still must debate and act on any final agreement, so ICBA will continue working closely with lawmakers to ensure that the current promise for a deal is not a humbug.

    Overdraft Guidance No Holiday Treat, or The Death of Common Sense

    Nov 29, 2010
    Happy holidays, folks. In case you missed it, on the day before Thanksgiving, the FDIC released final guidance on overdraft-protection programs that institutes new regulatory burdens and doesn’t include a single recommendation from the community banking industry. Further, by threatening to shutter overdraft programs that were created at the urging of consumers in the first place, the agency’s guidelines are against the best interests of community bank customers. Talk about the nanny state gone wild. This is an Orwellian nightmare.

    Following the Federal Reserve’s enactment this year of overdraft rules for debit-card and ATM transactions, the FDIC guidance requires banks to monitor programs for excessive customer use and to contact in person or by telephone customers who have incurred six overdrafts over a rolling 12-month period to discuss other alternatives. Additionally, the guidance encourages financial institutions to allow consumers to opt out of coverage for checks and ACH transactions and to impose daily fee limits. Much to my chagrin, the guidance does not explicitly exempt ad hoc overdraft payment programs, a service provided by community banks nationwide, as requested by ICBA.

    Two days after the guidance was out—and as most Americans hit their local shopping malls or recovered from too much turkey and stuffing—The Wall Street Journal reported that three-quarters of bank customers are opting in to debit-card overdraft programs under the Federal Reserve guidelines. It is the latest study showing that consumers want overdraft protection. Requiring recurring customer contact will be regarded by most of these customers as harassment: the first call may be appreciated, but repeated calls will be poorly received and may force some of the neediest customers back into the shadow banking world. And then there are the state laws that must be reconciled with the FDIC rules—what a mess. As usual, well-meaning community bankers and their customers are caught in the crossfire.

    The bottom line is this: Banks began offering overdraft protection to meet customer demand. And now the government is getting in between a product the customer wants (and in many cases needs) and the bank.

    As ICBA continues meeting with the FDIC on this issue, we will work to ensure the new rules do not overburden community banks and threaten a product their customers want and need.

    A Sea Change

    Nov 09, 2010
    Acting Comptroller of the Currency John Walsh called it a “sea change.” He’s right. Today the FDIC board of directors voted to base assessments on assets minus tangible capital instead of domestic deposits, which will level the playing field and lower premiums for community banks. After years of prodding by ICBA and the nation’s community bankers, policymakers will ensure that the largest banks pay their fair share of deposit-insurance premiums.

    Meanwhile, requiring these institutions to cover the risks they pose to the Deposit Insurance Fund will mean lower premiums for community banks for years to come—an estimated $4.5 billion over the next three years alone. That certainly isn’t pocket change.

    With financial institutions across the nation on edge about what financial regulatory reforms will mean for them, community banks can take comfort that this change will have a positive impact on their bottom line. It will allow community banks to reinvest their savings in their neighborhoods, strengthening Main Street communities across the nation. This change will do all of us a lot of good.

    We the People

    Nov 02, 2010
    We the People go to the polls today to engage in our sacred, inalienable right. The outcome of today’s midterm congressional elections will select the citizens who will come to Washington to lead our federal government for the next two years.

    Of course, Congress and all of Washington, D.C., are bracing for yet another political sea change from today’s elections. The anger and anxiety over our country’s economic troubles and the memories of the Wall Street financial crisis and bailouts are as fresh as ever. And this bumpy political ride isn’t likely to end with this year’s elections. Governing on Capitol Hill could get harder before it gets easier. So hold on to your chads.

    Does this landscape of shifting political power in Washington make it more difficult for ICBA to represent the nation’s community banks? No, it doesn’t.

    ICBA will always engage and educate any public official, regardless of his or her party affiliation, on community banking issues. Whoever the American voters elect to office will be the people ICBA works with in good faith for community banks and for Main Street America.

    That doesn’t mean ICBA will shy away from vigorously opposing proposals or ideas that are harmful to community banks. We won’t. Our longstanding advocacy record demonstrates that. Whatever judgments American voters make in this midterm election, or in any election for that matter, ICBA will work alongside our members, our leadership bankers and our state and regional association partners to advance and promote the community banking industry.

    So let the voters decide. Let our great, tumultuous democracy reign. And after the ballots are counted, ICBA will be united and ready to move forward to achieve the best public policies that the American people want.

    FDIC Long-Term Plan Offers Short-Term Relief

    Oct 27, 2010
    At a time when good news is hard to come by in the financial services industry, or anywhere for that matter, the FDIC’s recently proposed Deposit Insurance Fund management plan can be met with some relief. First of all, the FDIC plan would forgo the 3-basis-point increase in assessment rates scheduled for Jan. 1, 2011, which is expected to save the industry billions of dollars. Second, the agency said it is abandoning the increase largely because it has reduced its projected losses for the DIF. So far, so good.

    These provisions are part of a long-term plan that significantly restructures how the FDIC funds the DIF, and this is where things get a little more complex. The FDIC will not provide dividends to banks when the reserve ratio tops 1.5 percent, as it is authorized to do. Instead, it plans to gradually lower assessments to keep the reserve ratio well above its statutory minimum.

    In other words, community banks may never again see a DIF dividend, and they certainly will not experience a decade of not paying assessments, as the industry did from 1996 to 2006. However, with a positive fund balance and predictable assessment rates, community banks are less likely to face special assessments to replenish the fund when they can least afford it.

    Short-term relief from scheduled assessments and a countercyclical approach to funding the DIF that will benefit banks during economic downturns is downright good news. Further, with the FDIC expected to release its rule on ICBA-advocated changes to the assessment base next month, we even have something to look forward to.

    A Robo-Sign of the Times

    Oct 25, 2010
    The so-called Masters of the Universe are at it again. Some of the same large financial institutions that caused the financial crisis have engaged in practices that could ultimately stunt the economic recovery. Several mega-institutions’ questionable foreclosure practices, such as “robo-signing” foreclosure documents, have made front-page news and have led to foreclosure moratoriums at several firms and an investigation by all 50 state attorneys general.

    However, the danger of the documentation flap is not likely to be to the borrowers involved, as there have been no reports of homeowners being wrongly foreclosed on because of paperwork errors. Rather, the true threat is the call from consumer activists for a national moratorium on foreclosures.

    A mandatory moratorium could wreck the mortgage market and jeopardize the economic recovery. Fortunately, the White House, regulators, members of Congress and leading commentators on the right and left have voiced their opposition.

    Community bankers do what the mortgage factories should have done all along—work directly with borrowers. Because of this, community banks generally haven’t experienced a spike in foreclosures. Nevertheless, we all would be negatively affected by a moratorium. Once again, the irresponsible practices of the nation’s largest financial firms are imperiling our financial and housing systems.

    Credit Unions Having Their Cake and Eating it Too

    Sep 30, 2010
    It’s official: The nation’s credit unions get to have their tax-exempt cake and eat it too!

    Federal regulators last Friday afternoon announced a multi-billion-dollar bailout of the credit union industry due to risky bets on subprime mortgages. Regulators will manage $50 billion in troubled assets and issue approximately $35 billion in taxpayer-backed bonds. In other words, a financial industry that has never paid a dime in federal taxes is enjoying a taxpayer-funded rescue because of their risky and overreaching lending practices.

    Under the plan, regulators seized the three largest wholesale credit unions and introduced new restrictions to try to avoid risky practices at credit unions—the same regulators that were urging Congress to expand the lending powers of credit unions!! Well, that sure seems a day late and about $35 billion short.

    ICBA has long called on Congress to reconsider the tax-exempt status of the nation’s credit unions. A 2005 Tax Foundation study found that the exemption is costing taxpayers more than $30 billion over 10 years. Last Friday afternoon, that tab just about doubled. With spiraling budget deficits, maybe this bailout is enough to get Congress to finally act to ensure that the rest of us don’t have to take a bite of what the credit union industry is cooking up.

    The Big Short: Inside the Doomsday Machine

    Sep 28, 2010
    If you want to know who and what really triggered the financial chaos and calamity through which we all have just lived, a must read is The Big Short by Michael Lewis.

    If you are a true community banker, this book will make your blood boil. The arrogance and greed that Lewis exposes on the part of many “elites” on Wall Street will leave you shaking your head and fist. If nothing else, read the book’s epilogue. It will open your eyes, or, as the saying goes, “The truth will set you free.” And when you are done, you will know exactly why the community banking industry needs an independent, focused voice. Why we need ICBA.

    Persistence Pays Off on Small Business Jobs Act

    Sep 23, 2010
    The long and winding road of passing legislation to stimulate the small-business sector came to a successful end this week as the House voted to send the Small Business Jobs Act (H.R. 5297) to the president. ICBA worked closely with Congress to pass the legislation since the introduction of the $30 billion Small Business Lending Fund. With the help of the nation’s community banks and ICBA’s affiliated state and regional community banking associations, we succeeded in seeing this thing through.

    While the $30 billion fund dedicated to expanding small-business lending has been the most high-profile provision in this bill, there are other important measures as well. The law extends Recovery Act provisions that increase government guarantees on Small Business Administration loans and reduce borrower fees, permanently increases loan limits on SBA loans and expands the SBA’s trade and export finance programs. It also provides $12 billion in targeted tax cuts for the nation’s small businesses.

    After a series of fits and starts and continued partisan wrangling threatened to derail this common-sense legislation, it was the persistence of ICBA and the nation’s community banks that made the difference. Even as Congress has its eyes on November, with many incumbents fearing for their political lives, lawmakers were able to rally around Main Street thanks in no small part to the reputation and resilience of the nation’s community banks.

    Ben Franklin said that energy and persistence conquer all things. Fortunately for the small-business sector and our economic recovery, ICBA and community bankers don’t quit.

    What do the opportunities offered by this legislation mean for your community bank?

    Wanted: Sanity in the Exam Environment

    Sep 21, 2010
    Albert Einstein defined insanity as doing the same thing over and over again and expecting a different result. Given that definition, to many observers ICBA’s constant calls for more reasonable and balanced field examinations for community banks might appear insane. After numerous and repeated private meetings and public testimony in Washington on this crucial issue over the past three years, community bankers continue to face an overly stringent regulatory environment even as policymakers plead with community banks to boost lending to consumers and businesses.

    The current environment hinders the ability of community banks to make loans, which ties up funding that could stimulate the economy. While bank regulators in Washington keep assuring us that they are working to have examiners take a reasonable and consistent approach, community bankers are experiencing something very different in the field and are feeling the consequences of unreasonably harsh exams. With mixed messages such as these, community bankers should be excused for questioning the regulators’ sanity.

    All of Washington needs to listen up on this issue—and quickly. As policymakers grapple with a sputtering economic recovery, rigid examiner practices are contributing to a contraction of credit. Einstein also said that the only things that are infinite are the universe and human stupidity, and he wasn’t so sure about the universe. We need a smarter approach to bank exams if we want to keep the fragile economic recovery from reversing course. It doesn’t take an Einstein to figure that out. In a fair exam environment, community banks can give small businesses the loans they need and help America get back to work.

    Reputations Intact: Proud To Be a Community Banker

    Sep 14, 2010
    One of the sad facts of this modern world in which we live is that we are bombarded with "messaging" nearly 24 hours a day. Our senses are overwhelmed with information. We’re on overload—and our memories are very short. And so it is with this most recent financial meltdown.

    In the fall of 2007, as the credit markets on Wall Street were going into vapor lock and mortgage-backed securities and the subprime loans that backed them were cratering, the politicians, policymakers and consumer advocates in Washington and around the nation were all screaming that everyday Americans and the economy were suffering because of the "greed" and “overreach” of the “bankers.” All fingers were pointing at “bankers.” It was the bankers’ fault, they said. All bankers were equally culpable in the eyes of the nation.

    During those very dark days, I got scores and scores of e-mails (some days several hundred) from community bankers nationwide imploring ICBA to draw a bright line of distinction between community banks and the nonbank financial firms and the mega Wall Street financial firms with their off-balance-sheet assets and so-called structured investment vehicles.

    “We are not those guys,” community bankers pointed out. “Make them understand,” they wrote. Community bankers raged about how it was not the little community banks that engaged in the avarice and recklessness that caused our nation's financial system and economy to melt down. Please, please, please, ICBA members pleaded, make the policymakers understand how and why community banks are different.

    ICBA did just that. And we were highly successful in doing so in several ways—from knocking back the FDIC’s 20-cent special assessment to leveling the playing field on deposit insurance premiums, to raising the insured deposit level by two and a half times, to bringing “too-big-to-fail” to heel. Most importantly, for the first time in financial history, ICBA convinced policymakers to create a legal bright line distinction between the business model of a community bank and the business model of a "systemically dangerous" Wall Street bank or nonbank financial firm.

    These are historic achievements. No longer will smaller, local community banks be saddled with the same regulatory regime as international behemoths such as Citi or Bank of America. For the first time in financial history policymakers recognize and have acted to affirm that “one size fits all” financial regulation is not appropriate and that regulators should calibrate the country’s banking rules to accommodate for complexity, risk and size.

    ICBA heard our members’ pleas for equity and to keep their hometown reputations intact, and ICBA responded with all our energy and achieved historic results for the community banking industry.