EGRPRA AND REDUCING REGULATION ON COMMUNITY BANKS
- ICBA strongly supports the EGRPRA process and commends the agencies for holding six outreach meetings to gather feedback and input from bankers on ways to reduce regulatory burden. Many ICBA members have participated at the outreach meetings and have made many recommendations.
- Issues raised by community bankers include (1) call report reform and a community bank short form call report; (2) a two-year exam cycle for well-rated community banks; and (3) increasing many of the dollar or asset threshold requirements under the Bank Secrecy Act (BSA), the Community Reinvestment Act (CRA), and regulations governing mortgage lending. ICBA strongly supports all of these initiatives.
- ICBA encourages the banking agencies to implement the recommendations made by community bankers and by ICBA and where necessary to make recommendations for statutory changes. During the next EGRPRA process, the CFPB should be included in the process.
The banking agencies are conducting a two-year review of their regulations to identify outdated, unnecessary, or unduly burdensome regulation on insured depository institutions as required under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA).
ICBA and its members have been actively engaged in the current EGRPRA process and have made numerous recommendations for reducing regulatory burden including (1) call report reform and in particular a streamlined call report for community banks; (2) extending the current exam cycle to two years for well rated banks; (3) simplifying Basel III for community banks; (4) streamlining and updating Regulation O (loans to officers and directors); (5) increasing the exam cycle and the assets thresholds under the Community Reinvestment Act; and (6) increasing the dollar thresholds under the Bank Secrecy Act. We have also advocated for changes to Regulations D (reserve requirements), CC (funds availability), and S (reimbursement for providing financial records) as well as the Fair Credit Reporting Act and flood insurance regulations.
The banking agencies are required to submit their EGRPRA report to Congress in 2016. Already, they have begun to implement several changes including a review of community bank call reporting. ICBA looks forward to working with the banking agencies to implement many of the changes that ICBA and community bankers have recommended.
Staff Contact: Chris Cole