COMMUNITY BANKER REPRESENTATION
- To ensure community bank views are considered by key policy bodies, ICBA supports the appointment and election of ICBA member bankers to public and private sector boards, advisory groups and task forces that influence the development of regulations and policies affecting the banking industry.
- ICBA supports the statutory requirement that at least one member of the Board of Governors of the Federal Reserve System have experience as a community banker or community bank regulator.
- ICBA strongly supports the existence of the FDIC’s Advisory Committee on Community Banking, the Federal Reserve’s Community Depository Institutions Advisory Council (and the Federal Reserve Banks’ similar local advisory councils), the CFPB’s Community Bank Advisory Council, the OCC’s Mutual Savings Association Advisory Committee and the OCC’s Minority Depository Institutions Advisory Committee. These councils and committees are important avenues through which community banks can provide the agencies with advice and recommendations on a broad range of policy issues that have particular impact on community banks and the communities they serve.
Community banker participation is essential to ensure community banking views are considered by a variety of key policy bodies. The statutory requirement that a member of the Board of Governors of the Federal Reserve System have experience as a community banker or community bank supervisor will help ensure that the policies and rules adopted by the Federal Reserve will take proper account of the unique role community banks play to support a vibrant small business sector and healthy rural communities.
Community banker representation on the Federal Reserve’s Federal Advisory Council is essential for the FAC’s deliberations to reflect the full range of interests of the banking industry. ICBA promotes the election of community bankers to the boards of the district Federal Reserve Banks and branches and the Federal Home Loan Banks. ICBA urges state community banker associations to actively recruit and support these nominees.
The FDIC’s Advisory Committee on Community Banking, composed of 15 community bankers from across the country, provides an important venue for the airing of community bank viewpoints, especially in the currently challenging regulatory environment. The committee fosters a dialogue between community banks and the FDIC on key policy issues that impact community banks and the communities they serve, including examination policies and procedures, credit and lending practices, deposit insurance assessments, regulatory compliance matters, and more.
The Federal Reserve Board’s Community Depository Institutions Advisory Council, composed of one community bank, thrift or credit union representative from each of the local advisory councils at the 12 Federal Reserve Banks, provides input to the Federal Reserve and the Reserve Banks on the economy, lending conditions and other issues. The CDIAC meets twice a year in Washington.
The OCC’s Mutual Savings Association Advisory Committee and its Minority Depository Institutions Advisory Committee help OCC meet the goals of addressing the needs and challenges of mutual savings associations, and of preserving and encouraging the creation of minority depository institutions.
The Consumer Financial Protection Bureau’s Community Bank Advisory Council is a vehicle for the community bank point of view to be aired and considered by the CFPB as it makes policy and writes regulations. The expertise of community bankers is needed to allow the CFPB to fully gauge the impact of consumer protection rules since they can be among the most burdensome. Unduly burdensome or costly consumer protection rules can result in smaller providers ceasing to make available desirable product offerings and exiting the market, thus reducing consumer choice.
Likewise, community banker participation is essential to ensure community banking views are considered by other key policy bodies such as Federal Home Loan Bank boards of directors, NACHA-The Electronic Payments Association, the Bank Secrecy Act Advisory Group, the Financial Accounting Standards Advisory Council, the FASB Small Business Advisory Committee, the Financial Services Sector Coordinating Council and the Financial Services Information Sharing and Analysis Center, and special task forces.
Staff Contact: Karen Thomas