Letters and Testimony

ICBA members and staff regularly communicate with Congress and regulators on behalf of the community bank industry.

Letters to Congress Letters to Regulators

Top Letter

The Independent Community Bankers of America (“ICBA”) commends the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board and the Office of the Comptroller of the Currency (the “Banking Agencies”) for their efforts to mitigate the strain placed on community banks as a result of the global COVID-19 pandemic. 

For instance, the Banking Agencies’ interim final rule issued last December to allow banking organizations with under $10 billion in assets to use asset data as of December 31, 2019 to determine the applicability of various regulatory asset thresholds greatly assisted community banks that participated in the Small Business Administration Paycheck Protection Program (PPP).

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Letters

Title Recipient Date
Brainerd Savings and Loan Acquisition Letter OCC 05/11/21
ICBA Statement for Tax Gap Hearing 5-11-2021 05/11/21
Joint Trades Letter Title VIII of HR 2547 117th Congress 05/11/21
Joint Trades Statement for the Record Senate Finance Subcommitte Hearing on Closing the Tax Gap Senate Finance Subcommitte 05/10/21
ICBA CFPB Servicing Letter CFPB 05/10/21
NCUA Simplification of Risk Based Capital Requirements NCUA 05/10/21
Joint Trades Letter Opposing SJ Res 15 True Lender 117th Congress 05/06/21
ICBA-ANPRM CTA Beneficial Ownership Rule Comment Letter FINCEN 05/05/21
Joint Letter on Withdrawing CRA Rule OCC 05/03/21
Requst to Extend AI Request for Information FDIC, OCC, Fed, CFPB, NCUA 04/22/21
Opposition to Assembly Bill 1177 California Legislature 04/21/21
ICBA Request for Extension of ECIP Application Deadline Treasury Department 04/20/21
Support for Promoting Access to Capital in Underbanked Communities Act Rep. Andy Barr 04/19/21
Comments on FHFA Climate Risk Management RFI FHFA 04/19/21
ICBA Letter in Support of SAFE Banking Act, HR 1996 U.S. House of Representatives 04/16/21
ICBA Statement For HFSC Charter Hearing 4.15.21 117th Congress 04/14/21
Comment Letter on Amendments to Rules Concerning Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) CFPB 04/13/21
ICBA Comment Letter on Incident Notification Requirements OCC, FDIC 04/13/21
ICBA Letter in Support of Dilawar Syed Committee on Small Business & Entrepreneurship 04/12/21
Letter to USDA on SDA Loan Payoffs USDA 04/09/21

Testimony

Title Committee Presenter Date
ICBA Statement for True Lender Hearing Committee on Banking, Housing and Urban Affairs ICBA 04/28/21
ICBA to Congress Don't Leave PPP Applicants Stranded House Small Business Committee Alice P. Frazier 03/10/21
ICBA Statement for HFSC Fintech Hearing 9-29-2020 HSFC 09/29/20
ICBA Statement for PPP Hearing 9-25-2020 House Committee on Small Business Subcommittee on Economic Growth, Tax, and Capital Access ICBA 09/25/20
Paycheck Protection Program: The Need for Simplified Forgiveness (6/17) House Small Business Committee Written statement 06/16/20