ICBA encouraged the OCC to rescind its proposal to require national banks over $2.5 billion in assets to complete an Information Collection Survey to establish benchmarks for its 2020 Community Reinvestment Act rule.

In a comment letter, ICBA said the survey would be a significant regulatory burden for many community banks, requiring them to collect and report data that does not currently exist.

ICBA encouraged the OCC to instead resume discussions with the FDIC and Federal Reserve to develop a uniform CRA rule.