Federal Reserve Governor Michelle Bowman reiterated her concerns with the community bank impact of regulators’ Community Reinvestment Act final rule and other recent agency actions.

Key Concerns: Speaking in Florida following similar remarks in Ohio, Bowman said:

  • The CRA rule applies the same regulatory expectations for small banks as it does for the largest banks.

  • The Fed’s proposed rule to lower the maximum interchange fee that covered debit card issuers may receive for debit card transactions would continue to affect a broader range of issuers, including community banks.

  • Interagency climate risk principles for institutions with at least $100 billion in assets could trickle down to smaller institutions.

ICBA View: ICBA has expressed concerns with:

  • The CRA rule’s disproportionate implementation costs for community banks.

  • The interchange proposal’s impact on smaller card issuers, including those intended to be exempt from the proposal.

  • Language in the climate principles describing all financial institutions and their potential application to community banks.