Independent consultant and EGRPRA czar needed to quantify regulatory burden

Press Release: Washington, D.C. (May 6, 2024)—The Independent Community Bankers of America (ICBA) today called on federal regulators to take meaningful action to address excessive regulatory burdens on community banks under the agencies’ latest review under the Economic Growth and Regulatory Paperwork Reduction Act, or EGRPRA.

“Consolidation within the industry, acquisitions of community banks by credit unions, and a small number of de novo bank applications are symptoms of the underlying problem: that the cumulative impact of regulatory burden on community banks is overwhelming the industry, and causing long-term damage to the communities that depend on these vitally important local resources,” ICBA Executive Vice President and Senior Regulatory Counsel Christopher Cole wrote.

In comments to the agencies, ICBA said the agencies should:

  • Take this new EGRPRA review much more seriously because of the exponential growth of community bank regulatory burdens and the little substantive relief provided by previous reviews.

  • Hire an independent outside consultant to quantify the current regulatory burden on community banks because previous reviews have shown the agencies cannot objectively evaluate the burden of their own regulations.

  • Hold at least two livestreamed outreach meetings in every region of the country and invite community banks to participate.

  • Set up an website as they have done previously to publish comment letters, post notices and outreach meeting resources, and list the regulations that bankers mention the most as being outdated, unnecessary, and unduly burdensome.

  • Designate an overall director of the current EGRPRA interagency review process who could overcome the objections of individual agencies to specific recommendations and resolve interagency disputes.

  • Conduct a thorough review of past regulatory assessments under the Paperwork Reduction Act of 1995 and the Regulatory Flexibility Act, which have consistently understated the regulatory burden of new regulation on community banks.

  • Simplify the call report, streamline the de novo bank applications, update the Small Bank Holding Company Policy Statement, and expedite procedures under the Bank Merger Act under its review of Applications and Reporting and Powers and Activities regulations, the first of four requests for comment under the current review.

ICBA’s complete comments are available on the ICBA website.

About ICBA
The Independent Community Bankers of America® has one mission: to create and promote an environment where community banks flourish. We power the potential of the nation’s community banks through effective advocacy, education, and innovation.

As local and trusted sources of credit, America’s community banks leverage their relationship-based business model and innovative offerings to channel deposits into the neighborhoods they serve, creating jobs, fostering economic prosperity, and fueling their customers’ financial goals and dreams. For more information, visit ICBA’s website at