Our Position

Agencies and Regulators

Letters to Congress and Regulators

Title	Recipient	Date
Joint Letter to House on True Lender	House of Representatives	05/24/21
Joint Letter Opposing Proposal on Bank Premises	OCC	03/23/21
Letter on FHA Condo Recommendations	HUD	03/11/21
ICBA Letter in Support of Yellen Nomination	Committee on Finance	01/15/21
ICBA Response to 1071 Outline Proposal	CFPB	12/14/20
ICBA FedNow Comment Letter	Fed	09/10/20
COVID-19 Recommendations for Regulation D	Federal Reserve	03/24/20
RFI on a Framework for Analyzing the Effects of FDIC Regulatory Actions	FDIC	01/24/20
Comments on Small Bank Assessment Credits	FDIC	09/29/19
Community Reinvestment Act – Opportunity for Modernization	OCC	09/25/19
Letter to Chairman McWilliams on Part 363 Regulations	FDIC	09/16/19
Support for Innovation Competition Proposal	FDIC	08/26/19
Support for Fed Real-Time Gross Settlement Service	Federal Reserve	07/24/19
Comments on Potential Changes to Federal Reserve Settlement Services	Federal Reserve	07/16/19
Support for Fed Operating Real-Time Gross Settlement Service	Federal Reserve	06/27/19
ICBA Letter Supporting Miki Bowman Renomination	Senate Banking Committee	06/04/19
Regulation D: Reserve Requirements of Depository Institutions	Federal Reserve	05/09/19
ICBA Letter Supporting Renomination of Miki Bowman for Fed Board	White House, Senate Banking Committee	01/30/19
ICBA Comment on Opportunity Zone Guidance	Internal Revenue Service	01/02/19
Response to Request for Information on Communication and Transparency	FDIC	12/04/18
Letter on LIBOR Fallback Contract Language	Alternative Reference Rate Committee	11/13/18
Comment Letter on Small Bank and Savings and Loan Holding Company Policy Statement Interim Final Rule	Federal Reserve	10/29/18
Comment Letter on FDIC Proposed Rulemaking Regarding Reciprocal Deposit Treatment	FDIC	10/26/18
Comment Letter on Disparate Impact	HUD	08/20/18
Hurricane Harvey Relief Recommendations	FDIC, Federal Reserve, OCC, Department of Treasury	08/29/17
Proposed Changes to Credit Union Field-of-Membership Rules	National Credit Union Administration	12/10/16
Supporting Responsible Innovation in the Federal Banking System: An OCC Perspective	OCC	05/31/16