Our Position

Regulatory Capital


  • ICBA supports strong capital requirements for all banks and their respective holding companies. ICBA continues to support the community bank leverage ratio (CBLR) but does not support the 9 percent reporting threshold.
  • Basel III continues to be punitive and to inhibit lending for community banks that do not elect or do not qualify for the 9 percent CBLR. ICBA supports a full exemption from Basel III for non-systemically important financial institutions (non-SIFIs) or amendments as discussed in the background of this resolution.
  • Capital standards should not disadvantage community banks relative to credit unions or global systematically important banks (GSIBs).
  • Banking regulators should not impose liquidity coverage ratio restrictions on high-quality investment securities that would impact the liquidity of those securities for community banks. ICBA supports Congress’ efforts to expand the types of municipal securities that can be categorized as high-quality liquid assets when calculating a bank’s liquidity coverage ratio. ICBA also believes that Fannie Mae and Freddie Mac securities should qualify as high-quality liquid assets.
  • ICBA supports regulatory efforts to impose requirements for the largest banks to issue long-term debt instruments that can be used as tier 1 capital in order to allow for an orderly resolution of a failed institution.


Basel III. Regulators should reduce the CBLR to 8.5 percent to address the temporary but penalizing changes in community bank balance sheets caused by various pandemic stimulus programs. Regulators should also work toward a permanent 8 percent CBLR as a more practical alternative for community banks that execute a straightforward lending business model.

Recognition of ALLL Loss Absorption. FASB’s CECL accounting guidance clarifies that the allowance actually represents the first layer of the capital cushion to absorb bank losses. As such it should be included in tier 1 capital. Moreover, because the CECL accounting guidance requires the allocation of more capital to ALLL, it results in a larger omission from tier 1 regulatory capital calculations. ALLL should be included in tier 1 capital in an amount up to 1.25 percent of risk weighted assets, and the remaining balance of ALLL should qualify for inclusion in tier 2 capital.

Basel III Punishes Mortgage Servicing. The threshold deductions for mortgage servicing assets should be raised from 25 percent of common equity tier 1 capital to 50 percent of tier 1 capital. Additionally, for mortgage servicing assets that are not deducted, the risk weight should be restored to 100 percent from the overly punitive 250 percent.

High Quality Assets Must Be Recognized Under Liquidity Coverage Rules. ICBA believes that municipal debt as well as Fannie Mae and Freddie Mac mortgage-backed securities should be categorized as high-quality liquid assets, commensurate with their treatment in the capital markets, under liquidity coverage ratio rules.

Staff Contact

James Kendrick

First VP, Accounting and Capital Policy



Rob Birgfeld

EVP, Chief Marketing Officer