Advocacy

Technology

ICBA IT Outsourcing
Pre-Decisioning Questionnaire

Is your bank contemplating a new project to obtain strategic IT capabilities? Don’t know where to start? Weighing the pros and cons of IT outsourcing can be stressful.

Use this interactive quiz to evaluate your bank’s unique circumstances, the risks and regulatory requirements, and balance these considerations against the advantages of outsourcing your key IT capabilities.

Additional information is available in the IT Outsourcing white paper.

Take the quiz

Publications

Core Processor Resource Guide

Resource Guide

A community bank’s core processor should be a strategic partner that supports the bank’s long-term business objectives.

The ICBA Core Processor Resource Guide will help community banks with some of the more important aspects of managing this relationship to maximize the return on their technology investments.

Is your bank contemplating a new project to obtain strategic IT capabilities? Don’t know where to start? Visit our technology advocacy page for useful resources and documents.

FREE for members
Members Only Webinar

Optimizing Your Core Processor Relationship

Learn how to better optimize your core processor relationship with this member-exclusive webinar recorded April 14, 2021.

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Letters

Title Recipient Date
Comment Intake—LP Payment Apps Rulemaking Consumer Protection Financial Bureau 01/09/24
ICBA comment on OMB proposed AI memo Office of Management and Budget 12/05/23
Joint Letter on Aggregation Services Market CFPB 08/02/22
Comments on Fed Accounts Supplemental Proposal Federal Reserve Board 04/22/22
Joint Letter Supporting the Close the ILC Loophole Act House Financial Services Committee 04/05/22
Support for Senate CBDC, FedAccount Bill Sens. Cruz, Braun, Grassley 04/04/22
Support for House CBDC, FedAccount Bill Rep. Tom Emmer 04/04/22
Comments on DOJ Bank Merger Analysis DOJ 02/15/22
Comments on Beneficial Ownership Rule FinCEN 02/08/22
Comment Letter on Big Tech Platforms CFPB 12/06/21
Basel Cryptoasset Comment Letter Basel Committee on Banking Supervision 09/10/21
Extension Request for Proposed Third-Party Guidance FDIC, Fed, OCC 07/30/21
Comment Letter to FDIC on Digital Assets FDIC 07/15/21
ICBA Interagency Artificial Intelligence-Machine Learning RFI Comment Letter OCC, Fed, FDIC, CFPB, NCUA 07/14/21
Joint Comments on Fed Accounts Proposal Fed 07/12/21
House SECURE Support Letter - Coalition Reps. Madeleine Dean and Kelly Armstrong 06/11/21
Joint Letter to House on True Lender House of Representatives 05/24/21
Joint Trades Letter Opposing SJ Res 15 True Lender 117th Congress 05/06/21
Requst to Extend AI Request for Information FDIC, OCC, Fed, CFPB, NCUA 04/22/21
Letter to Agency Innovation Offices CFPB, FDIC, Fed, OCC 03/08/21
Response to First Blockchain Bank & Trust, N.A.'s Application for National Bank Charter OCC 03/02/21
Joint Letter on OCC Interpretative Letter 1176 OCC 02/12/21
Joint Letter on OCC Trust Charter Applications OCC 01/08/21
Comments on Convertible Virtual Currency Requirements FinCEN 01/04/21
Comment Letter to the OCC concerning Figure Bank OCC 12/07/20
Joint Request for Charter Comment Period Extensions OCC 11/20/20
Hill Payments Charter Letter 116th Congress 10/15/20
Comment Letter Regarding Application of Kraken Financial for Access to Federal Reserve System Services Fed 10/05/20
Hill Payments Charter Letter 9.29 U.S. House Task Force on Financial Technology 09/29/20
ICBA Response to FDIC Request for Information FDIC 09/22/20
Advance Notice of Proposed Rulemaking OCC 08/04/20
Joint Industry Letter Regarding COVID Calls FCC 05/22/20
ICBAs Ex Parte Regarding CG Docket No. 02-278 FCC 04/20/20
ABA Joint Trades Petition Emergency Purposes Exception FCC 03/31/20

Senate Finance chair questions crypto exchanges following FTX failure

Nov. 30, 2022

Washington continued to escalate its response to instability in the crypto sector as the Senate Finance Committee’s chairman questioned leading crypto exchanges on their consumer protections.

Consumer Focus: Sen. Ron Wyden (D-Ore.) sent letters to Binance, Bitfinex, Coinbase, Gemini, Kraken, and KuCoin asking whether the exchanges provide any protections for customers if they fail. With Congress considering how to regulate the crypto industry, Wyden said he will focus “on the clear need for consumer protections” along the lines of those available at banks and other regulated institutions.

BlockFi Bankruptcy: The letters came a day after crypto lender BlockFi filed for Chapter 11 bankruptcy protection in the latest fallout from FTX's collapse earlier this month. BlockFi said its largest creditors include FTX, which provided the lender a $400 million line of credit in June following the collapse of the TerraUSD stablecoin.

FTX Meltdown: FTX filed for bankruptcy earlier this month as a run on the crypto exchange—and reportedly a series of hacks—depleted its holdings. The Securities and Exchange Commission and the Commodity Futures Trading Commission are reportedly investigating FTX, which caretaker CEO John Ray has said suffered from a complete failure of corporate controls and absence of trustworthy financial information.

ICBA Op-ed: Following the collapse of FTX, policymakers should ensure new policies directed at the crypto sector fully reflect its risks, ICBA President and CEO Rebeca Romero Rainey wrote in a recent op-ed on Medium. Romero Rainey said the ongoing crypto failures validate what community banks have long warned—the crypto sector is fragile, prone to facilitating financial crime, entirely lacking in the protections available in the banking system, and ultimately a poor alternative to banking locally.

Committee Activity: The Senate Agriculture Committee is scheduled to meet tomorrow for a hearing on the FTX collapse and the congressional response. The House Financial Services Committee has said it will host its first FTX hearing on Dec. 13, and the Senate Banking Committee has said it also intends to hold hearings.

Testimony

Title Committee Presenter Date
Enhanced Regulation of Digital Assets Will Promote Responsible Innovation Senate Banking Hearing 02/15/22
Statement for Senate Stablecoin Hearing Senate Banking Committee Written Statement 12/14/21
Statement for House Hearing on Digital Assets House Financial Services Committee Written statement 12/07/21
ICBA Statement for True Lender Hearing Committee on Banking, Housing and Urban Affairs ICBA 04/28/21
ICBA Statement for HFSC Fintech Hearing 9-29-2020 HSFC 09/29/20
Hearing: Examining the Fintech Landscape Senate Banking, Housing, and Urban Affairs Committee Written Statement 09/12/17