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.
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.
|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|
March 22, 2023
ICBA called on the Financial Crimes Enforcement Network to modify its proposed form for collecting beneficial ownership information from reporting companies.
Background: Reporting companies subject to FinCEN’s September 2022 final rule must report identifying information about their beneficial owners, the company applicant, and the entity itself directly to FinCEN.
ICBA Comments: In a comment letter, ICBA said:
It opposes the requirement that banks collect beneficial ownership information, or BOI, but supports ensuring banks have access to this information collected by FinCEN.
While bank access to BOI would enhance their customer due diligence process, FinCEN’s proposed form for collecting such information is problematic.
FinCEN’s proposed form would allow reporting companies to skip providing required information in 29 places on the form, including for reporting full legal names, birthdays, and addresses, allowing companies to evade reporting requirements.
FinCEN should remove all 29 “check if you are not able to obtain” references from the reporting form.
Requiring financial institutions to collect all required BOI without exception while allowing reporting companies to skip these requirements would be wholly prejudicial.
FinCEN should not require banks to “chase down” missing BOI to assist FinCEN in fulfilling its CTA obligations.
Previous Comments: In letters to FinCEN on beneficial ownership reporting and the agency’s broader Bank Secrecy Act review, ICBA called on the agency to withdraw bank beneficial ownership collection and verification requirements now that it is required to collect this information directly from reporting companies.
|ICBA Summary of CFPB Proposals on No-Action Letters and Product Sandboxes||01/15/19|
|ICBA Guidelines for Responding to ADA Demand Letters (Members Only)||11/18/16|
|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|