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


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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Title Recipient Date
CFPB 08/02/22
Federal Reserve Board 04/22/22
House Financial Services Committee 04/05/22
Sens. Cruz, Braun, Grassley 04/04/22
Rep. Tom Emmer 04/04/22
DOJ 02/15/22
FinCEN 02/08/22
CFPB 12/06/21
Basel Committee on Banking Supervision 09/10/21
FDIC, Fed, OCC 07/30/21
FDIC 07/15/21
OCC, Fed, FDIC, CFPB, NCUA 07/14/21
Fed 07/12/21
Reps. Madeleine Dean and Kelly Armstrong 06/11/21
House of Representatives 05/24/21
117th Congress 05/06/21
FDIC, OCC, Fed, CFPB, NCUA 04/22/21
CFPB, FDIC, Fed, OCC 03/08/21
OCC 03/02/21
OCC 02/12/21
OCC 01/08/21
FinCEN 01/04/21
OCC 12/07/20
OCC 11/20/20
116th Congress 10/15/20
Fed 10/05/20
U.S. House Task Force on Financial Technology 09/29/20
FDIC 09/22/20
OCC 08/04/20
FCC 05/22/20
FCC 04/20/20
FCC 03/31/20

ICBA urges FinCEN to modify proposed beneficial owner reporting form

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.


Title Committee Presenter Date
Senate Banking Hearing 02/15/22
Senate Banking Committee Written Statement 12/14/21
House Financial Services Committee Written statement 12/07/21
Committee on Banking, Housing and Urban Affairs ICBA 04/28/21
HSFC 09/29/20
Senate Banking, Housing, and Urban Affairs Committee Written Statement 09/12/17