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Bowman reiterates CRA, interchange, climate concerns


Federal Reserve Governor Michelle Bowman reiterated her concerns with the community bank impact of regulators’ Community Reinvestment Act final rule and other recent agency actions.

November 13, 2023 / By ICBA

Federal Reserve Governor Michelle Bowman reiterated her concerns with the community bank impact of regulators’ Community Reinvestment Act final rule and other recent agency actions.

Key Concerns: Speaking in Florida following similar remarks in Ohio, Bowman said:

  • The CRA rule applies the same regulatory expectations for small banks as it does for the largest banks.

  • The Fed’s proposed rule to lower the maximum interchange fee that covered debit card issuers may receive for debit card transactions would continue to affect a broader range of issuers, including community banks.

  • Interagency climate risk principles for institutions with at least $100 billion in assets could trickle down to smaller institutions.

ICBA View: ICBA has expressed concerns with:

  • The CRA rule’s disproportionate implementation costs for community banks.

  • The interchange proposal’s impact on smaller card issuers, including those intended to be exempt from the proposal.

  • Language in the climate principles describing all financial institutions and their potential application to community banks.

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