CBAO LEGISLATIVE PRIORITIES

In concert with ICBA, CBAO is actively engaging our leaders on these current issues:

• Amending FCRA (Fair Credit Reporting Act) to address “Trigger Leads”
• FDIC Special Assessment - supporting the FDIC proposal to exempt community banks with uninsured deposits of less than $5 billion from a special assessment triggered by the failures of Silicon Valley Bank and Signature Bank. We estimate the ICBA advocated carveout will save community banks approximately $2.8 billion over two years.
• Durbin- Marshall Amendment Expansion Legislation - opposes legislation to create new credit card routing mandates, expanding on the Durbin Amendment’s interchange restrictions. While the Credit Card Competition Act (S. 1838 and H.R.
  3881) is designed to apply to banks with over $100 billion in assets, community banks would be forced to subsidize costly systemwide changes that would put customer data at risk.
• Congressional Challenge to 1071 Rule - supporting resolutions in the House and Senate (H.J.Res.85 and S.J.Res.32) that would use the Congressional Review Act to nullify the CFPB’s final rule under Dodd-Frank Section 1071. While the resolution faced a presidential veto, it will nevertheless help to highlight and advance community bank concerns with the final rule.
• Climate Risk Regulation - opposing proposals under consideration in the Administration, the agencies, and Congress to create new climate-risk mandates. Proposals include stress testing for the impact of weather events on bank-held assets, concentration limits, increased disclosures, and other mandates.
• Central Bank Digital Currency - oppose a U.S. CBDC which would compete with community bank deposits needed to fund local lending and undermine consumer privacy, among others.
• Crypto Assets and Decentralized Finance – Unregulated crypto assets, including stablecoins, as well as decentralized finance (DeFi), threaten to disintermediate community banks and heighten risks for the wider economy and must be brought within the regulatory perimeter. We strongly oppose efforts to grant nonbank stablecoin issuers access to the Federal Reserve master account and to license novel nonbank issuers not subject to the same regulation as community banks. We will continue to work with regulators, policymakers, and standards-setting bodies to address serious risks to financial stability, consumer protection, and community bank lending.
• Support for Agriculture – we are aggressively advocating for rural community bank priorities, recommending six key principles for a new Farm Bill, which is now in development. These priorities include ample funding for commodity programs, rural broadband, and crop insurance. We also advocate for higher USDA guaranteed loan limits, a USDA Express program (loan approval within three days of submission), and other program enhancements. We strongly opposes expansion of the Farm Credit System into non-farm lending activities.
• SBA Lending and Nonbank Fintechs - strongly oppose an SBA final rule that will allow nonbank fintechs to originate 7(a) loans thereby increasing fraud risk and defaults. ICBA is promoting legislation that would modify the SBA rule to address bankers’ concerns.