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On behalf of the Independent Community Bankers of America (ICBA)1, I write to express our concerns about your April 10 proposed rulemaking titled Micro-Captive Listed Transactions and Micro-Captive Transactions of Interest.
As written, the proposal would make community bank captive insurance arrangements unworkable and thereby expose banks to unreasonable, uninsured risk. We urge Treasury and the IRS to revise the proposal with a view toward narrowly targeting abuses while preserving legitimate captive insurance arrangements.