Welcome to 2016, community bankers! We had a prolific year of advocacy in 2015, and I want to thank all of you for doing your part. ICBA is again primed and ready to hit the ground running in Washington on a number of fronts. But we can’t forget that diligence alone will not ensure another successful year. We must also be flexible and quick to respond to the constantly churning and evolving political realities of the nation’s capital.
That means not only actively working to advance long-standing ICBA initiatives, such as building on the common-sense regulatory relief we achieved last year, but also defending against new and dangerous threats to relationship banking and Main Street economies as they arise.
Take last year, for example. Sure enough, ICBA and community bankers achieved numerous significant victories by actively supporting pro-community bank policies. That means the Plan for Prosperity provisions eliminating redundant privacy notice requirements, extending the 18-month exam cycle, and allowing more banks to qualify as “rural” mortgage lenders under CFPB rules. It means mandated community bank representation on the Fed, call report reform, the cybersecurity information-sharing law, stricter capital standards on the riskiest megabanks, and tax relief for Subchapter S corporations. None of this could have been achieved without active community bank advocacy on behalf of established industry goals.
However, just as important is a forceful defense against the misguided policies that continue to crop up in Washington and elsewhere. Some of these we can anticipate year after year, including the persistent and oft-frustrated attempts by credit unions and the Farm Credit System to expand into commercial banking without facing the same regulatory and tax obligations. And some we’ve worked for years to moderate, including Basel III capital guidelines and the Financial Accounting Standards Board’s costly and burdensome standards update. But some bad ideas seem to come out of nowhere, such as last year’s Senate-passed plan to cut dividends on Federal Reserve Bank stock. Following vociferous ICBA opposition, Congress exempted community banks under $10 billion in assets, saving them an estimated $200 million per year. And lawmakers softened the blow on banks over $10 billion by providing a variable rate on Fed stock tied to the 10-year Treasury.
Sometimes the policies that didn’t pass are as important as those that are signed into law. Let’s not forget that our job as community bank advocates—whether by supporting pro-community bank measures or neutralizing hostile policies—is to promote an environment where community banks flourish. That is our mission. And after a busy and productive year, I am confident we can continue advancing that mission in 2016 and beyond.