Washington, D.C. (March 23, 2021) — BPI, the American Bankers Association and the Independent Community Bankers of America sent a joint comment letter calling on the OCC to withdraw its Notice of Proposed Rulemaking on National Bank and Federal Savings Association Premises.
The proposal would abandon a flexible, principles-based approach to regulating what banks can do with their buildings, land and facilities that has worked well for decades, and instead adopt a bright-line, rules-based approach. The lack of flexibility in the proposal would diminish the ability of banks to adapt to the post-pandemic transformation of work and business environments as well as other changing circumstances in the future.
“In any case, as they consider changes to space needs and use, banks need flexibility to adapt to an uncertain future,” the groups said in the comment letter. “Implementing the Proposal now would interfere with banks’ ability to adapt to changing premises needs and arrangements in a post-pandemic working environment, detracting from their ability to hire competitively.”
About Bank Policy Institute.
The Bank Policy Institute (BPI) is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
About the American Bankers Association.
The American Bankers Association is the voice of the nation’s $21.1 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $17 trillion in deposits and extend nearly $11 trillion in loans.
About ICBA.
The Independent Community Bankers of America creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.
With nearly 50,000 locations nationwide, community banks constitute 99 percent of all banks, employ more than 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding more than $5 trillion in assets, over $4.4 trillion in deposits, and more than $3.4 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation, and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org.
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