ICBA filed a comment letter with the OCC and FDIC in response to their proposal regarding unsafe or unsound practices and matters requiring attention. ICBA said it is supportive of the agencies’ efforts to bring greater transparency and accountability to the supervisory process and recommended:

• Clarifying definitions and standards for key concepts to provide a more consistent understanding of the terms. 
• Guarding against unintended constraints on matters requiring attention by maintaining the agencies' abilities to address emerging risks. 
• Ensuring consistency across among community bank supervision by coordinating with the Federal Reserve.