Federal Government Relations
CBA Federal Government Relations
Welcome to the CBA Federal Government Relations section, where you’ll find the latest information on federal banking legislation. In addition, you can find information about federal legislative alerts. Much of the information on this page is available to members only.
ACTION ALERT: Contact Congress, Urge Approval of Additional PPP Funds
As of today, April 16, the SBA has announced that the $349
billion authorized by the CARES Act for Paycheck Protection
Program (PPP) loans has been exhausted. Accordingly, the SBA will
no longer accept applications for PPP loans. Loan applications
received by banks but not yet submitted to SBA will not be able
to be completed, and we understand that the SBA will not maintain
a queue for PPP applications should additional funds be
authorized.
CBA Submits CRA Modernization Comment Letter
CBA submitted comments this week to The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation on a proposed rule to modernize the Community Reinvestment Act. The proposed rule focuses on improvement in the areas of qualifying activities, assessment areas, performance standards, and data collection.
We also have worked with the American Bankers Association (ABA) on a joint comment letter regarding the proposed regulations.
Comments on Community Reinvestment Act Modernization Due April 8
The Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation have proposed a rule on modernizing the Community Reinvestment Act. The proposed rule focuses on improvement in the areas of qualifying activities, assessment areas, performance standards, and data collection. The proposed rule can be reviewed here.
CFPB finalizes policy statement regarding “Abusive” Practices under UDAAP
Last Friday, CFPB issued a policy statement clarifying what constitutes “abusive” conduct for purposes of supervision and enforcement under Unfair Deceptive or Abusive Acts or Practices as compared to conduct that is unfair or deceptive. The policy is effective immediately. In determining whether an act or practice is “abusive” under UDAAP, the CFPB will consider whether the harm outweighs the benefits to consumers. In addition, the CFPB will generally avoid alleging that an act or practice that meets the unfairness or deceptive standard would also trigger a violatio
Ask Your Lawmaker to Co-Sponsor Important Legislation to Delay the Implementation of CECL
TAKE ACTION!
The Financial Accounting Standard Board’s new Current Expected Credit Loss standard poses significant operational challenges for the banking industry. CECL, which goes into effect January 2020 for some banks and later for others, will change the economics of lending and the unintended consequences are likely to result in changes to credit availability, product mix and cost of credit, particularly for consumers and small businesses. CECL will change the way your bank accounts for credit/loan losses.
New Report Finds Credit Unions Operate with ‘Scant Regard’ for Statutory Mission
On the eve of the 85th anniversary of the Federal Credit Union Act’s enactment, new research released today found that credit unions are falling short of their mission to serve households of “small means.” In fact, according to the research by respected analyst Karen Shaw Petrou, credit union members are disproportionately from middle- and upper-income households, and credit unions’ lack of “mission compliance” deepens U.S. economic inequality.
Joint Visit to Washington, D.C. with the Florida Bankers Association
September 17-19, 2019
The California Bankers Association (CBA) Federal Government Relations Committee invites you to join your peers at the 16th annual Joint Visit to Washington, D.C. with the Florida Bankers Association. We will be staying at the Omni Shoreham Hotel. This annual trip to our nation’s capital provides us with an excellent opportunity to discuss critical issues impacting our industry with our elected officials and representatives from key regulatory agencies.
Resource Available at the Federal Reserve Bank of San Francisco to Assist with Fintech
Do you need help navigating the regulatory and supervisory system in support of your business model or involvement with financial technologies? SF Fed Navigate fintech analysts can assist.
Their goal is simple: to help facilitate responsible innovations while protecting consumers and ensuring the safety and soundness of banks. SF Fed Navigate fintech analysts are available to help answer questions from fintech companies and banks to build an understanding of the financial regulatory environment so innovative ideas thrive.
Annual Visit to Washington, D.C.
June 4-6, 2019
The California Bankers Association (CBA) Federal Government Relations Committee invites you to join your peers for CBA’s Annual Washington, D.C. Visit, June 4 –6, 2019. We will be staying at the Grand Hyatt Hotel. This visit is a great opportunity to discuss critical issues that impact banking with members of California’s congressional delegation and officials from the various regulatory agencies.
Reminder: Comments on Volcker Rule Exception for Qualifying Community Banks Due April 9
The financial regulatory agencies have issued a proposed rule to implement a section of S.2155 that grants an exemption from the Volcker rule for community banks that meet certain qualifications; for instance, banks that have $10 billion or less in total consolidated assets as well as trading assets and liabilities of 5 percent or less of total consolidated assets.
Federal Reserve Seeks Comments on Faster Payment System
The Federal Reserve is considering the creation of the first new payment system in more than 40 years and it is important for your bank to be heard. The Federal Reserve issued a Request for Comment on whether it should consider creating a new, faster settlement infrastructure to support real time payments in the United States. The Fed seeks comment on the benefits of it creating a new Real Time Gross Settlement System (RTGS) that would operate 24/7/365 enabling payments to clear and settle on a real time basis at any time.
ACTION NEEDED! Community Reinvestment Act Reform and Modernization: OCC Request for Public Comment
On August 28, 2018, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) concerning modernization of the Community Reinvestment Act (CRA). CRA modernization can become a reality, but achieving it requires the involvement of as many financial institutions as possible. The first step is to comment on the ANPR. The ANPR can be reviewed here.
FDIC Seeks Comment on the Treatment of Reciprocal Deposits
The FDIC is seeking comment on a proposed rule to implement an amendment to the Federal Deposit Insurance Act (FDIA) that would exempt certain reciprocal deposits from being considered brokered deposits. The amendment to the FDIA was one of the provisions of S.2155.
Comments on the proposed rule are due on or before October 26, 2018.
California Bankers Sign Letter to CFPB Regarding TRID Disclosure
On July 3, the ABA sent a letter, co-signed by several California bankers, to Consumer Financial Protection Bureau Director Mick Mulvaney, urging the bureau for regulatory relief from rules affecting residential construction lending. Specifically, the letter requests immediate action to exempt residential construction-only loans from the TRID disclosure regulation.
The California Bankers Association Applauds Senate Passage of Bipartisan Regulatory Reform Legislation
SACRAMENTO, Calif. – On a strong bipartisan
vote, the U.S. Senate approved 67-31, S. 2155, the Economic
Growth, Regulatory Relief and Consumer Protection Act. The bill,
which will now advance to the House, is designed to right-size
banking regulations to allow banks to better serve their
customers and their communities, while maintaining appropriate
safety and soundness controls.
Treasury Releases Report Suggesting Significant Reforms to Banking Regulations
The U.S. Treasury Department has officially issued its 150-page report, making several recommendations for how Congress and the regulatory agencies can streamline bank regulation in a way that promotes economic growth.
CBA Responds to CFPB’s Request for Information on Mortgage Market Dynamics
In response to a request made by representatives from the Consumer Financial Protection Bureau (CFPB) during a recent meeting with CBA’s president and CEO, Simone Lagomarsino, we have shared with the bureau information providing evidence of the shifting marketplace dynamics relative to residential mortgage loan origination and mortgage servicing. The CFPB requested that we share additional data identifying the marketplace trends.
CECL Resources Now Available
The Financial Accounting Standards Board has just issued its new loan loss accounting framework, also known as the current expected credit loss (CECL) model. The new standard is expected to increase the allowance for loan and lease losses throughout the industry. CECL will require significant operational changes at all banks, including collecting and analyzing the type of data that supports the modeling of the life-of-loan loss expectation, as well as forecasting and quantifying losses in the future.
Action Needed on NCUA Attempt to Expand Credit Union Membership
This past November the National Credit Union Administration (NCUA) put out a proposal for comment regarding field of membership. This proposal, by NCUA’s own account, is the most sweeping change on membership limitations in the agency’s 45-year history and goes to the basic ability of credit unions to get new customers in the door.
CBA Supports Sen. Shelby’s Regulatory Relief Bill
The CBA joined the ABA and state bankers associations as signatories on a letter supporting Senator Richard Shelby’s “Financial Regulatory Improvement Act of 2015.” The associations noted that the ability of our nation’s financial institutions to support the needs of the economy has been limited by regulatory impediments that both restrict the flexibility to serve those needs and tie up substantial internal resources on unnecessary co