For Members
CBA State Issue Brief: The State of the Banking Industry
The U.S. banking system is safe, remains resilient and is on a solid foundation. The banking industry is well-capitalized, has strong liquidity, and is represented by banks of all sizes that serve every segment of the American economy.
CBA Submits Comment Letter on Definition of a Depository Institution
CBA has previously provided comments on this matter on January 22, 2019, and again on September 9, 2019. CBA strongly reiterates its position that subsidiaries, affiliates and entities otherwise related to depository institutions, which are engaged in the business of commercial lending under federal regulatory oversight should be exempted from application of the proposed regulations in the same manner that depository institutions are exempted.
CBA Submits Comment Letter on Brokered Deposits
Our letter provides comments on the proposed revisions to the Brokered Deposits Restrictions regulation promulgated by the Federal Deposit Insurance Corporation (FDIC).
While we are generally supportive of the efforts to modernize these regulations, we do believe that some aspects of the proposal should be clarified to avoid ambiguity and unintended consequences.
Click here to view our letter.
CBA Submits Public Bank Comment Letter to DBO
This week, CBA submitted its comment letter to the Department of Business Oversight regarding the proposed rulemaking relative to public banks.
Click here to read the letter.
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.
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.
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.
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.
Disaster Planning and Recovery Resources
The California Bankers Association has provided the following resources for disaster planning and business resumption:
Equifax Breach: Resources to Communicate with Your Customers
As the Equifax breach continues to dominate headlines, you may begin to get questions from your customers and the media. Here are a few resources you might find helpful as you decide how to communicate about the breach:
California Bankers Association Joins ABA Foundation’s Safe Banking for Seniors Campaign
SACRAMENTO – The California Bankers Association (CBA) is joining the American Bankers Association Foundation’s Safe Banking for Seniors campaign. Through this campaign, the CBA will mobilize bankers across California to educate older Americans and their caregivers about elder financial abuse and how to prevent it.
CBA Resources to Get Prepared for .bank Domain Name Availability
Thousands of new domains – including .bank – are making their way to the Internet. The American Bankers Association partnered with banking industry participants to establish fTLD Registry Services to operate .bank and ensure it is governed in the best interests of banks and their customers. Only verified members of the banking community will be able to register .bank domains.