Independent Banker - December 2018 - 39

S.2155 includes numerous policies from ICBA's Plan
for Prosperity, including provisions offering " qualified
mortgage " relief, simplifying capital requirements, implementing
Volcker Rule and escrow exemptions, expanding
access to the 18-month exam cycle and authorizing a shortform
call report. It also provides relief for larger community
banks, such as eased stress testing and risk committee
requirements. These gains came on top of the significant
tax relief contained in the Tax Cuts and Jobs Act finalized
at the end of 2017.
While ICBA continues to encourage regulators to quickly
implement the outstanding provisions of S.2155, the
agencies have issued guidance or regulations on many policies.
Relief from the Home Mortgage Disclosure Act and
TILA-RESPA Integrated Disclosure rule, reciprocal deposit
reform and more have already advanced. A comprehensive
tracker on the implementation of S.2155 and an interactive
timeline on its passage are available at icba.org/s2155
Sustainable environment
The steady implementation of S.2155 is due in no small part
to the improved regulatory environment. New regulators,
such as Joseph Otting at the Office of the Comptroller of
the Currency (OCC), Jelena McWilliams at FDIC and Mick
Mulvaney at the Consumer Financial Protection Bureau
(CFPB), have worked to instill a culture of transparency and
accountability at their agencies.
Michelle " Miki " Bowman will prove a valuable presence
on the Federal Reserve Board as she fills the ICBA-advocated
position dedicated to individuals with experience in
community banking. Bowman is uniquely qualified for the
role, with service as a Kansas state bank commissioner,
community banker, family farmer, and congressional and
agency staffer.
The improved environment has already led to tangible
pro-community bank reforms. Regulators this year eased
commercial real estate appraisal mandates, proposed phasing
in the day-one impact of the Current Expected Credit
Loss (CECL) accounting standard, reduced disclosure
requirements for publicly held community bank holding
companies and granted exceptive relief from beneficial
owner requirements.
Legislative loose ends
Meanwhile, Congress has not limited its pro-community
bank agenda to S.2155. Following testimony from Cynthia
Blankenship, vice chairman and COO of Bank of the West,
in January, Congress passed legislation over the summer
strengthening the Small Business Administration's 7(a) program.
The bipartisan Small Business 7(a) Lending Oversight
Reform Act stabilizes 7(a) program funding by allowing the
agency to lift the overall cap on general business lending by
up to 15 percent if the cap will be reached, as it was in 2015.
Congress also passed a resolution overturning the CFPB's
2013 guidance on indirect auto lending, which held certain
lenders that offer auto loans through dealerships responsible
for unlawful pricing.
Unfinished business
While 2018 was a banner year for community banks, much
advocacy work remains. For one, ICBA and several members
of Congress are calling on the Treasury Department
With 2019 arriving around
the corner, community
bankers can celebrate the
holidays knowing that we
gave it our all this year and
are reaping the benefits.
to revisit its proposed rule implementing the 20 percent
tax deduction for Subchapter S banks, which unreasonably
limits the deduction established by the Tax Cuts and
Jobs Act.
Among many other priorities, ICBA is working to:
Q support final passage of a five-year farm bill
Q oppose the credit union industry's expansionist agenda
and its plans to ease megabank capital rules
Q build on Nelnet's withdrawn industrial loan corporation
application to push for regulatory consistency at technology
companies
Q advocate a Federal Reserve role in faster payments
Q promote pro-community bank housing finance reform.
Meanwhile, initiatives to reform the Bank Secrecy Act and
Community Reinvestment Act, pass a legal safe harbor for
banking cannabis businesses and transition from LIBOR to
alternative reference rates require continued involvement.
With 2019 around the corner, community bankers can
celebrate the holidays knowing that we gave it our all this
year and are reaping the benefits. While much remains to
be done, we can be confident in our continued success following
a prolific and historic 2018.
independentbanker.org Q 39
http://www.icba.org/s2155 http://www.independentbanker.org
Independent Banker - December 2018

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