Page 2 - 2017 Spring Visit issue resources_Neat

Spring Government Relations Summit Page 2.

CBA PRIORITIES:
1) TAILOR ACT – To provide regulatory relief to as many banks as possible and maintain appropriate
regulation where needed, Congress needs to pass the TAILOR Act to tailor regulations to the
business model and risk profile of the bank. CBA was deeply involved in writing it; Rep. Scott
Tipton (CO-3) is its sponsor.

2) MORTGAGE LENDING – QM and ATR status should be conferred automatically for loans held in
portfolio; it is logical and essential to providing credit to various groups currently with constrained
access to credit. The high cost mortgage language and the balloon payment prohibitions in DFA
should be eliminated for banks restoring access to mortgage credit for many Coloradans. We
support mortgage cost disclosures but believe CFPB missed opportunities to truly reform these
disclosures: new forms remain lengthy and intimidating to average consumers and overly complex
and ambiguous calculations increase cost and liability for banks.

3A) – DURBIN AMENDMENT ON INTERCHANGE FEES – In lieu of repealing the unfair and
damaging Durbin repealed, we endorse a free market (requirement for multiple networks on a card
and the increased competition that produces), while anti-free market price setting by the Fed should
be repealed.

3B) – CFPB – CFPB needs major reform. We favor Congress requiring the CFPB to be subject to
Congressional appropriations and creating a board versus a single directorship, and returning the
enforcement of the 18 consumer protection and fair lending laws applicable to FDIC-insured
institutions to the prudential regulators. There are other options.

There are many other important issues (not prioritized since we will get what we can as opportunities
arise):
a) AML/BSA – Banks play an important role in the fight against terrorist financing, money
laundering, and other financial crimes. We support government efforts to track illegal financial
transactions, but banks should not be burdened with massive reporting of legitimate activity by
law-abiding people. FinCEN, federal bank regulators and law enforcement should administer
BSA by giving due deference to a bank's risk-based compliance judgments to use AML
resources wisely. Banks should report suspicious transactions but should not act as “deputized”
law enforcement agents on unusual or suspicious transactions.

b) DATA ON SMALL BUSINESS LENDING – Although not implemented yet, Sec. 1071 of DFA
essentially requires the equivalent of HMDA reporting for small business loans by amending the
Equal Credit Opportunity Act to require institutions to collect data about commercial loan
applicants, identifying whether the loan applicant is a small business, female-owned business or
minority-owned business. The ECOA already covers the area of concern. 1071 should be
repealed.

c) EXAM APPEAL/REFORM – Banks need a better avenue for appealing examination findings.
This issue is particularly important now, given the role of CAMELS ratings in risk-based deposit
insurance premium assessments.