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Spring Government Relations Summit Page 3.
d) FAIR LENDING – The Equal Credit Opportunity Act and the Fair Housing Act should be
amended to require actual intention to discriminate rather than using the disparate impact
standard. Further, there have been abuses in the referrals of community banks for minor
infractions to the Justice Department. DFA language regarding federal banking agency referrals
to the Attorney General should be amended to replace “shall” with “may, where warranted”.
e) FCS OVER-REACH – It is important to prevent FCS from expanding its charter and further
exploiting its tax-advantage and GSE retail lending authority to compete unfairly with banks, in
light of the FCS’ loss of mission focus, the dire state of the U.S. government’s finances and
policymakers’ desire to make the tax code more equitable.
f) TAX REFORM – In reform of the tax code Congress needs to make sure all appropriate parties
are taxed, such as credit unions and the Farm Credit System, and that existing deductions are
maintained such as interest expense.
g) OTHER ISSUES
i) Remove the “Abusive” standard from UDAAP and return to UDAP
ii) Raise the automatic SIFI threshold from $50 billion
iii) Relieve banks that only take deposits and make loans from a 10% Tier 1 capital requirement;
it is too high
iv) Exempt community banks from Basel III requirements
v) Other – There are other important issues: appraisals, data breach, marijuana (few states),
overdraft, small dollar lending, defensive issues (mortgage interest deduction, bank cross-
selling practices…), GSE reform…
Banker quote: I’ve had a number of people tell me that our bank gave them their first loan, probably
when they didn’t deserve it. Today, they are business and civic leaders. I guess we made the right call
then. However, today we cannot make that call. Washington has already made that call, and the
answer is no.
ABA Blueprint for Growth, February 2017: Four Principles
Grow the Economy
A thriving economy depends on well-functioning financial markets as well as consumers and
businesses that can take advantage of them. More efficient regulation of banks and policies that make
credit and debt more manageable for borrowers can increase the ability for all parties to participate in
the credit cycle, generating economic growth and prosperity. Properly structured and comprehensive
tax reform will also provide further promotion of a growing economy.
Capital and liquidity. Free up bank capital to drive growth by minimizing overly burdensome and
unnecessarily complex capital, accounting and liquidity requirements.
Tailored regulation and arbitrary thresholds. Tailor regulation to correspond to business model and
risk, eliminate artificial regulatory asset thresholds and pursue a more balanced supervisory process
that eliminates drag on bankers’ ability to employ capital to support economic growth.