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ICBA is urging community bankers to sign a petition opposing harmful crop  insurance amendments that are expected to be offered when the full Senate considers its version of the farm bill next week.
The deadline to add names to the petition is close of business today, June 20.
Consistent with ICBA's farm bill infographic and "Focus on Farm Policy" white paper, the letter urges senators to oppose all harmful amendments to crop insurance, including those that would
reduce or limit participation, make insurance more expensive for farmers, or harm private-sector delivery.
The Senate Agriculture Committee voted 20-1 to pass the Agriculture Improvement Act of 2018 (S. 3042) last week.
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President Donald Trump formally nominated Kathy Kraninger of the Office of  Management and Budget to head the Bureau of Consumer Financial Protection. Kraninger, the OMB's program associate director for general government, would replace acting director Mick Mulvaney if confirmed by the Senate.
Before serving at the OMB, Kraninger worked for the Department of Homeland Security and the Senate Appropriations Committee. Mulvaney has served as the bureau's acting director since November 2017.
Kraninger's nomination comes at a key moment for the CFPB; under the Federal Vacancies Reform Act, Mulvaney's stint as acting director would have expired this month, but when a permanent replacement is nominated, the clock resets, allowing Mulvaney to remain as acting director until Kraninger is confirmed.
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The Federal Reserve should clarify that agency guidance and other statements  not issued via notice-and-comment rulemaking do not establish binding legal standards, Rep. Blaine Luetkemeyer (R-Mo.) said in a letter to Fed leadership yesterday. Luetkemeyer added that the Fed should make a "clear statement" that guidance should not be the basis for enforcement actions; supervisory directives, such as Matters Requiring Attention; or other supervisory determinations, such as ratings downgrades.
"Over the years, a significant number of agency guidance, handbooks and circulars have been issued," wrote Luetkemeyer, who chairs the House Financial Services Subcommittee on Financial Institutions and Consumer Credit. "Greater clarity around the appropriate use and interpretation of such guidance is of the u[t]most importance." Luetkemeyer also urged the Fed to ensure that its examiners are "appropriately educated about the use and role of guidance" and "held accountable when guidance is applied inappropriately."
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The Senate Agriculture Committee voted 20-1 to pass the Senate version of the  farm bill, the Agriculture Improvement Act of 2018 (S. 3042). ICBA applauded the panel and said the bipartisan vote sends a strong message to the full Senate to quickly adopt the measure.
ICBA said it welcomes the bill's provisions to maintain commodity price protections and a strong crop insurance program. ICBA also supports the bill's increase for guaranteed farm loan limits to $1.75 million, up from the current $1.39 million level, in addition to other important programs.
"The bipartisan vote keeps the process of enacting a new farm bill this year moving forward," ICBA President and CEO Rebeca Romero Rainey said. "Although there are still many challenges to enacting final legislation, ICBA will work with Congress on enacting a new farm bill in a timely manner."
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SeReps. Steve Pearce (R-N.M.) and Blaine Luetkemeyer (R-Mo.) introduced a bill  that would update several elements of the Bank Secrecy Act and other anti-money laundering laws and regulations. H.R. 6068 would raise the threshold for when Currency Transaction Reports must be filed from $10,000, where it was set by Congress nearly half a century ago, to $30,000, as well as increase the monetary threshold for Suspicious Activity Reports.
The bill would provide an 18-month enforcement safe harbor for financial institutions making good-faith efforts to comply with the recently effective customer due diligence rule. It would also facilitate SAR sharing with foreign bank affiliates, give the Treasury Department a more prominent role in coordinating AML policy and require studies of streamlining CTR and SAR reporting requirements and of the effectiveness of new beneficial ownership requirements.
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The Consumer Financial Protection Bureau (CFPB) and state regulators
 coordinate well together on supervision activities when they have overlapping jurisdiction, but there could be some improvements, CSBS said in a
comment letter.
In particular, CFPB should coordinate its exam schedule to finish near the same time as state exams, said CSBS in its letter.
The letter is in response to the CFPB's request for information on its supervision processes.
State regulators made additional recommendations, including suggesting that the CFPB:
- Limit its scope of formal appeals, which could clog the process if unduly expanded;
- Improve processes to streamline information sharing with the Bureau;
- Allow both the Bureau and the states to maintain their own oversight authority with respect to third-party service providers;
- Improve processes for the sharing of potential action and request for response letters, when possible; and
- Continue to recognize and promote the value of its Supervision and Exam manual.
This is the third comment letter CSBS has sent in the past month to the CFPB, which has requested input on all aspects of its statutory and discretionary functions. CSBS also has commented on the Bureau's Civil Investigative Demands and Enforcement Process activities.
CSBS comment letters >>
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The Board of Governors of the Federal Reserve System, the Federal Deposit  Insurance Corporation, and the Office of the Comptroller of the Currency issued the host state loan-to-deposit ratios that they will use to determine compliance with section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. These ratios replace the prior year's ratios, which were released on June 21, 2017.
In general, section 109 prohibits a bank from establishing or acquiring a branch or branches outside of its home state primarily for the purpose of deposit production. Section 109 also prohibits branches of banks controlled by out-of-state bank holding companies from operating primarily for the purpose of deposit production.
Section 109 provides a process to test compliance with the statutory requirements. The first step in the process involves a loan-to-deposit ratio test that compares a bank's statewide loan-to-deposit ratio to the host state loan-to-deposit ratio for banks in a particular state.
A second step is conducted if a bank's statewide loan-to-deposit ratio is less than one-half of the published ratio for that state or if data are not available at the bank to conduct the first step. The second step requires the appropriate agency to determine whether the bank is reasonably helping to meet the credit needs of the communities served by the bank's interstate branches.
A bank that fails both steps is in violation of section 109 and is subject to sanctions by the appropriate agency.
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The Compliance Event of the year!
Brought to you by the Arkansas Community Bankers and
Bankers Assurance.
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Holiday Inn - Airport Convention Center
November 8, 2018
ACB Annual Management & Directors Conference
Holiday Inn - Crowne Plaza - Little Rock
June 26, 2018
July 6, 2018
July 12, 2018
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