-: We're now gonna mix it up a little bit,
and I'm gonna call back to the stage.
I'm gonna call Jeremy, our conference chair,
Julie, the ABA chair and our chief policy officer
to do a little immediate reaction
to the two regulatory speeches we heard.
So if I could call my peers up to the stage,
that would be great.
(bright electronic music)
If I could call my peers up
to the stage, that would be great.
There we go.
(bright electronic music continues)
Jeremy: Please. Thank you, Rob.
-: Alright, so here's what I wanted to do.
I wanted to take and get from each of you one thing
that resonated with you from each
of our two regulatory speakers this morning.
So we'll start with Governor Bowman,
and I'll start with our chair,
Julie Thurlow, what's one thing the governor said
during the interaction with you that really resonated?
And then Jeremy and Naomi,
I'll ask the same question of you two.
-: Sure. So, and I wanna say two, sorry, I can't split.
-: That's great.
-: The fluidity, as far as asset size is concerned,
that really struck me because the rules
are changing, so between each of the rules.
So it's kind of similar because also when she actually
talked about the volume of pages,
we've been talking about the size of CRA at 1500 pages,
but the Fed publishing 5,000
and then the, that doesn't count all the pages
from the other agencies.
There's not even enough bedtimes to read all that book.
-: Gotcha.
Jeremy, what is something Governor Bowman
said that resonated with you?
-: Thanks, Rob.
I believe that the, you know, kind of the,
whenever she stressed the moving, you know,
the moving asset size target, I mean,
that spoke volumes and actually got to visit
with her just a little bit yesterday with Julie.
And she couldn't stress enough the importance of us
sharing our concerns with her.
And she really, really would like to hear 'em.
So I'd like to encourage everyone
to do that anytime they can.
-: That's great. Naomi?
-: Building on what we just heard when she
called out the number of pages
that you all are dealing with,
she didn't stop at the 1500 pages of CRA,
which explicitly applies to you.
She also called out the 1100 pages of Basel
that conceptually or theoretically doesn't apply to you,
but we all know that it does.
And so her ability to appreciate what implementation means
for banks, for community banks,
but also understanding that,
well-intentioned exemptions don't actually always work.
-: Thank you very much.
I, for me, listening to her,
I thought her assessment of the various types of risks
that banks undergo was fantastic.
I also thought her adherence to admiration for,
and the importance of tailoring, I thought
that resonated with me.
And then also I did hear her say
that there were some supervisory gaps around SVB
and I thought that was spot on.
So now I'll ask this, the three
of you the same question about acting comptroller Sue
who just exited the stage.
What was one thing that he said
that caught your attention, resonated with you?
And again, I'll start with our chair, Julie.
-: Sure.
So in addition to the strong risk management,
I like the fact that he teed that up and both he
and Mickey hit on that because that is our business
of banking, which is risk management.
But then he did pivot and talked
about the other opportunities
that are there for community banks.
And it aligns obviously with the work that we're doing
in a minority majority community,
identifying particular communities
and identity that we can actually do well with.
And we can have wins by providing financial services and
or opportunities for people to be successful financially
within our financial institution.
I do, although we've leaned hard into that, I am concerned
as far as CRA is concerned in the way it's been written
with counties, entire counties meeting the needs
of those in parallel to a strategy, much like the one
that we have, which is very, very nuanced and very niche.
There are gonna be people that we miss
that from a CRA metric might not be appropriate if you get
that specific as far as who you're targeting.
So I really would like to see how
that plays out in the CRA rules as it relates to
attacking niche markets.
-: Jeremy?
-: I think preaching to the choir here,
but his opening of, you know, proactively manage risk,
prudently provision and manage capital,
it's what everyone in this room does all the time.
And so I think his opening was great
and I think, like I said, preaching to the choir.
-: Sure, Naomi.
-: Great.
So what I really appreciated from the acting comptroller
was painting a picture of incredible optimism
and positivity about what banking can do for communities,
how community banks can really bring people in,
provide them the economic foundation
that they need to succeed.
But what struck me was what he didn't say, which was
overlaying what it is they're trying to,
what these proposals do
and how it will actually prevent you all
from realizing the promise of what is out there.
So for example, he talked about during one part of his talk
about people who are paycheck to paycheck,
and what they really need is not just products and services,
but true flexibility while at the same time trying
to take away the flexibility in terms of the products
and services that you offer
to make exactly those accommodations
for customers who really need it.
So what inspired me about his talk is also what troubled me
about his talk, which is unlike,
I don't believe he's ever worked in a bank.
And so the lack of sort of discussion about the nuts
and bolts of how you achieve the promise with what you have
for me was striking.
-: The regulatory impediments to achieving that optimism
and that view, because that is a wonderful view
and an opportunity.
-: Right?
It's lovely, but in fact they're making it harder
to do exactly what they want us to do and for me-
(audience applauds)
-: Well, incredibly well said.
So Naomi, Julie, Jeremy, thank you very much
for providing this on the spot analysis, feedback,
and reaction to the two regulatory stakeholders
who just spoke to us moments ago.
So thanks everyone. Our live stream will leave us now.
Thank you so much for tuning in.