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ABA Blueprint for Growth

To strengthen our communities and help our customers thrive, America’s banks call on Congress and the administration to enact policies that will:

Promote Economic Growth

A thriving economy depends on well-functioning financial markets as well as consumers and businesses that can take advantage of them. Build on recent tax reform legislation by continuing to promote more efficient regulation of banks and policies that facilitate economic growth and prosperity.

Capital and liquidity. Free up bank capital to drive growth by reducing overly burdensome and unnecessarily complex capital, accounting and liquidity requirements. Require more transparency in the CCAR process to ensure fair and consistent application of capital rules.

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 enhances bankers’ ability to employ capital to support economic growth. Reduce economic distortions by providing more charter flexibility and capital options for thrift institutions, including mutual banks, while addressing Sub S Corp dividend, capital, tax and other issues.

Credit Unions and Farm Credit. Eliminate market inequities among banks, credit unions, and FCS institutions.

Small business and community growth. Fuel lending to job-creating businesses through both increased funding for key SBA loan programs and elimination of regulations that artificially dictate business lending decisions. Support targeted tax credits that underpin service to markets in need.

Student debt. Address the massive burden of student debt and its drag on the economic opportunities of millennials and others.

Diversity in Banking. Promote the collective strength and diversity of our nation’s vibrant banking system. Encourage the creation of de novo institutions, support the continued prosperity of community banking, and otherwise promote the ability of banks of all sizes to better serve their communities.

Encourage Innovation while Protecting Consumers

New banking technologies have the potential to increase U.S. competitiveness, promote financial inclusion, and expand access to banking services that drive the economy. Policymakers should facilitate innovation through “smart” regulation, preserve the integrity of the payments system, and protect banks and consumers against bad actors.

Fintech and nonbank competitors. Facilitate partnerships of banks and technology firms through effective guardrails for collaboration, ensure customers are protected through consistent oversight of all providers, closely examine for unequal regulatory treatment and the implications thereof, and reduce costs and impediments to banker-driven innovation (including addressing vendor management issues).

Shared responsibility. Ensure that all parties share a national, bank-like standard of accountability for protecting customer information and notifying the public after a breach, with the responsible party bearing the costs for their failed security.

Robust culture of cybersecurity. Expand collaborative public-private efforts to fight cyber threats through information-sharing and self-reporting of cyber risks without fear of regulatory sanctions or reputation risk.

Consumer protection and system integrity. Ensure that all payments system participants are subject to the same rules and oversight (including fair lending, KYC, and safety and soundness), fostering a safe, dynamic, innovative and efficient payments system that facilitates growth.

Support the Housing Market

Ensuring Americans have access to mortgage loans and affordable housing can help stabilize communities and provide individuals and families with the means of building wealth. Reduce barriers that impede the mortgage credit markets, and address unresolved national housing finance policy issues.

Mortgage rules. Reform mortgage regulations that have raised costs and prevent banks from flexibly serving their customers—starting by deeming loans held in portfolio as Qualified Mortgages. Revamp HMDA rules to remove unintended barriers to meeting community housing needs.

Housing finance reform. Constrain the role of the federal government—and potential taxpayer liability—in housing finance to a well-defined, explicit and fully priced guarantee of loans made by private lenders. Ensure equitable access to such programs by lenders of all sizes and from all communities.

Flood insurance. Help homeowners protect themselves by providing more incentives to participate in the National Flood Insurance Program and encouraging development of a strong private flood insurance market.

Remove Impediments to Serving Customers

Overly prescriptive regulation and price controls, along with overzealous enforcement, can be counter-productive and inhibit the ability of consumers and small businesses to gain access to products and services that they want and need.

Market pricing for card services. Restore market pricing on debit interchange fees so that consumers can again enjoy more flexibility in the products and services that banks offer.

Rural growth. Pursue pro-growth policies to help farmers manage debt burdens and pricing challenges, fight deposit flight through encouraging access to stable longer-term funding sources, and address the shortage of qualified appraisers in rural areas that hinders real estate transactions.

AML/BSA. Limit the burdens of BSA compliance and reporting—especially new requirements that place undue burdens on customers—and eliminate potential sanctions for banking legal businesses. Support cooperative information-sharing efforts between banks and law enforcement that promotes efficiencies and the establishment of appropriate reporting thresholds.

Cannabis Banking. Recognize the public safety consequences and operational concerns resultant from the conflict between Federal law and state-granted cannabis authority. Seek practical solutions to mitigate problems and eliminate sanction risk for those banks which choose to provide services for that industry.

Rationalize CFPB Rules. Protect consumers while modifying rules that unnecessarily drive up complexity and costs of financial products. Roll back HMDA-like reporting requirements for small business loans, promote banks’ ability to serve customers with small dollar loans and overdraft protection, and revisit other rules that impede consumer and small business access to credit and other services. Advocate for improved CFPB governance and accountability.

Sensible regulation. Oversee finance in a way that promotes growth and innovation, avoiding arbitrary and capricious penalties and providing robust exam review and appeal channels. Update rules to reflect changes in technology and continue to “tailor” regulation to risk while eliminating the trickle down effects of over-regulation on community banks. Modify CRA requirements to reflect actual community needs and improve the CRA supervisory process.

Approved by the ABA Board of Directors January 30, 2018

​Questions? Contact Ken Clayton for more information.