ABA/State Association Letter Urging FCC to Discontinue Use of Weiss Safety Rating

Dear Secretary Dortch:

The seventy-five (75) undersigned state banking associations, the American Bankers Association and the Independent Community Bankers of America ("Associations") represent financial institutions of all sizes located across the United States. We appreciate the opportunity to comment on the above referenced Notice of Proposed Rulemaking ("NPRM") issued by the Federal Communications Commission ("FCC"), which seeks comment on whether the FCC should retain use of the Weiss safety rating for determining whether a bank is eligible to extend a letter of credit ("LOC") to a recipient of the FCC's Rural Digital Opportunity Fund ("RDOF").

We urge the FCC to discontinue its requirement that a bank obtain a Weiss safety rating in order to be eligible to provide a LOC to recipients of the FCC's RDOF. We believe the existing bank regulatory structure and supervision of banks provides the FCC with strong assurance that banks that issue a LOC do not present risk of failure. Nonetheless, if the FCC insists on retaining some verification method as part of its bank eligibility rules, we present two options that are superior to the Weiss rating system.

Background

Banks across the country represented by our Associations have longstanding relationships with rural telecommunications ("telco") providers for their banking services including providing LOCs when needed. There continue to be many geographic areas across the nation that are unserved or underserved when it comes to broadband, which make grant programs like the FCC's RDOF and the RDOF Auction critical to help telco providers achieve their deployment milestones. It is in the context of these programs that the Associations are submitting comments for the FCC's consideration as part of its NPRM.

Download the joint comment letter to read the full text.