Policy

CSBS supports state regulators in advancing the system of state financial supervision by ensuring safety, soundness and consumer protection; promoting economic growth; and fostering innovative, responsive supervision. The content in the Policy Section describes the positions of CSBS on legislation, regulations and guidance in advancing these objectives.

Featured

CSBS Applauds Continued Congressional Oversight of Critically Flawed FDIC Corporate Governance Proposal

As the administrative record makes clear, the FDIC’s corporate governance proposal is ill-conceived and must be withdrawn. The FDIC’s rule would impose a one-size-fits-all mandate on institutions that would intrude on over a century of state fiduciary laws.

OCC 5-Year Review of Preemption
CSBS believes this review is long overdue, and we stand ready to assist as you undertake the processes mandated by the Dodd-Frank Act.

Money Service Businesses
The Money Transmission Modernization Act is a single set of nationwide standards and requirements to modernize the supervision and regulation of money transmitters.

All Issues

Bank Merger Policy
Community banks need clear bank merger standards that enable beneficial transactions.
Bank Merger Policy Details

Brokered Deposits
The laws and regulations governing bank use of brokered deposits should be updated to reflect current deposit behaviors and bank funding models.
Brokered Deposits Details

BSA/AML Modernization
The current BSA/AML framework is ineffective and inefficient.
BSA/AML Modernization Details

Community Bank Regulatory Thresholds
Many regulatory thresholds are static and have not kept pace with inflation, economic growth, or broader changes to the industry.
Community Bank Regulatory Thresholds Details

Cybersecurity
Financial services companies face a host of significant cybersecurity threats from various domestic and foreign threat actors. CSBS supports adoption of robust state data security laws, develops cyber exam resources, and provides numerous training opportunities for state examiners.
Cybersecurity Details

De Novo Banks
New bank formations are a critical component of a healthy banking sector.
De Novo Banks Details

Digital Asset Regulation
A robust state pathway for payment stablecoin issuers is critical to maintain dynamic supervision of payment stablecoin issuers, better protect consumers who purchase stablecoins, and support innovation in this developing market.
Digital Asset Regulation Details

FDIC Board Composition
The FDI Act requires that one of the positions on the FDIC Board be held by someone with “State bank supervisory experience.”
FDIC Board Composition Details

Federal Reserve Master Account Access
Master account access should be evaluated on an equitable and impartial basis, regardless of charter type or supervisor.
Federal Reserve Master Account Access Details

FHLB and Fed Discount Window Policy
CSBS encourages continued efforts by the Fed to modernize and improve discount window operations to ensure it can serve as an effective “lender of last resort.”
FHLB and Fed Discount Window Policy Details

Large Bank Capital Requirements
The largest firms should be subject to clear, rational, and appropriately calibrated heightened standards that promote financial stability, a competitive banking system, and regulatory and supervisory transparency.
Large Bank Capital Requirements Details

OCC Preemption
Wholesale preemption of state laws poses risks to consumers and financial stability.
OCC Preemption Details

Third-Party Risk Management
Targeted, actionable, and operational third-party risk management guidance is needed to better support community bank innovation.
Third-Party Risk Management Details

Policy Questions?
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Policy Statements

Access all testimony, comment letters, and policy letters sent by CSBS.

Networked Supervision

A supervisory approach that produces highly-skilled examiners, a more streamlined and efficient compliance process, and a safer consumer experience.

Cooperative Agreements

State Regulators have cooperative agreements with one another, with federal agencies, and with other state representative agencies. You can find all of these agreements here.