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The Examiner

"The willingness with which our young people are likely to serve in any war, no matter how justified, shall be directly proportional to how they perceive the veterans of earlier wars were treated and appreciated by their nation."

- George Washington

CSBS wishes you a thoughtful and reflective Veteran's Day weekend.


CSBS Supports Miki Bowman for Fed Board Seat

The following letter from CSBS President and CEO John Ryan was sent this week to Senate Majority Leader Mitch McConnell and Senate Minority Leader Chuck Schumer.

On behalf of the Conference of State Bank Supervisors (CSBS), I am writing to express state bank regulators’ strong support for Michelle Bowman’s nomination to serve on the Board of Governors of the Federal Reserve System.

Commissioner Bowman’s confirmation would install a gifted and dedicated community bank regulator and community banker to the Federal Reserve Board. Indeed, she would be the first individual to fill a seat on the Board that Congress reserved for a community bank regulator or community banker, qualifications that Congress recognized were indispensable in carrying out the Federal Reserve System’s numerous public policy objectives. During her time leading the Office of the State Bank Commissioner of Kansas, as well as her executive leadership at Farmers & Drovers Bank in Council Grove, Kansas, Commissioner Bowman saw firsthand the vital role small, local banks play in the national economy. Moreover, as a regulator and community banker she understands the Federal Reserve’s critical role in fostering a healthy U.S. economy, labor market, and financial system.

Commissioner Bowman’s experience has strongly positioned her to faithfully execute the monetary, regulatory, and associated policy duties as a governor on the Federal Reserve Board.

CSBS encourages Commissioner Bowman’s swift confirmation to the Federal Reserve Board.

cc:    The Hon. Michael Crapo, Chairman, Committee on Banking, Housing, and Urban Affairs
The Hon. Sherrod Brown, Ranking Member, Committee on Banking, Housing, and Urban Affairs


Data Corner: Distribution of Bank Branches

This animated map shows the distribution of the top 10 banks branch locations (ranked by assets) versus all of the other banks in the system from 1994 through 2018. The top 10 banks (in red) are heavily focused in urban/metropolitan areas, while the other 5,541 banks (in green), mostly community banks, often provide the only coverage in less dense/more rural areas outside of major cities. 

In fact, almost one out of every five U.S. counties have no other physical banking offices except those operated by community banks, according to the FDIC Community Bank Study. (Note: the FDIC definition of community banks is different from the “all banks under the top 10” classification used in this analysis).

Out of 5,551 banks in Q2 2018, the top 10 held 50.7 percent of all assets, while the remaining 5,541 held less than half of all assets in the nation (or 49.3 percent).

Branch data for this analysis is taken from the FDIC Summary of Deposits data. For more industry analysis charts and tools, visit data.csbs.org.


FFIEC Releases Statement on OFAC Cyber-Related Sanctions

The FFIEC members issued a joint statement alerting financial institutions to recent actions taken by the Department of Treasury’s Office of Foreign Asset Control (OFAC) under their Cyber-Related Sanctions Program and to the potential impact it may have on financial institutions’ risk-management programs.

The statement describes the issues a financial institution should consider regarding the effect of sanctions on the operations of the financial institution and the implications of the continued use of products or services provided by a sanctioned entity.

Since the program’s inception, OFAC has issued sanctions against entities that are responsible for, are complicit in, or that have engaged in, certain malicious cyber-enabled activities, and providing material and technological support to malicious cyber actors that have targeted U.S. organizations. Some sanctioned entities may offer services to financial institutions that operate in the United States.

As a result of OFAC’s sanctions, all property and interests in property of the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are generally prohibited from engaging in transactions with them. Financial institutions should refer to OFAC resources or the FFIEC’s Information Technology Examination Handbook for information on requirements and expectations regarding OFAC-related compliance and operational risk management.

The FFIEC is a formal interagency body empowered to prescribe uniform principles, standards, and report forms for the federal examination of financial institutions by the Board of Governors of the Federal Reserve, the FDIC, the NCUA, the OCC, and the CFPB, and to make recommendations to promote uniformity in the supervision of financial institutions. The State Liaison Committee (SLC) is also a voting member and includes representatives from CSBS, the American Council of State Savings Supervisors (ACSSS), and the National Association of State Credit Union Supervisors (NASCUS).


South Carolina Receives CSBS Bank Accreditation

CSBS announced this week that the South Carolina Office of the Commissioner of Banking has received a certificate of accreditation for banking supervision, certifying that the office maintains the standards and practices set by the CSBS Accreditation Program. This is the first bank accreditation for the office, led by Commissioner of Banking Robert Davis.

CSBS President and CEO John W. Ryan: “Congratulations to Commissioner Davis and all the staff at the office of the Commissioner of Banking. This accreditation demonstrates the commitment of South Carolina and Commissioner Davis to leadership and excellence in bank supervision.”

The CSBS Bank & Mortgage Accreditation involves an in-depth review of an agency’s policies, procedures, and operations to determine if it meets the standards set forth by the CSBS Performance Standards Committee (PSC). The Accreditation Program helps state bank departments standardize their process, provides guidance and assistance through self-evaluations, socializes best practices for state regulation, and strengthens the state bank system by establishing a shared set of principles.