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
As the administrative record makes clear, the FDIC’s corporate governance proposal is ill-conceived and must be withdrawn.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.
Comment Letter
CSBS believes this review is long overdue, and we stand ready to assist as you undertake the processes mandated by the Dodd-Frank Act.
All Issues
Community banks need clear bank merger standards that enable beneficial transactions.
The laws and regulations governing bank use of brokered deposits should be updated to reflect current deposit behaviors and bank funding models.
The current BSA/AML framework is ineffective and inefficient.
Many regulatory thresholds are static and have not kept pace with inflation, economic growth, or broader changes to the industry.
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.
New bank formations are a critical component of a healthy banking sector.
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.
The FDI Act requires that one of the positions on the FDIC Board be held by someone with “State bank supervisory experience.”
Master account access should be evaluated on an equitable and impartial basis, regardless of charter type or supervisor.
Efforts by the Fed to modernize and improve discount window operations are welcome and essential to ensuring it can serve as an effective “lender of last resort.” At the same time, any policy reforms to the discount window should avoid undermining the FHLBs’ important liquidity role.
CSBS has long maintained that 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.
2024 proposed revisions by the CFPB to the mortgage servicing rules under RESPA/Regulation X create uncertainty and ambiguity regarding how processes and protections under various state laws will interact with the federal framework going forward.
Wholesale preemption of state laws poses risks to consumers and financial stability. The OCC has failed to adhere to the strict requirements established by Congress, inappropriately shielding national banks from state consumer financial laws that apply to similarly situated state-chartered banks and state-licensed nonbank firms.
Bank-TSP relationships have grown in importance and scale, especially for community banks, and clear, actionable, and operational guidance from regulators is critical for banks to successfully navigate complex third-party relationships while meeting their compliance obligations.