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

Treasury’s Substantially Similar Principles for State Stablecoin Regimes Need Recalibration

The GENIUS Act recognized the states’ foundational role in the stablecoin market and directed Treasury to set principles for state regimes to be substantially similar to the federal framework — not identical.

OCC Stablecoin Rules Must Address Issuer Risks and Protect Consumers

The OCC should limit issuer activities consistent with the GENIUS Act and establish capital standards that address the heightened risks posed by digital asset service provider activities.

Agencies’ Capital Proposals Much Advanced but Warrant Further Improvements

CSBS supports the goal of enhancing the risk sensitivity, consistency, and transparency of the risk-based capital framework, but important adjustments are necessary to promote a level playing field between large and small banking organizations.

The OCC Overreaches with State Escrow Preemption

The OCC’s preemption of state interest-on-escrow laws erodes 50 years of precedent designed to protect consumers.

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