Community Bank Regulatory Thresholds
Position Summary
Many regulatory thresholds are static and have not kept pace with inflation, economic growth, or broader changes to the industry. As community banks grow and cross these static thresholds, they become subject to more complex and costly compliance requirements that divert resources away from lending and community investment. Updating these thresholds, and then indexing them going forward, would ensure that regulations continue to meet their intended scope and purpose.

Community Bank Regulatory Thresholds News

Blog post

Adjusting Outdated Regulatory Thresholds Helps Community Banks

Static and outdated regulatory thresholds impede a dynamic banking system and can create unnatural barriers that limit a community bank’s growth. State supervisors consistently have called on federal policymakers – whether before Congress or the federal regulatory agencies – to update rules and supervisory approaches to account for economic growth and changes in the banking industry. This week, CSBS stated
September 25, 2025
Comment Letter

Adjusting and Indexing Certain Regulatory Thresholds

Download the Full Comment Letter [PDF] Jennifer M. Jones, Deputy Executive Secretary Federal Deposit Insurance Corporation 550 17th Street NW Washington, DC 20429 RIN 3064-AG15 Re: Adjusting and Indexing Certain Regulatory Thresholds Dear Ms. Jones: The Conference of State Bank Supervisors (“CSBS”) provides the following comments on the Notice of Proposed Rulemaking (“proposal”) issued by the Federal Deposit Insurance Corporation
September 24, 2025
Press Room

FSOC State Banking Supervisor Representative Commissioner Lise Kruse Statement

Washington, D.C. — North Dakota Department of Financial Institutions Commissioner and Financial Stability Oversight Council (FSOC) State Banking Supervisor Representative Lise Kruse statement from today’s FSOC meeting: "I would like to start by commending Secretary Bessent, along with the federal banking agencies, for their attention to this important issue. On
September 10, 2025
Comment Letter

Request for Information: Deregulation

Download the Full Comment Letter [PDF ] The Honorable Russel T. Vought Director Office of Management and Budget 725 17th Street NW Washington, DC 20503 Docket No. OMB-2025-0003 Re: Request for Information: Deregulation Dear Director Vought: In response to the Office of Management and Budget’s (“OMB”) Request for Information: Deregulation, the Conference of State Bank Supervisors (“CSBS”) has attached letters
May 15, 2025
Press Room

“Preserving America’s Community Banks”

“Preserving America’s Community Banks” Conference of State Bank Supervisors President and CEO Brandon Milhorn Remarks ICBA Capital Summit May 14, 2025 Introduction It is exciting to be here at the ICBA Capital Summit, and energizing to be in a room full of community bankers willing to come to Washington, D.C
May 14, 2025
Comment Letter

Modification of Outdated, Burdensome Community Bank Regulatory Thresholds

Download the Full Comment Letter [PDF] The Honorable Scott Bessent Secretary of the Treasury United States Department of Treasury 1500 Pennsylvania Avenue NW Washington, DC 20220 The Honorable Jerome H. Powell Chair Federal Reserve Board of Governors 20th Street and Constitution Avenue NW Washington, DC 20551 The Honorable Travis Hill Acting Chairman Federal Deposit Insurance Corporation 550 17th Street NW
May 12, 2025
Comment Letter

CSBS Comments on House “Making Community Banking Great Again” Agenda

Download the Full Comment Letter [PDF] The Honorable French Hill Chairman Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 The Honorable Maxine Waters Ranking Member Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 Dear Chairman Hill and Ranking Member Waters, On behalf of the Conference of State Bank Supervisors (CSBS), I appreciate the opportunity
March 28, 2025
Press Room

Community Banks Need Tailored Rules to Thrive

Washington, D.C. – In testimony today before the House Financial Services Committee, Arkansas Bank Commissioner Susannah Marshall warned that without collective action from Congress and the federal banking agencies, the nation will continue to lose community banks, threatening banking access for millions of Americans – especially those in rural and
February 5, 2025

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