Pub. 3 2013-2014 Issue 2

6 O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S A Word From CBA... Prioritizing Regulatory Burden Issues The Basel III rules have been finalized and sev - eral positive major changes were made from the bad proposed rule a year ago. CBA provided national and creative leadership in our effort to block the Basel III proposal a year ago: CBA materials were used na - tionwide, an extensive CBA comment letter was filed, our first letter of opposition was signed by Colorado’s entire Congressional delegation, and CBA called for Congressional hearings. The day after the revised and improved rule was finalized, CBA convened a small working group to begin to identify the next tier of is - sues that need to be addressed. CBA now is at work on this next layer of issues. Out of the dozens and hundreds of regulatory issues constricting banks and their ability to serve customers, our industry needs to focus on the most egregious. Most public officials do not care about the burden imposed on banks, and some would in fact cheer that burden on. To motivate many public of- ficials, we instead need to demonstrate the negative impact of the rules on bank customers. The second “flash survey” recently focused on these two questions and is providing very meaningful information so we can target the worst regulatory burdens where bad customer impact of the rules is on our side. Among the topics bank presidents in dozens of states were asked to rank in priority were the dispa- rate impact theory in fair lending, ability-to-repay mortgage rules, UDAAP standards and application, mortgage loan origination compensation and many more. To learn bankers’ priorities, a second flash survey quizzed bankers nationwide. It, like the first flash survey, was drafted by CBA. The first flash survey garnered responses from more than 10% of all banks in the U.S. That first one reflected bankers’ priorities on many issues: 1)Provide regulatory relief, 2)Limit proposed real estate lending regulations, 3)Stop expansion of credit unions and Farm Credit System, 4)Promote checks and balances for CFPB, 5)Block/limit increased capital require - ments, 6)Work to eliminate “Too Big To Fail,” and 7) Improve bank examinations and appeals process. Our resources will be spent in this order. The flash surveys are designed to be a couple of questions that focus on current hot topics which CEOs can answer in a couple of minutes. The initial surveys have focused on giving direction to bankers associa- tions; future surveys will try to reflect the collective thinking of bankers where the answers will help you manage your banks. These flash surveys are an outgrowth of the Regula - tory Feedback Initiative (RFI). The RFI gathers infor - mation from bankers nationwide on issues addressed in their most recent exams. More than 1,800 banks (25% of all banks in the U.S.) have answered the exam survey. Before slicing the data by bank size, charter, location… the full set of data covers 500 pages in small print. It is very meaningful, especially when refined to reflect your kind of bank. To get your report tailored to your bank, contact Fritz at CBA (fritz@colorado - bankers.org) . The RFI was launched nationwide in 2011 and was based almost exclusively on an annual survey of Colo - rado banks on exam issues started in 2008. CBA does all of this to help banks help build a stronger economy for the benefit of Coloradans. We take pride in tackling national issues as well as state ones in your behalf. n Don Childears CBA President/CEO To motivate many public officials, we instead need to demonstrate the negative impact of the rules on bank customers.