Page 5 - January 16, 2025 Bulletin

aRTiCLeS

Associations Ask Trump to Pause
All Open Regulatory Actions Agencies Announce Small Bank,

NDBA joined the ABA and the other 51 state bankers Intermediate Small Bank Asset-
associations urging President-elect Trump to halt work on all Size Thresholds For 2025
open regulatory actions during his first day in office and conduct The Federal Reserve and FDIC announced the updated
a comprehensive review of regulations created in the past four Community Reinvestment Act “small bank” and “intermediate
years, pointing to what they said has been an onslaught of small bank” asset-size thresholds for 2025. The thresholds are
“questionable and unnecessary policy actions.” adjusted annually.
In a joint letter to Trump, the associations asked for the Under the new thresholds, a small bank is an institution that, as
regulatory pause and for the president-elect to extend the of Dec. 31 of either of the prior two calendar years, had assets of
effective dates for finalized regulations until his administration less than $1.609 billion. An intermediate small bank is a small
has time to review and assess the policies. They also requested a institution with assets of at least $402 million as of Dec. 31 of
review of agency guidance and pending agency litigation. The both of the prior two calendar years and less than $1.609 billion
groups urged Trump to direct the Treasury secretary to initiate a as of Dec. 31 of either of the prior two calendar years.
comprehensive review of the current regulatory rulebook, paying
particular attention to the changes enacted over the past four The new thresholds take effect Jan. 1.
years “to assess the cumulative impact of these rules and how they Read more: https://www.federalreserve.gov/newsevents/
are suppressing access to capital and credit across the country.” pressreleases/bcreg20241219a.htm
For the past few years, the federal banking agencies, Consumer
Financial Protection Bureau and capital markets regulators Associations Criticize Lack of
“have pursued an aggressive and misguided regulatory Bank Representation at Credit
agenda, upending longstanding, tested banking practices with
questionable and unnecessary policy actions that undermine our Card Hearing
members’ ability to provide capital and credit to Main Street,” the NDBA joined the ABA and the other 51 state bankers
associations said. They cited examples ranging from the CFPB’s associations in a letter to the leaders of the Senate Judiciary
Attempts to further restrict bank fees to bank merger guidance Committee criticizing them for failing to include any
from multiple agencies “designed to freeze and disincentivize representatives from banks or credit card issuers during a
transactions.” hearing last month on credit card competition. “As a result,
“ABA and our member banks have participated in good faith in the committee and the public failed to receive testimony
the regulatory process, offering data-driven feedback through from a major group of U.S. market participants that is core to
comment letters and hundreds of banker meetings in an effort to facilitating one of the most vibrant credit card markets in the
shape reasonable, economically grounded regulatory outcomes,” world,” the groups said in a joint statement.
ABA and the associations said. “But all too often, the input from The Senate Judiciary Committee held a Nov. 19 hearing on
4,500 banks was ignored, and in some cases, regulators made credit interchange card fees and the retailer-backed Credit Card
decisions to overshoot their legal authority altogether. This has Competition Act, co-sponsored by committee Chair Richard
led ABA and some state associations to file an unprecedented Durbin (D-Ill.) and Sen. Roger Marshall (R-Kan.). While
seven lawsuits challenging statutory overreach and process representatives from Visa and Mastercard testified at the hearing,
failures.” the remaining witnesses represented merchants who have lobbied
The associations said they appreciated Trump’s commitment heavily for passage of the bill. In their letter, the associations
to reducing burdensome regulations and promoting policies noted that thousands of banks and credit unions issue credit
that will create economic growth. “The process of amending or cards, and their investments help maintain and upgrade global
withdrawing agency actions can be slow, but these are steps you payment networks. Community banks also rely on interchange
can take on day one to prevent further harmful regulations from fees to pay for rewards programs and fraud protection, and to
taking root,” they said. underwrite affordable lines of credit, they said.
Read the letter: https://www.aba.com/advocacy/policy-analysis/ “The payments system is critical infrastructure that fuels
letter-to-president-elect-trump-requesting-pause-on-active- our economy — without it, commerce grinds to a halt,” the
regulations associations said. “We hope lawmakers recognize the enormous

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