CSBS strongly opposes the federal agency's plan to change the Community Bank Leverage Ration in way that may actually increase the burden on community banks, despite how the framework for the rule was intended to be drafted.

While state regulators support maintaining fair and appropriate pricing of deposit insurance for institutions that use the CBLR, we believe that the proposed revisions to the deposit insurance assessment system are ultimately unnecessary because the CBLR should be defined as a Tier 1 leverage ratio.

In a comment letter to the FDIC, CSBS suggested changes to the regulatory treatment of brokered deposits and deposit interest cap methodology. Access the full letter [PDF] here.

In a comment letter to House Committee on Financial Services Chairwoman Maxine Waters, CSBS supported and offered suggestions to a draft amendment to the Bank Secrecy Act.

CSBS has unique insight into PACE financing as many R-PACE lenders are state-supervised non- depository institutions.

CSBS has consistently maintained that access to Federal Reserve services should be restricted to eligible institutions on an equitable and impartial basis. We are concerned that this proposal assumes state supervision is substandard to federal supervision.

State regulators remain concerned about the ability of lenders to use the internet to reach borrowers in states where payday lending is restricted. The Bureau’s 2017 Rule would not have prevented illegal payday lending, but its implementation would have instituted nationwide compliance requirements backed up by the Bureau’s examination authority.

State regulators remain concerned about the ability of lenders to use the internet to reach borrowers in states where payday lending is restricted.

State regulators believe this framework has been effective in protecting consumers. The proposed amendments to the Safeguards Rule would bolster the consumer protections ensured by the rule and would not prevent states from imposing stricter requirements.

The Honorable Mitch McConnell Majority Leader United States Senate Washington, DC 20510 The Honorable Charles Schumer Minority Leader United States Senate Washington, DC 20510 Dear Majority Leader McConnell and Minority Leader Schumer: On behalf of the Conference of State Bank Supervisors (CSBS), I am writing to express state bank regulators’ continued support for Michelle Bowman’s nomination to a full term