STATE GOVERNMENT RELATIONS
Register for 2022 IBA Regional Meetings
The IBA is once again hosting a series of regional meetings around the state to facilitate grassroots communication between the bankers we serve and the legislators who serve our state. The meetings will include an hour-long update on the IBA, including legislative information and advocacy opportunities. Following the update, local legislators from the Indiana General Assembly will meet for lunch with bankers from the community. Five regional meetings remain, each beginning at 11:00 a.m. local time. Below are the dates, locations and registration links of each regional meeting.
Merrillville – July 19
Cooper’s Hawk
2120 Southlake Mall
Merrillville, IN 46410
West Lafayette – July 20
Walt’s Pub & Grill
1050 Kalberer Road
West Lafayette, IN 47906
New Albany – August 4
The Exchange Pub
118 W Main Street
New Albany, IN 47150
Richmond – August 29
Olde Richmond Inn
138 South 5th Street
Richmond, IN 47374
Bloomington – August 30
Graduate Hotel
210 East Kirkwood Avenue
Bloomington, IN 47408
FEDERAL GOVERNMENT RELATIONS
FHFA Issues Final Rule Regarding Fannie, Freddie Annual Capital Plans
The Federal Housing Finance Agency has published its final rule requiring Fannie Mae and Freddie Mac to submit annual capital plans and incorporate the stress capital buffer determination from the Enterprise Regulatory Capital Framework into the capital planning process. The government sponsored enterprises’ (GSE) capital plans are due by May 20, 2023, and must include:
- An assessment of the expected sources and uses of capital over the planning horizon;
- Estimates of projected revenues, expenses, losses, reserves, and pro forma capital levels under certain scenarios;
- A description of all planned capital actions over the planning horizon;
- Details on how the GSEs will maintain capital standards commensurate with risk under stressful conditions; and
- An explanation of how expected changes to the GSE’s business plan will impact capital adequacy or liquidity.
FDIC Climate Comments Due by Midnight
Today is the deadline for to submit personalized comment letters to the Federal Deposit Insurance Corp. on its draft statement of principles for climate-related financial risk management for large financial institutions. To help bankers submit unique comments, the IBA provided guidance from both the Independent Community Bankers of America and American Bankers Association in an email last week.
The FDIC proposal would impose a climate-related financial risk management framework for institutions over $100 billion in assets. However, the FDIC indicated in releasing the plan that all financial institutions may have material exposures to climate-related financial risks, raising concerns that the principles will trickle down to community banks.
To submit comments:
- Use the FDIC’s internet comment form.
- Send an email to comments@fdic.gov. Include RIN 3064–ZA32 in the subject line of the message.
- Send paper comments to James P. Sheesley, Assistant Executive Secretary, Attention: Comments – RIN 3064–ZA32, Federal Deposit Insurance Corporation, 550 17th Street NW, Washington, DC 20429.
- All submissions should refer to File Number RIN 3064–ZA32. This file number should be included on the subject line if email is used. To help the FDIC process and review your comments more efficiently, please use only one method of submission.
Comment Letter Writing Guides:
ABA Comment Letter Writing Guide
ICBA Comment Letter Writing Guide
Joint Trades Submit Letter to SBA
The American Bankers Association joined the Bank Policy Institute and Consumer Bankers Association in sending a letter to request the Small Business Administration to adjust the time period that Paycheck Protection Program lenders may ask SBA to purchase the guaranty on a PPP loan. Current SBA policy states that a lender may request the SBA purchase the guaranty on a PPP loan within 180 days after a forgiveness decision is made or the loan matures, or 60 days after the borrower has filed an appeal with SBA’s Office of Hearing and Appeals of SBA’s decision to provide partial or no forgiveness of a PPP loan. The joint letter asks SBA to allow the lender to seek SBA’s purchase of the guaranty within 180 days from the date of an OHA appeal decision (not from the date of filing the appeal). It also asks for guidance that states that, for loans that remain in deferment (including because a timely OHA appeal was filed), the 180-day timeline to request that SBA purchase the guaranty upon the loan’s maturity will be tolled until the loan exits deferment.