2019 Journal of Community Bank Case Studies

2019 COMMUNITY BANK CASE STUDY COMPETITION

Volcker Rule, Escrow, HMDA, Small Bank Holding Company Threshold The provisions listed above hold no weight at People’s Intermountain Bank because the bank either does not engage in proprietary trading, generates too many mortgages, or is not involved with significant debt issuance at the holding company level (Perkins). Williams summarized the overall effect of the regulatory relief by saying “EGRRCPA did not impact us very much at all because we have historically run ourselves in accordance with the prior regulatory rules and requirements anyway. So this relief does not matter a whole lot to us. We are still going to maintain the conservatism that we have. The one benefit that we did get was the longer period between exams” (Williams). Equally important to the relief has been the administrative changes in the federal

regulatory agencies. During 2018, new directors were appointed to both the FDIC and the CFPB. Since then, both organizations have experienced changes in positions such as general counsel, deputy chairman, senior deputy general counsel, and director of external affairs among others (Sparks). Williams shed light on this saying, “We have received positive movement from the FDIC. The tone from the FDIC is how can we help banks? How can we be transparent in what is going on? You’re going to know why we’re asking for it, how it benefits.” Regarding the CFPB he said, “The community banking perspective on them has changed a lot. They are improving from a more backward- looking view to a more forward-looking one” (Williams). Looking forward, there are no practical ways for People’s Intermountain Bank to better take advantage of unapplied EGRRCPA provisions. As already discussed, the bank operates under a well-capitalized and conservative strategy which resulted in it realizing minimal effects from EGRRCPA. Due to People’s Intermountain Bank not experiencing any relevant relief other than from the exam cycle extension, the bank is not in a better position to serve any more customers than it was previous to the passing of the bill. Because of this, there will be no economic impact foreseen on the community as a result of S.2155. This occurs because of the unique way that People’s Intermountain Bank functions and operates. As already explained, the bank was functioning incredibly well within the regulations set forth by Dodd-Frank.

Looking forward, there are no practical ways for People’s Intermountain Bank to better take advantage of unapplied EGRRCPA provisions.

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