Bank Directors Seminar, Coeur d'Alene, ID, September 15-17, 2019

2019 Comment Letter

CSBS focused on four areas: • Brokered Deposits can serve as a critical funding source • The ‘cliff effect’ • Institutions should be able to wind down their brokered deposits over time (12-24 months) using the glidepath • The interest rate cap methodology should be changed to account for interest rate fluctuations. Current methodology vs a more market rate methodology

A link to the letter is available here .

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Community Bank Leverage Ratio

CSBS made five main points in its comment letters: (1) The creation of a new prompt corrective action PCA (PCA) framework for the Community Bank Leverage Ratio (CBLR) is unnecessary and creates too much burden. (2) Banks that fall below a CBLR of 9 percent should be given a two-quarter grace period to get the CBLR back above 9 percent or transition back to the current capital rules. (3) The CBLR should be defined as a Tier 1 leverage ratio, that is, the numerator of the CBLR should be Tier 1 capital . (4) Certain qualifying criteria for the CBLR should be eliminated or refined. (5) The federal banking agencies should consult with and notify state regulators in certain circumstances potentially not contemplated by the proposal

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