On this day of remembrance, we should all to take a few moments to reflect on those who lost their lives 23 years ago, and their families who lost loved ones. We should also remember the many brave men and women who serve to protect our freedoms and still do! God Bless America!

IBANYS EXECUTIVE LEADERSHIP SYMPOSIUM - With the college football and NFL seasons now underway (and with the Buffalo Bills still undefeated!), Fall is underway. It’s time to register for IBANYS' EXECUTIVE LEADERSHIP SYMPOSIUM (October 7-9) in beautiful Clayton, NY at 1000 Islands Harbor Hotel! Use this brochure. The event is designed for community bank C-suite execs and their leadership teams, board of directors – and, RISING STARS within your bank. Great speakers, great networking, and great fun with sports fishing on the St. Lawrence, golf at Thousand Islands Country Club and a river cruise. Our room block is sold out. Click here for a list of overflow hotels in Clayton. Information on registration, golf, fishing and sponsorships are in the brochure -- or, at www.ibanys.net/events. A special discount will be given to banks that register 3 or more people.

. . . Preferred partners & associate members: Some Sponsorship opportunities are still available, but they are going fast. Take advantage of joining us at the Symposium. While we will not have exhibit booths -- we will have senior bank executives and the industry’s rising stars under one roof – your chance to meet them and build relationships. 

Questions? Call Linda Gregware at the office 518.436.4646 or John Witkowski at 716.880.0518. 

WE LOOK FORWARD TO SEEING ALL OF YOU IN CLAYTON!!

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NBT Bancorp Inc. and Evans Bancorp, Inc. announced a strategic merger, with Evans merging into NBT. The deal will expand NBT's presence into Western New York, including Buffalo and Rochester markets. The combined organization will have the highest deposit market share in Upstate New York for banks under $100 billion in assets, with over 170 locations from Buffalo, New York to Portland, Maine. Evans CEO (and former IBANYS Chairman) David Nasca will join NBT's Board of Directors. The merger is expected to close in Q2 2025 subject to shareholder and regulatory approvals. IBANYS’ preferred partner Luse Gorman is legal counsel to Evans Bancorp in the transaction.

Words worth sharing from Paul Mello and his team at Solvay Bank (@SolvayBank): “We're excited to recognize Exceptional Family Resources as a recipient of a recent $5,000 grant, made possible through our partnership with the Federal Home Loan Bank of New York! #SolvayBank #CommunityBank.”

Community Bankers: ICBA will hold a complimentary community bank briefing on key congressional and regulatory developments Thursday, September 19 at 2:00 p.m. The briefing will include Q&A with ICBA experts. Register here.

IBANYS’ preferred partner Ncontracts -- a leading provider of integrated compliance, risk, and vendor management solutions to the financial services industry -- has acquired Venminder, a unified platform for managing third-party risk. Simultaneously, Hg -- a leading investor in software and services businesses -- has bought out prior Ncontracts shareholder Gryphon Investors as well as prior Venminder shareholders, and is backing Founder and CEO Michael Berman to lead the combined business, which promises to deliver more value to customers via these expanded capabilities. Read the press release:  https://www.ncontracts.com/nsight-blog/press-release/ncontracts-acquires-venminder-via-hg-buyout

ICBA announced the winners of the 2024 National Community Bank Service Awards in recognition of the creative and exemplary efforts of the nation’s community banks to help their local communities. Congratulations to Kingston-based Ulster Savings Bank, which received “Honorable Mention” for its commitment to supporting local nonprofits through its Ulster Savings Charitable Foundation which provides vital funding and resources to community organizations.

Latest On Fraud Against Banks, Consumers. The American Banker (subscription required) reports that Fraud against banks, consumers declines in 2024. Suspicious Activity Reports (SARs) from banks related to fraud are on pace to level off this year for the first time since 2014, when the FinCEN began releasing SAR data in its modern form. These reports include loan fraud, check fraud, credit card fraud and other scams that mainly victimize financial services companies.

“ICBA LIVE 2025” will be held March 11-14, at the Gaylord Opryland Resort & Convention Center in Nashville. It’s ICBA’s premier event for community bankers, the largest annual gathering of its kind and offers opportunities for connection, idea-sharing, and professional growth. Bankers can participate in general sessions, practical learning labs, and peer-driven roundtables designed to empower and inspire community banker, so register by Sept. 20 to secure early access to ICBA’s room block

. . . John

From NFL to Banking: John Witkowski’s Journey and Insights



The new season of “Jack Rants” with Modern Bankers kicks off today, September 4, and I had the honor of being the first guest. You can watch on Linkedin: https://lnkd.in/ga_pKwYT

Podcast Episode Locations

● The Modern Banker Podcast

● Spotify

● Apple Podcast

● YouTube - https://www.youtube.com/watch?v=FQb9JiFi3Xg

● Google Podcast

● iHeartRadio

● ListenNotes

● PlayerFM

● Podchaser

● Podcast Index

IBANYS MEETINGS

MEET THE SPEAKERS

Steffani Jenkins

CRA Liaison

ICBA CRA Solutions

Steffani Jenkins is the CRA Liaison for ICBA CRA Solutions. She has over 20 years of experience in CRA, serving in multiple capacities, including Community Development Manager, CRA Analyst, and Deputy CRA Officer. Most recently, she served as the Community Development Director for a large bank for thirteen years. 

In her current position, Steffani is responsible for assisting banks of all asset sizes with training, analysis, and recommended enhancements to optimize CRA activities. She offers webinars to banks and also through ICBA’s Education Department on the CRA, including the new requirements under the modernized CRA. She also frequently speaks at state banking association conferences on CRA topics.  Additionally, she serves as moderator of the CRA Collaborative peer group for CRA professionals.  

James Branco,

Director of Financial Institution Partnerships

Upgrade

James is responsible for Upgrade's bank and credit union relationships in the Northeast. James is an industry veteran with 19 years in banking and financial services. James was most recently a managing director handling Fintech / FI business development for an advisory firm, specifically developing bank partnerships in the asset, card and payment sectors. Previously, James was a vice president of client development at a top 5 bank. In addition, James spent 10 years in various roles building partnerships at a large specialty purpose bank.

LEADERSHIP SYMPOSIUM SPONSORS

SEPTEMBER WEBINARS

ICBA Information

Hotel Information: *New Location*

The Peabody Memphis

149 Union Avenue | Memphis, TN 38103

— Book Your Stay —



Who Should Attend?

The in-person seminar is structured for more experienced investment managers, particularly those who have attended Bond Academy. It incorporates balance sheet strategies into the day-to-day management of an institution's investment portfolio, wholesale funding and interest rate risk management. Bank personnel with an intermediate level of understanding of investments who are integral to the investment and balance sheet management process will benefit the most from this advanced course. New directors serving on the investment or asset-liability committee will also find this course beneficial.

Agenda

Courses will focus on the understanding, development and implementation of strategies for balance sheet management, liquidity and capital management, loan portfolio management, investment portfolio construction, among other topics.

Costs/Person

Members: $595

Nonmembers: $695

Additional Registrations - Same Bank: $445/$545 (Discounted Prices)

CPE Credit

Earn up to 12 credits

Questions

631-656-4752 | fixedincomeevents@stifel.com

ICBA Securities is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be addressed to the National Registry of CPE Sponsors, through nasbaregistry.org

ALBANY UPDATE

 LEGISLATIVE UPDATE

• Wild Card Law Extended Until 2029. Governor Hochul signed legislation (A.10031 (Buttenschon/S. 9382, Sanders) that extends the sunset of the state’s banking wild card law for five years-- from September 10, 2024 to September 10, 2029. It is now Chapter 254 of the Laws of 2024. The banking "wild card" law " provides an administrative mechanism to keep the state banking charter viable and competitive with the federal banking charter."

• Hochul’s “To Do” List. There is unfinished business from 2024 Legislative Session. More than 500 bills await action by the Governor. https://memo.odonnellsolutions.com/p/september-2-2024

REGULATORY ITEMS

• Governor’s New Chief Counsel. Governor Hochul named Brian Mahanna as Counsel to the Governor. He will succeed Liz Fine, and will begin later this month. Mahanna previously served as Chief of Staff and Deputy Attorney General in the Office of the New York State Attorney General -- responsible for operations -- and was primary liaison to the Governor’s office, the State Legislature, and NYS agencies. He was previously Senior Adviser to former NYC Mayor Bloomberg; Chief of Staff & Counsel to NYC's Deputy Mayor for Operations, and is currently a Partner at Wilmer Hale, where he Co-Chairs the firm’s State Attorneys General practice and is Vice Chair of its Regulatory Department. He is a trustee of the Citizens Budget Commission of New York.

• Budget Process Beginning Soon. The state’s budget planning for the upcoming fiscal year that begins April 1, 2025. The Department of Budget (DOB) will hold public hearings – likely in October – when state agencies will outline their capital budget requests and answer questions from state legislators. In November, representatives from DOB, the Senate Finance Committee, the Assembly Ways and Means Committee, and the State Comptrollers' office will hold a public “Quick Start” meeting to discuss revenue estimates and spending projections for the upcoming year. https://memo.odonnellsolutions.com/p/september-2-2024. The Governor will present her initial budget proposal to the Legislature in January, when negotiations will begin.

POLITICAL, ECONOMIC & DEMOGRPHIC NEWS

• New NY House Ratings. New York is a key battleground state for control of the U.S. House. Several hotly contested New York congressional races could decide which party controls Congress. New York surprisingly titled the balance in favor of the GOP two years ago. The “Cook Political Report” has released its most recent update on its House ratings for November, assessing  the competitiveness of all 435 House elections. It lists NY’s 3rd CD (Suozzi) as “Likely Democratic”, NY18 (Ryan) as “Lean Democratic”, NY22 (Williams) as “Lean Democratic”, NY4 (D’Esposito), 17 (Lawler) and 19 (Molinaro) as “Tossups”, and NY1 (LaLota) as “Likely Republican” (link). 

• NY Dems Have A Long-Term Plan. DNew York Democrats are building a voter outreach and campaign infrastructure they want to last beyond Election Day, as the party fears its toehold on statewide power is starting to slip. 

• While NY GOP's Running Against Hochul. House Republicans in New York State who are facing tough reelection fights have been running against Gov. Hochul – a “repurposing” of the strategy that helped them win office in 2022 – and it’s ramping up. https://www.politico.com/newsletters/new-york-playbook/2024/09/05/house-republicans-familiar-common-foe-00177468?nname=new-york-playbook&nid=0000014f-1646-d88f-a1cf-5f46b74f0000&nrid=00000152-f737-dcf0-a7d7-f73fb7700001&nlid=630317. Hochul had a 39 percent favorable rating according to a recent Siena College poll. Politico New York reports. Meanwhile, NYS Democrats said they’ve opened 36 field offices, signed up 8,400 volunteers, contacted 800,000 voters, knocked on 220,000 doors and made over 540,000 phone calls. 

• Disaster Aid. Rep. Langworthy (R-Erie County) has appealed directly to President Biden to approve the state's Major Disaster Declaration Request following the flooding caused by Hurricane Debby.  Gov. Hochul has requested a Major Disaster Declaration  to help support ongoing recovery in communities that were impacted. Langworthy said the Southern Tier needs FEMA support to recover. Steuben and Allegany counties suffered millions of dollars in damages. Read more.



• CPI Up; Inflation Crisis Over? The Consumer Price Index rose 0.2% in August, while the gauge that excludes food and energy rose 0.3%, the government said on Wednesday – the latest evidence that the inflation crisis is over, as the Fed looks to lower interest rates as soon as next week and take some pressure off the economy. https://www.axios.com/2024/09/11/cpi-report-august-inflation-fed-interest-rate-cuts?stream=top&utm_source=alert&utm_medium=email&utm_campaign=alerts_all

• Latest On Credit Unions. ICBA called on the National Credit Union Administration to bar tax-exempt credit unions from using funds raised from Wall Street investors to finance acquisitions of tax-paying community banks. In a letter to the NCUA, ICBA said the agency should curb the abuse of its subordinated debt rule, which allows credit unions to use their tax exemption to raise money from private equity firms to acquire community banks. ICBA said the NCUA rule: 1) Has led to an explosion of subordinated debt issuance by credit unions, rising from $540 million in the second quarter of 2021 to $3.65 billion in the second quarter of 2023; 2) Allows credit unions to sell ownership interests in their credit unions to nonmember investors, not their traditional member-owners; 3) Has contributed to a cottage industry of boutique investment banks and consultants supporting credit union acquisitions of tax-paying community banks. To address the negative impact of the subordinated debt rule, ICBA called on the NCUA to prohibit: 1) Any credit union that issues subordinated debt from participating in a merger or acquisition for the next five years. 2) Any credit union from issuing subordinated debt for five years after completing the acquisition of a community bank. In a national news release, ICBA said policymakers must step in to address perversions of increasingly antiquated federal policy: “The credit union tax exemption should not be for sale to the highest bidder on Wall Street.” ICBA has repeatedly called on Congress to investigate credit union acquisitions of tax-paying banks. Community bankers can use ICBA’s Be Heard grassroots action center to call on members of Congress to hold a hearing on credit union policy, while additional resources are available on the ICBA website.

• Credit Unions, Part II. After the 15th credit union acquisition of a community bank this year, ICBA said the acquisition trend shows credit unions have expanded beyond the limits established by Congress to justify their federal tax exemption. ICBA President & CEO Rebeca Romero Rainey issued the following important statement: https://www.icba.org/newsroom/news-and-articles/2024/09/04/latest-acquisition-of-tax-paying-community-bank-comes-amid-increased-attention-to-credit-union-tax-exemption. In a national news release, ICBA President and CEO Rebeca Romero Rainey renewed ICBA’s calls for Congress to hold hearings and to consider an “exit fee” on credit union acquisitions of tax-paying banks to capture lost tax revenue resulting from these deals. She noted the news media and the public are taking notice, with recent CNBC, Axios, and CNN coverage raising questions about credit union practices, while ICBA polling conducted by Morning Consult shows Americans support a congressional review of credit union policy. Use ICBA’s Be Heard grassroots action center to call on members of Congress to hold a hearing on credit union policy. Additional resources are available on the ICBA website

• Congress Is Back; House To Vote On Government Funding. Congress returned this week to the traditional election year “push and pull” of members anxious to leave Washington ASAP -- doing just enough to avoid a government shutdown –to campaign. Read more...  Government funding expires in less than three weeks. Speaker Johnson (R-LA) is pulling House Republicans’ six-month stopgap funding plan, forgoing today's planned vote on the bill. He will delay the vote until next week so House Republicans can work over the weekend to address GOP defections and “build consensus.” However, it’s unclear if more time will help save the bill, unless leaders make drastic changes,” Caitlin Emma writes, noting: “House GOP leaders have already been whipping the bill, and nearly a dozen Republicans have publicly said they plan to vote against it.”

• New Meaningful Farm Bill Needed! ICBA and other agricultural stakeholders called on Congress to advance a meaningful farm bill in 2024 that addresses worsening conditions in farm country. In the letter to congressional leaders, the more than 300 groups said: 1) It is time to pass a new farm bill instead of extending the current bill given the potential for many farmers to not qualify for bank financing; 2) The new farm bill should strengthen the safety net with many producers facing multiple years of not being profitable. The letter follows a USDA report showing lower net farm income in 2024. According to the USDA, inflation-adjusted net farm income is forecast to decrease by 6.8% from 2023 to 2024, slightly less than forecast in February but still revealing economic challenges faced by many ag producers. ICBA supports passage of a new farm bill with enhancements to USDA farm programs, including higher loan limits on USDA guaranteed loans and a quicker approval process on USDA guaranteed farm loans. ICBA also continues to express strong opposition to several proposals to expand Farm Credit System authorities. 

• OCC's Hsu On Industry Supervision. ICBA agreed with Acting Comptroller of the Currency Hsu about the impact of banking industry concentration on industry supervision. Hsu said the combined assets in the largest U.S. banks may reach $26 trillion over the next 10 years, and there must be commensurate strengthening of supervision and regulation. In a national news release, ICBA expressed agreement and said there must be effective capital, liquidity, and resolution standards in place following last year's big bank failures, noting: “Policymakers must work to maintain a diverse and decentralized financial system that meets the needs of consumers and small businesses nationwide, including by addressing the cumulative impact of regulatory burden on community banks.”

• Fed Governor Speaks. Fed Governor Waller said he believes the time has come to lower the target range for the federal funds rate at the Fed’s upcoming meeting, and he does not expect the first cut to be the last. Waller said that with inflation and employment near the Fed’s goals and the labor market moderating, a series of reductions will likely be appropriate.

• CFPB's Earned Wage Access Proposal. ICBA told the CFPB its proposed interpretive rule on “earned wage access” products defines “debt” too broadly. In a comment letter, ICBA said while it appreciates the CFPB’s intention of curbing costly EWA products, its definition does not align with its 2020 advisory opinion of EWA products, and the broadened definition creates the potential for ambiguity among consumers and those in the financial services industry and may preclude responsible lenders from providing wage access. EWA products (aka paycheck advance products) provide consumers access to their wages ahead of the normal pay cycle to assist with unexpected circumstances and provide an alternative to predatory payday loans.  The July CFPB proposed guidance says many such products are consumer loans subject to the Truth in Lending Act. In 2020, the CFPB released an advisory opinion on covered EWA programs, clarifying that they did not constitute “credit” as defined by Reg Z.

• Fed On Basel III & Capital Surcharges. Fed Vice Chair for Supervision Barr previewed pending regulatory changes to regulators’ proposals to implement Basel III endgame standards and capital surcharges on the largest banks. Barr said: 1) He intends to recommend that the Fed board re-propose the Basel III endgame proposal and the proposal to adjust the surcharge for global systemically important banks. 2) Changes in the endgame re-proposal will cover all major areas of the rule; 3) He will recommend changes to the G-SIB proposal to better align the capital surcharge with G-SIB systemic risk profiles; 4) Together, the re-proposals would increase aggregate common equity tier 1 capital requirements for the G-SIBs by 9%—down from 19% under the original proposal—and for other large banks by 3-4%; 5) Banking regulators have not made final decisions on any aspect of the re-proposals. The original proposal would apply an enhanced risk-based approach for qualifying banks and require these institutions to run stricter risk-based capital calculations. In March, Fed Chairman Powell told Congress regulators will likely make substantial updates to the Basel III proposal. In a comment letter to regulators earlier this year, ICBA said it generally supports the proposal but cautioned more research is needed to avoid unintended consequences on community banks. ICBA also expressed support for an interagency proposal to require banks with $100 billion or more in assets to maintain minimum levels of externally issued long-term debt, which does not appear to be included in Barr’s recommendations.

•  Fed's Bowman On Stress Tests. Fed Governor Bowman expressed concerns with the current regime of stress testing the nation’s largest banks. Bowman said she is concerned with volatility in firm results from year to year, linking stress testing outcomes with capital through the stress capital buffer, a lack of transparency, and overlap with other capital requirements. She called for reforms to improve countercyclicality, disclose more granular information about stress-testing models, adjust the compliance framework, and address overlapping requirements. This year, 32 banks with $100 billion or more in total assets were subject to the Fed's stress tests.

• FinCEN On BSA Reports. FinCEN said it received 15,417 Bank Secrecy Act reports from 841 financial institutions on more than $688 million in reported suspicious activity in the six months after it issued its February 2023 alert. Banks filed 13,618—or 88%—of the reports, while securities firms filed 885 and credit unions filed 882. Small and midsized banks accounted for the majority of the reports from banks. In its analysis of the BSA reports, FinCEN identified three primary outcomes after checks were stolen from the U.S. Mail: 1) 44% were altered and then deposited; 2) 26% were used as templates to create counterfeit checks; 3) 20% were fraudulently signed and deposited. ICBA continues to raise awareness of check fraud in the news media and encourages community bankers to share their experiences and input on the challenge of check fraud at checkfraud@icba.org. For more information on check fraud, community bankers can: Listen to an Independent Banker podcast on the issue; Download ICBA’s check fraud guide; Join the fraud subgroup on ICBA Community; Read Independent Banker’s latest article on check fraud mitigation tips; Watch the recording of ICBA’s ThinkTECH Solutions Forum on fraud.

• Schumer Interview. Senate Majority Leader Schumer (D-NY) discussed the 2024 presidential race and battle for the Senate majority in an exclusive interview with Spectrum News, Read more. Schumer also spoke with the White House on how to accelerate the pace of judicial confirmations. Democrats have two challenges in surpassing Trump's mark: a clock that's ticking and a Senate that's functionally 50-50 on judicial nominations. Senate Republicans confirmed 234 federal judges under the Trump administration. Senate Democrats have confirmed 205 lifetime judges under the Biden administration, and there are 21 nominees waiting for a floor vote, six others waiting for a committee vote, and nine awaiting a committee hearing. https://www.axios.com/newsletters/axios-sneak-peek-38fe5fc0-6eb7-11ef-8c1a-bd12ad080471.html?utm_source=newsletter&utm_medium=email&utm_campaign=newsletter_axiossneakpeek&stream=top

• Beige Book. The Fed’s “Beige Book” is a periodic publication on current economic conditions across the 12 Fed districts. In the New York District: “. . .broad finance sector continued to weaken. Small-to-medium-sized banks reported no change in loan demand, though demand for refinancing picked up from low levels. Credit standards tightened slightly, particularly for business loans and commercial mortgages. Deposit rates declined noticeably. Loan spreads were mostly unchanged. Delinquency rates continued to rise, particularly for consumer loans.” On balance, “regional economic activity remained flat in the New York District. Labor market conditions continued to moderate, with ongoing cooling in labor demand and increased worker availability. Consumer spending was unchanged. Housing markets remained solid, with home prices edging up. Selling price increases remained modest. For more information about District economic conditions.” visit: https://www.newyorkfed.org/regional-economy.

• FDIC Q2 Banking Profile: Community Banks. The FDIC’s latest Quarterly Banking Profile found Community bank net income rose 1.1% in the second quarter but remained down 8.2% from a year ago on higher noninterest expense. Higher net interest income (up 2.7%) and higher noninterest income (up 5.0%) offset higher noninterest expense (up 2.1%) and higher provision expenses (up 18.2%). For the second quarter, community banks reported: 1) The pretax return on assets ratio increased 1 basis point from the previous quarter to 1.14%. 2) The net interest margin increased 7 basis points from the last quarter to 3.30%, reversing a five-quarter declining trend. 3) Net operating revenue increased 3.2% quarter-over-quarter on higher real estate loan income and higher net gains on loan sales. 4) Noninterest expense increased 2.1% from the previous quarter and 5.6% from a year ago, and quarterly provision expense was up 18.2% and 30.6%, respectively. 5) Unrealized losses on securities declined 1.4% from the previous quarter and 12.3% from the previous year. 6) Total assets increased 0.5% quarter-over-quarter and 3.9% year-over-year. 7) Loan and lease balances grew 1.7% from the previous quarter and 6.3% from the prior year, and loan growth was broad-based across categories. 8) Total community bank deposits increased 0.2% from the previous quarter and were up 3.5% from a year ago. 9) Deposits increased 1.0% from the previous quarter and were up 2.9% from a year ago. 10) The share of noncurrent loans and leases increased 3 basis points from the previous quarter, while the net charge-off rate increased 2 basis points.

• And, Overall Industry. The overall banking industry reported an 11.4% increase in net income from the previous quarter due to a decline in noninterest expense and one-time gains on equity security transactions. Deposit Insurance Fund: The DIF balance increased $3.9 billion to $129.2 billion, while the reserve ratio increased four basis points during the quarter to 1.21%. The total number of FDIC-insured institutions declined by 29 to 4,539. Three banks were sold to credit unions, 26 institutions merged with other banks, one bank failed in the second quarter but did not file a call report in the first quarter, and no banks opened. FDIC Chairman Gruenberg commented: “The banking industry continued to show resilience in the second quarter. Net income increased and asset quality metrics remained generally favorable. However, the banking industry still faces significant downside risks from uncertainty in the economic outlook, market interest rates, and geopolitical events. In addition, weakness in certain loan portfolios, particularly office properties, credit cards, and multifamily loans, continues to warrant monitoring.” Quarterly Banking Profile Home Page (includes previous reports and press conference webcast videos); Charts and Data; Chairman Gruenberg’s Press Statement. The complete Quarterly Banking Profile is available on the second-quarter report’s landing page. 

• FinCEN On BSA Reports. ICBA told FinCEN its proposed rule to update anti-money-laundering and countering-the-financing-of-terrorism programs would create additional burdens on banks without benefitting FinCEN’s efforts to reduce financial crimes. In a comment letter, ICBA said the proposed rule would likely: 1) Impede banks’ efforts of achieving an “effective, risk-based, and reasonably designed AML/CFT program”; 2) Increase regulatory burden and compliance spending by hindering risk-related resource allocation; 3) Increase occurrences of subjective exams due to the lack of guidance; 4) Invalidate the competency, training, and expertise of BSA officers who happen to have other positions in a bank, and 5) Keep in place the practice of robotic and mechanical compliance impeding. ICBA added banks would face increased enforcement risk that result from technical errors if the rule were adopted. The FinCEN proposed rule would require AML/CFT programs with certain minimum components to incorporate government-wide AML/CFT priorities.

• New Leadership At Freddie Mac. Freddie Mac announced Diana Reid as its next CEO, effective immediately. President and interim CEO Michael Hutchins will continue as President.

• On Nonbank Service Providers. ICBA agreed with a Financial Stability Board report that nonbank service providers involved in cross-border payments are not subject to the same regulatory scrutiny as banks. The FSB’s consultation report is the latest step in its work to fulfill a G20 directive to improve the speed, efficiency, transparency, and cost of cross-border payments by 2027.