MIB Policy Resolutions for 2025-2026

The following constitutes the resolutions of the Montana Independent Bankers Association (MIB), which such resolutions broadly describe the Association’s major policy objectives for the 2025-2026 time period.

MEMBERSHIP
Montana Independent Bankers Association (MIB) exclusively represents Montana’s community banks of all sizes and types. MIB is dedicated to maintaining the highest value membership available for community banks that provide financial services to all the people in Montana.

Independent Community Bankers of America (ICBA) is the exclusive voice for community banks on the national level.

TIERED REGULATION FOR COMMUNITY BANKS
The current regulatory framework imposes burden on community banks that diverts resources from their ability to support the financial needs of their customers, serve their communities, and contribute to their local economies. Regulatory relief is needed to account for relationship banking.

MIB urges Congress and the regulatory agencies to continue to expand and refine a tiered regulatory and supervisory system that recognizes the significant differences between community banks and large, complex institutions in terms of the risks they pose to consumers and to the financial system.

To preserve their original purpose and remain aligned with an evolving financial services landscape thresholds for regulatory accommodations and exemptions based on asset size, risk profile, and transaction volume should be continually reviewed and adjusted upward as community banks consolidate and the average asset size of banks increases.

SMALL BUSINESS LENDING
MIB promotes Small Business Administration loan programs and federal policies that foster a vibrant small business sector.

MIB opposes SBA proposals to open SBA 7(a) participation to additional Fintechs and other unregulated, non-depository institutions. Institutions.

MIB opposes proposals to create an SBA 7(a) direct lending program.

MIB opposes proposals to raise SBA 7(a) program fees.

Congress should repeal Section 1071 of the Dodd-Frank Act which requires new data reporting on small business loan applications. If repeal is not possible, the CFPB should exempt community banks under proposed regulations required by statute. Additionally, the CFPB should not use its authority to impose requirements beyond those mandated by statute. 

MIB opposes efforts to impose consumer-like regulations on small business loans.

MIB continues to enhance its small business sector relationships and coalition building.

SMALL BUSINESS LOAN APPLICATION DATA COLLECTION
As relationship bankers, community banks look at each small-business loan individually and often in customized terms based on many factors.

The CFPB’s rigid data collection requirements will hamper the ability of community banks to tailor loans to meet the unique needs of local businesses.

Not only will these data reporting requirements place a significant compliance burden on small community banks, but this final rule does not address the significant concerns ICBA has raised about the privacy of applicants, particularly in smaller communities.

The CFPB’s rule will make it possible for loan applicants to be identified, especially in rural areas — potentially driving small-business owners away from community banks and local communities while having a chilling effect on small-business lending.

The CFPB should use its authority to exempt more community banks and small businesses from its rule and limit mandatory data points to those required by statute. Restricting access to credit in local communities during this critical economic period will ultimately harm the borrowers the CFPB is trying to help — women-owned, minority-owned, and small businesses.

MIB supports Congressional action to repeal the statute, or at a minimum, legislatively fix the most invasive and burdensome portions of the rule.

CYBER INCIDENTS AND BREACHES
MIB supports national cyber incident reporting standards.

MIB supports national data breach legislation to fix the patchwork of state data breach laws.

MIB supports third-party incident and breach notifications to banks.

MIB supports assigning the cost of an incident or data breach to the party that incurs the breach.

MIB supports U.S. Government reporting incidents to banks.

DATA AND CYBER SECURITY
Any new Federal or state legislation, regulation, or guidance related to data or cybersecurity should be non-proscriptive and non-duplicative.

MIB suggests that regulators broaden their supervision to include all companies that have access to consumer financial data.

Regulators should not mandate the use of any one framework, tool, or assessment, but rather support community banks’ ability to use the framework, tool or assessment that best suits their institution’s size, complexity, and risk tolerance.

MIB supports bi-directional sharing of threat intelligence between the financial sector and the government.

MIB supports stronger cybersecurity standards and practices for government.

MIB supports financial sector initiatives such as .BANK and Sheltered Harbor.

BANK SECRECY ACT AND ENFORCEMENT
MIB opposes the mandatory collection of beneficial ownership information of legal entities regardless of risk by financial institutions. Rather, this information should be universally collected by FinCEN at the time an entity is formed. However, financial institutions should have access to and rely on this information to assist them in performing customer due diligence.

MIB strongly recommends raising Currency Transaction Reporting (CTR) and Suspicious Activity Reporting (SAR) thresholds with future increases linked to inflation. The CTR threshold should be raised from $10,000 to $30,000.

MIB supports Bank Secrecy Act/Anti-Money Laundering (BSA/AML) reforms that will ease compliance burdens while providing more useful data to law enforcement.

MIB urges FinCEN to develop an effective communication mechanism between law enforcement, FinCEN, and banks.

Nonbank institutions that perform “bank-like” functions and offer financial services should be subject to the same AML/BSA laws and regulations as banks.

MIB encourages the Office of Foreign Asset Control to streamline and simplify watch-lists of terrorists for ease of reference and application by bankers.

MIB urges FinCEN to take a leadership role in combatting ransomware, synthetic IDs, check and debit card fraud, frauds related to virtual currencies, and other types of fraud. FinCEN needs to also increase proactive communications pertaining to frauds to ensure banks are equipped to combat them

PUBLIC BANKS: POSTAL BANKING & FED ACCOUNTS, AND STATE OWNED BANKS
MIB opposes the provisioning of deposit services and the allocation of credit to consumers, businesses, non-profits, or governmental entities by the United States Postal Service (USPS), the Federal Reserve, or any other federal, state, or quasi-federal or state instrumentality.

The financially challenged USPS has virtually no expertise in providing financial services to consumers in a cost-effective manner. Greater entry by the USPS into financial services introduces another tax-advantaged and lightly regulated entity with limited expertise into the marketplace, akin to credit unions and the Farm Credit System.

MIB opposition extends to the creation of special purpose banks to service the cannabis industry or a National Infrastructure Bank.

Community banks offer affordable accounts for unbanked and underbanked consumers, raising questions about the need for FedAccounts and their ability to attract consumers. Financial services are best provided in a competitive, private, and free marketplace that openly and efficiently benefits customers.

TAX-EXEMPT CREDIT UNIONS
MIB urges Congress to end the unwarranted federal tax subsidy of growth-obsessed credit unions with $1 billion or more in assets and/or promote increased tax parity between credit unions and community banks.

MIB staunchly opposes credit unions’ exploitation of their tax subsidy and lax regulatory environment to acquire locally based community banks.

MIB urges Congress to use its oversight authority to investigate the National Credit Union Administration’s failure to adequately regulate and supervise the industry and to adhere to the original purpose of the credit union tax exemption.

MIB opposes expanded powers for credit union service organizations, which are independently owned, for profit, and not supervised by any federal agency, and supports legislation that would provide NCUA with authority to examine third-party service companies.

MIB opposes NCUA’s weakening of safeguards on commercial lending, field of membership, and the growing use of credit union subordinated debt, which allows outside investors to exploit the credit union tax subsidy.

MIB supports applying Community Reinvestment Act requirements to credit unions comparable to and with the same asset size distinctions as banks and thrifts.

Credit unions should be subject to fair lending exams with the same frequency as banks. While FDIC reviews thousands of banks for compliance with fair lending laws every year, NCUA only conducts approximately 50 annual fair lending exams of credit unions and is not permitted to conduct fair lending exams of state-chartered credit unions.

MIB urges states to prohibit the placement of public deposits in tax-exempt credit unions.

MIB believes that federal credit unions should submit form 990 tax filings as do other tax-exempt organizations.

MIB stands ready to partner with state banking association campaigns to raise awareness among state legislators and the public, urging them to protect community banks and the communities they serve.

COMMUNITY BANK ACCESS TO CAPITAL
MIB supports legislative and regulatory changes that would improve the ability of community banks to raise capital.

MIB opposes the inequitable capital treatment of community banks, based solely on corporate structure, for banks participating in economic stimulus programs such as the Emergency Capital Investment Program. Subchapter S banks should receive the same capital treatment as Subchapter C banks when participating in economic stimulus programs designed to increase capital investments in local communities.

MIB is supportive of additional upward adjustments to the asset limits under the Federal Reserve’s Small Bank Holding Company Policy Statement to ensure these thresholds remain current and properly align with industry consolidation trends.

DIGITAL ASSETS AND CRYPTOCURRENCIES
MIB has serious concerns regarding threats posed by cryptocurrency to privacy and to consumers, and financial stability resulting from increases in money laundering, terrorist financing, and fraudulent activity.

Unregulated cryptocurrency threatens to disintermediate community banks and undermine their ability to provide funding to support local economic activity, growth, and development.

Cryptocurrencies have a history replete with volatile price swings, hacks, and exploits. MIB cautions policymakers that strategic reserves of cryptocurrencies may lose value and lead to unknown risks for the US economy.

MIB urges policymakers to ensure public trust by fostering collaboration between domestic and international regulatory authorities to mitigate risks as the adoption of cryptocurrency continues to increase.

MIB supports ongoing efforts by policymakers to harmonize regulations to ensure strong, clear, and consistent oversight of cryptocurrency service providers and establish guidelines for any permissible activities by banks.

MIB believes most cryptoassets are likely offered and sold as unregistered securities. Therefore, crypto entities should be subject to relevant securities laws and regulations. MIB supports the efforts of the U.S Securities and Exchange Commission to apply the securities framework to cryptoassets and related entities.

MIB urges policymakers, regulators, law enforcement, and national security organizations to coordinate their efforts to combat ransomware and prevent bad actors from using cryptocurrencies for illicit activities and investment scams.

MIB encourages regulators to collaborate on a comprehensive approach to prevent the rise of decentralized finance (DeFi), a shadow banking system filled with unregulated, decentralized platforms that pose risks to consumers, the financial system, and U.S. national security.

Stablecoin issuers should not have access to Federal Reserve master accounts or the payments system.

Special purpose bank charters or similar alternatives should not be granted to crypto entities that do not fully meet the requirements of federally insured and supervised chartered banks.

Regulatory frameworks must establish strong federal oversight for stablecoin issuers to prevent a regulatory race to the bottom.

Any regulatory or supervisory regime applicable to nonbank issued stablecoins should be comparable to a functionally similar product offered by a bank or other traditional financial services provider. This will ensure risks created by loosely regulated nonbank firms do not spill over into the traditional banking system.

The separation of banking and commerce must be preserved by ensuring commercial firms are not given the significant power of issuing private currency.

MIB is concerned about the potential development of state-issued stablecoins that could negatively impact deposits at community banks, thereby harming their ability to provide credit to their communities. If states create new forms of money or payment systems, the U.S. financial system could experience significant fragmentation, threatening financial stability.

MIB urges policymakers to engage with community banks as the Federal Reserve begins to explore new tokenization systems.

RURAL AMERICA AND FARM BILL PROGRAMS
The new Farm Bill should continue to provide essential assistance to the farm sector and to rural America. Robust price support programs provide a financial safety net for many producers during times of low commodity prices.

The new Farm Bill should maintain a strong crop insurance program, a successful public-private partnership critical to the ability of farmers and ranchers to survive weather-related disasters and repay farm loans.

USDA farm loan guarantees benefit family farmers and ranchers and allow community banks to better manage the lending risks of producers who would otherwise be unable to obtain commercial credit. These programs should remain primarily financially geared to establishing successful family farm and ranch operations. Program fee levels should not discourage participation by community bank borrowers and should not be set at levels that overfund government collections.

Farmer Mac should continue to focus on its primary mission of improving secondary market access for community banks.

COMMUNITY BANK CLIMATE RISK REGULATION 
MIB will oppose any federal or state climate risk regulation that adversely impacts community banks and their ability to support their communities and customers, including any guidance, rule, regulation or law that requires community banks to directly or indirectly:

1. comply with hard concentration limits on any type of legal lending, including lending to fossil fuel or other carbon-intensive industries;
2. perform climate stress testing or scenario analysis;
3. make mandatory climate related disclosures;
4. adhere to capital requirements based on climate risk; or
5. discriminate against legal but climate disfavored industries or customers.

MIB supports independent decision making at community banks and will oppose any federal or state initiatives, including ESG and so-called anti-ESG initiatives, designed to limit community bank discretion by forcing banks to categorically deny or discriminate against lending to lawful but disfavored industries and businesses or compelling banks to lend to specific industries or customers.

MIB supports providing incentives to industries deemed to be affected by climate risks if such incentives reward current and future voluntary practices and if climate impact is verified by accurate scientific analysis. Such incentives could include carbon sequestration or other climate mitigation efforts.

State and federal bank regulators should conduct outreach meetings with community bankers and collect empirical data prior to finalizing any supervisory guidance on climate risks to confirm community banks are successfully managing climate risks and better understand how burdensome “one-size-fits-all” climate risk supervision will harm community banks and their customers.

TAX POLICY
MIB continues to promote tax and budget policies that foster economic growth and support the community bank sector by providing direct tax relief and encouraging private savings and small business investment. A fair and unbiased tax code will enhance the viability of community banks and the vital role they serve in the U.S. economy as a source of lending for consumers, small businesses, and farms.

Tax laws should promote robust economic activity and a vibrant community banking sector and foster saving and investment.

The 2017 Tax Cuts and Jobs Act has provided significant tax relief for community banks and their customers. Community bank tax savings support community lending and investment in workforce, technology, and physical infrastructure. ICBA will advocate for permanent extension of the individual provisions, including the deduction for pass-through income (Section 199A), a top individual rate of no more than 37 percent, preferential tax rates for capital gains, and an adequate estate tax exemption, before their scheduled expiration in 2026.

MIB opposes any new bank-specific fees, punitive new tax levies, transaction taxes, limitations on the deductibility of FDIC premiums, or other proposals specifically targeting the financial services sector. Additionally, MIB will continue to oppose any legislation – tax or non-tax – that requires revenue offsets or “pay fors” that target the banking industry, in particular account reporting to the IRS.

Public policy should support community banks’ ability to raise capital including allowing S corporation banks to issue preferred stock, increasing their shareholder limits, and allowing new IRA shareholder investments.

MIB supports the creation of tax incentives for community bank retained earnings and community bank lending to low-to-middle income people, small businesses, and small farms. In particular, MIB supports the Access to Credit for our Rural Economy (ACRE) Act.

The tax code should create parity among all providers of financial services. Credit unions, Farm Credit System lenders, and community banks offer similar products and services and should be taxed equivalently.

MIB opposes changes that would effectively increase the taxation of estates, including taxation of capital gains at death and eliminating or curbing stepped up basis in the valuation assets. Such changes would trigger sales of community banks and promote industry consolidation.

MIB opposes any new limitations on Section 1031 exchanges. 

ENDING TOO-BIG-TO-FAIL
MIB supports legislative and regulatory measures that would curb or end advantages currently enjoyed by large banks holding more than $100 billion in total assets. MIB supports increased measures to regulate large too-big-to-fail banks and help mitigate the risk they pose to the financial system and economy. Such measures include: (1) higher capital and supplemental leverage ratio requirements on the largest banks and their holding companies; (2) enhanced liquidity standards; (3) activity restrictions; (4) concentration limits; (5) limitations on the federal safety net; and (6) more effective resolution authority.

MIB supports a significant capital surcharge on SIFIs and the imposition of total loss absorbing capacity (TLAC) and long-term debt (LTD) requirements on all banks with assets greater than $100 billion in assets. In addition to providing protection to the FDIC’s Deposit Insurance Fund and U.S. taxpayers from the failures of large banks, TLAC or long-term debt requirements would also allow the FDIC to resolve large banks over an extended period of time and provide community banks a greater opportunity to purchase a large bank’s assets and deposits in receivership.

MIB supports the Federal Deposit Insurance Corporation’s (FDIC’s) and the Federal Reserve’s rules on contingent resolution plans which would facilitate rapid and orderly resolutions and enable the FDIC, as receiver, to resolve the institution under the FDI Act. MIB believes that the submission of resolution plans should be limited to those banking organizations with total consolidated assets of $100 billion or more. MIB opposes the FDIC proposal to require informational filings for banks with assets of $50 billion or more.

The same prosecutorial standards and enforcement procedures must apply to community banks and large banks alike.

DEPOSIT INSURANCE
Our nation’s federal deposit insurance system is critical to depositor confidence in the banking system, to the protection of small depositors, and to the funding base of community banks.

MIB supports a deposit insurance assessment framework that is appropriately tiered and risk weighted.

MIB opposes sharp, procyclical increases to deposit insurance assessments.

MIB strongly opposes special assessments for community banks when the FDIC utilizes the systemic risk exception to resolve large, risky, and TBTF banks.

MIB encourages the FDIC to create a systemic risk premium, which would require the nation’s largest TBTF institutions to pay a premium on their deposit insurance assessments based on the unique risk they pose to the DIF in the event one of these institutions required resolution.

MIB urges Congress to ensure the FDIC has needed authority to quickly authorize a Transaction Account Guarantee (TAG) program to protect depositors without needing to make any determinations of systemic risk. MIB has historically supported TAG programs that provide increased deposit insurance for noninterest bearing accounts to prevent or stabilize disruptive shifts in deposit funding.

MIB opposes increases to deposit insurance assessments that are based on the DIF achieving a 2 percent designated reserve ratio rather than the statutory minimum of 1.35 percent.

MUTUAL AND SAVINGS INSTITUTIONS
MIB supports and defends the choice of mutual ownership before all regulatory and legislative bodies. Mutuality is a viable charter alternative that should be accorded parity in all respects with other charter forms. A financial institution has the right to choose the type of charter and business model under which it operates whether it is a traditional mutual institution with a savings and loan mission, a covered savings association established to hold national bank powers, or a state-chartered mutual organization that offers expanded banking services like commercial loans.

Mutual institutions should be equally represented and accorded parity in all respects with other charter forms. Any proposed legislation or regulations should consider the impact on the mutual bank business model and its viability.

BANKING CANNABIS-RELATED BUSINESSES
Montana has legalized cannabis for medical and/or recreational use, it is critically important that cannabis-related businesses (CRBs) have access to traditional banking services. At the federal level, cannabis remains illegal under the Controlled Substances Act.

MIB does not advocate for the legalization of cannabis.

MIB advocates for federal legislation establishing an effective “safe harbor” from federal sanctions for banks that choose to do business with cannabis-related businesses (CRBs), including businesses that provide products or services to CRBs, in states where cannabis is legal under state law.

This safe harbor must extend to banks that serve businesses that may serve CRBs (“ancillary businesses”) such as landlords, accountants, utility providers, and others as ancillary businesses may be paid in funds ultimately derived from cannabis sales.

Federal banking regulators should not be able to threaten or limit a bank’s deposit insurance, downgrade a loan made to a CRB, force a depository institution to cease providing banking services to a CRB, or take any other prejudicial action in a state where cannabis is legal, solely because the customer is a CRB.

MIB opposes any effort by a state or municipality to establish a publicly owned bank or credit union to service the cannabis industry. Traditional banks are fully capable of serving this industry with the creation of an effective “safe harbor” to protect them from government or regulatory reprisal.

DEFENDING THE BANK CHARTER
Corporate conglomerates or other companies engaged in commercial activities should not be allowed to own full-service or special purpose banks in violation of the longstanding U.S. policy of maintaining the separation of banking and commerce.

Congress should close the ILC loophole and prevent the creation of special purpose national bank charters because they not only threaten the financial system but create an uneven playing field for community banks.

The OCC should have explicit statutory authority from Congress before issuing any special purpose national bank charter for financial technology (fintech) companies. Any new federal charter should be subject to the same standards of safety, soundness, and fairness as other federally chartered institutions.

The Federal Reserve Banks should conduct rigorous due diligence of state chartered special purpose depository institutions (SPDIs) before granting them access to the payments system.

Policymakers must ensure that stablecoin issuers and other crypto-related entities do not have access to Federal Reserve master accounts or the payment system. Special purpose bank charters or similar alternatives should not be granted to cryptoasset entities that do not fully meet the requirements of federally insured and supervised chartered banks.

THE FEDERAL HOME LOAN BANK SYSTEM
The Federal Home Loan Banks (FHLBs) must remain a strong, stable, reliable source of funding for community banks.

MIB opposes unnecessary efforts to steer banks away from utilizing FHLB advances in favor of using the Fed discount window as part of their liquidity planning.

MIB opposes any legislation or administrative action that would permit any new types of non-depository entities, which are not prudentially regulated, to access any FHLBank program or service, either directly or indirectly.

MIB strongly opposes any ongoing mortgage asset test for member institutions to access the FHLB system.

The regional structure and cooperative nature of the FHLB system must be maintained, and any structural changes to the FHLB system must originate and be supported by the member owners of the system.

Advances should remain the FHLBanks’ primary focus and members should not be required to track or segregate advances for “mission related purposes”.

FHFA should align the capital requirements for member bank FHLB advances with the prudential regulators to avoid disruption and possible liquidity problems for otherwise well capitalized community banks.

PAYMENTS ACCESS, CHOICE, AND GOVERNANCE
MIB is a strong advocate for secure, financial institution-centric payments systems, and urges policymakers and regulators to maintain their position that direct access to these systems be limited to federally regulated financial institutions.

MIB strongly urges policymakers to ensure a competitive level playing field for the financial services ecosystem.

MIB supports both public and private sector payments settlement networks that facilitate competition and that permit financial institutions to select the provider(s) of their choice.

MIB supports the industry rules and the payment market infrastructure (PMI) providers that play a role in developing and maintaining payments systems’ access and functionalities. MIB urges these organizations to ensure that their governance processes enable and foster community bank participation and support transparent, timely, and inclusive rulemaking.

PAYMENTS FRAUD & SCAMS
Fighting payments fraud and scams is a shared responsibility. MIB encourages everyone in the payments ecosystem to contribute appropriately to efforts to prevent, detect, and mitigate fraud and scams. Community banks know their customers well, so they are uniquely positioned to help prevent and detect fraud on the front lines.

MIB encourages law enforcement agencies to respond aggressively to check fraud. MIB opposes additional regulatory action that will add burden to community banks. Financial institutions should work together to ensure breach of warranty claims are addressed promptly as required by law.

MIB supports the full application of Regulation E and other consumer regulations to payment platforms that allow consumers to move money. MIB opposes amending Regulation E to make banks liable for fraudulent transactions authorized by customers. Expanding liability under Regulation E would have a chilling and disproportionate impact on community banks.

MIB encourages the use of technologies, solutions, and processes that help prevent and detect fraud. MIB also supports fraud mitigation solutions that empathize cooperation and information sharing across financial institutions.

REGULATORY CAPITAL
MIB supports strong capital requirements for all banks and their respective holding companies. MIB continues to support the community bank leverage ratio (CBLR) but does not support the 9 percent reporting threshold.

Basel III continues to be punitive and to inhibit lending for community banks that do not elect or do not qualify for the 9 percent CBLR. MIB supports a full exemption from Basel III for non-systemically important financial institutions (non-SIFIs) or amendments as discussed in the background of this resolution.

Capital standards should not disadvantage community banks relative to credit unions or global systematically important banks (GSIBs) and certain capital deductions like goodwill should be reconsidered by regulators.

Banking regulators should not impose liquidity coverage ratio restrictions on high-quality investment securities that would impact the liquidity of those securities for community banks. MIB supports efforts to expand the types of municipal securities that can be categorized as high-quality liquid assets when calculating a bank’s liquidity coverage ratio. MIB also believes that Fannie Mae and Freddie Mac securities should qualify as high-quality liquid assets.

MIB supports regulatory efforts to impose standardized approach capital requirements for the largest banks to better protect taxpayers from the heightened risk of failure when these institutions use internal models to calculate capital levels.

SUPERVISORY ENVIRONMENT
While liquidity, CRE concentrations and uninsured deposits are important areas for examiners to review, MIB is concerned that examiners are placing too much emphasis on liquidity following the failures of Silicon Valley Bank and Signature Bank and are unreasonably downgrading community banks (particularly those banks with significant unrealized losses) even when they have access to secondary sources of liquidity.

Community banks are concerned certain restrictions or practices that apply to the largest banks will trickle down to their level as “best practices.” Examiners should not apply large-bank practices to community banks that operate according to a different, less complex, and more conservative business model. Additionally, regulators should not issue recommendations that are not tied to examination findings. MIB opposes regulators imposing any additional requirements on community banks through the issuance of informal “recommendations” or “best practices.”

MIB opposes a supervisory process that places community banks at a competitive disadvantage to larger institutions and non-bank financial institutions due to inconsistent or non-existent oversight.

MIB supports legislation that would reform the appellate process for agency decisions or actions and allow bankers to appeal to an independent council or ombudsman office an adverse determination made by an examiner in an exam report.

MIB opposes the FDIC’s proposal to establish corporate governance standards for all FDIC-supervised institutions with assets of $10 billion or more. The proposal would impose heightened requirements for board members and increase the potential liability of bank directors and officers, making it harder for community banks to attract qualified directors and employees.

MIB supports regulation that would limit the use of Matters Requiring Attention (MRAs) to violations of law, regulation, or material safety and soundness issues.

MIB calls for the prudential regulators to allow well-capitalized and well-managed community banks with fewer than $10 billion in total assets to be examined under an extended 18-to-24-month examination cycle.

CENTRAL BANK DIGITAL CURRENCY (CBDC)
MIB opposes the creation of a retail Central Bank Digital Currency (CBDC) because the associated risks would outweigh its potential benefits. The policy goals that have been articulated in support of a retail CBDC would best be addressed through alternatives that are readily available in the market today.

As the Federal Reserve, Federal agencies, and Congress evaluate whether to create a retail U.S. CBDC, they must consider the risks, policy trade-offs, and challenges with the practicalities of introducing a retail CBDC in the United States, alongside the goals, use cases, technological considerations, and benefits.

Before instituting any form of CBDC, Congress would need to enact legislation authorizing its creation.

MIB adamantly opposes the direct provisioning of retail accounts at the Federal Reserve.

The issuance of a retail CBDC would unfairly position the Federal Reserve as a direct competitor for bank deposits, obstructing banks’ ability to provide vital lending services to customers.

Essential to the analysis of any form of a U.S. central bank digital currency, MIB urges the Federal Reserve to lead collaboration and broad engagement with a diverse array of stakeholders, including community banks.

MIB is actively monitoring global research and experiments on wholesale CBDC and related tokenization systems to understand the full range of potential risks or benefits to community banks. We encourage policymakers to engage in dialogue with community bankers throughout the experimentation process.

PRESERVING THE INDEPENDENCE OF THE FEDERAL BANKING AGENCIES AND THE DUAL BANKING SYSTEM
MIB opposes any action that erodes the independence of the federal banking agencies.

MIB supports bipartisan board oversight at the federal banking agencies.

MIB strongly supports the independence of each federal bank supervisor but encourages enhanced and improved cooperation and consultation among the agencies.

MIB supports preservation of the dual banking system which promotes consumer confidence in the banking system and allows for a diversity of financial institutions.