- Background on Exam Fee Provision
- Excerpts from the Financial CHOICE Act with relevant legislative language
- ICBA-ABA Joint Letter on Exam Fee Provision
CSBS Letters to Congress
As you know, Congress has been considering proposals to subject the federal financial regulators – the Fed, FDIC, CFPB, OCC, NCUA, and FHFA – to the Congressional appropriations process. The Financial CHOICE Act (H.R. 10), seeks to accomplish this and, in doing so, is required to include “offsets” for the added cost to the federal government of subjecting these agencies to the appropriations process. To meet this requirement, the version of the CHOICE Act approved by the House of Representatives on June 8, 2017 includes a funding offset in the form of exam fees to be assessed by the FDIC and the Federal Reserve.
Identical state bank exam language is included in FY 2018 Appropriations approved by the House on September 14. However, during floor debate the House approved an amendment removing NCUA from the group of regulators to be subject to appropriations and eliminating any corresponding credit union exam fee.
Proposals to assess exam fees on state chartered banks – effectively a tax on banks — are not new, and CSBS has successfully fought off similar provisions in the past.
At this point, the language has not appeared in any Senate proposals, and our goal is to ensure that the exam fee gains no traction in the Senate and that House members hear your objections as various House committees evaluate the exam fee.