Talking Points

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 language is included in House Appropriations legislation. Additionally, the House Budget Committee is considering its FY 2018 Budget Resolution, which contemplates provisions of the CHOICE Act that would cut the federal deficit by $14 billion over 10 years. These provisions may include the problematic provisions that subject the Fed and FDIC to appropriations and require them to charge exam fees.

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.