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FASB Responds to Community Banker Concerns

FASB’s Chairman, Russell Golden, responded to community banker concerns about his disturbing comments regarding the cause of the financial crisis and the proposed Current Expected Credit Loss (CECL) model. Golden has requested a meeting during the first quarter of 2016 to discuss those concerns.

In letters to FASB, CBAI and ICBA criticized Golden’s apparent lack of understanding of the role community banks paid in the financial crisis and the CECL model’s applicability to community banks. CBAI stated in its letter. “In the span of four sentences you cite community bank failure statistics followed by your conclusion that ‘Clearly community banks have been a major part of the problem’ and that this is the reason why ‘all lending institutions should be included in the new guidance.’ This flawed reasoning is comparable to citing elder financial abuse statistics and then blaming senior citizens for that abuse.”

Golden’s response letter stated “My remarks are neither intended to address the cause of the financial crisis nor suggest that community banks had a role in the crisis.” CBAI welcomes Golden’s admission that community banks were not the cause of the financial crisis which is why CBAI strongly believes community banks should not be ensnared in a regulatory solution (complete with an added burden) to a problem they did not cause. 

CBAI letter stated, "Too-big-to-fail (TBTF) banks, not community banks, caused the financial crisis. The banking system and economy was threatened with massive destruction by the greed and excess of these mega banks not community banks." CBAI’s letter continues, “What is not needed in FASB’s response to the financial crisis is a one-size-fits-all CECL model being imposed on community banks. What is needed is an exemption from the proposed CECL model for banks under $10 billion in assets. An exemption would alleviate the concerns of community banks regarding inappropriate and expensive provisioning that does not fairly present the risk profile of their assets.” CBAI then detailed the parameters of a simple and straightforward alternate approach.

CBAI thanks the many Illinois community bankers who responding to the recent Action Alert to encourage FASB reconsider their proposed CECL model. CBAI also looks forward to a continued dialogue with FASB, the goal of which will be to shield Illinois community banks from the harmful effects of this inappropriate accounting standard. Read CBAI Letter to FASB. Read ICBA Letter to FASB. Read FASB Response.

January 5, 2016