On April 23, 2019, the Community Bankers Association of Illinois (CBAI) commented on the Federal Deposit Insurance Corporation’s (FDIC) Advanced Notice of Proposed Rulemaking on Deposit Rate Caps in the brokered-deposit regulations. CBAI stated that the Deposit Rate Caps do not reflect either the realities of competitive funding or investing opportunities faced by community banks. CBAI is particularly concerned about how the National Rates are being inappropriately calculated for Rate Caps purposes, and how even “well capitalized” banks are being adversely impacted by the application of the Rate Caps in the analysis of liquidity during safety and soundness examinations. CBAI believes the Deposit Rate Caps are also aggravating an already significant competitive imbalance against community banks. CBAI urged the FDIC to reexamine and modify the brokered deposit restrictions to avoid the harmful consequences of these regulations on community banks. Read CBAI Comment Letter.