In late July, I was part of a small group of state bankers association representatives asked to participate in a meeting at the Consumer Financial Protection Bureau (CFPB) related to the Dodd-Frank Act’s pending Section 1071 Small Business Data Collection requirements. Meeting participants included association representatives from Georgia, Massachusetts, Missouri, Nebraska, New Hampshire, and Oklahoma as well as from the ABA. We were joined at the CFPB’s headquarters by 16 CFPB representatives who are responsible for implementing these regulations.
You will find the NBA’s formal comments to the CFPB’s Request for Information Regarding the Small Business Lending Market (Docket No. CFPB-2017-0011) at http://bit.ly/S1071Ltr. Below are a few personal observations about our meeting and subsequent discussions.
After returning to Nebraska, I spent a great deal of time mulling over the meeting and considering how our industry can proactively address the inherent challenges and assumptions held by some within the bank regulatory community.
First and foremost, we must remain vigilant on the legislative front. As we have learned all too well as a result of Dodd-Frank, regulations designed for larger, more complex financial institutions always seem to flow downhill, impacting every institution in America, regardless of their business model. Secondly, we need to find ways to help better educate young staffers who are starting their careers in Congress or within the regulatory agencies. We routinely host a “Take Your Lawmaker to Work” week, but how often do we spend time educating our young regulators? We must find ways to help them better understand the complexities of our core systems, why a combine costs $300,000 plus, why a bank may not loan the requested amount to a commercial borrower and how this may actually be better for the borrower’s business, how a bank can successfully operate with four staff members, or that our rural branch locations can operate efficiently even though they are 200 miles apart.
Finally, the banking industry must seek new opportunities to actively educate and engage the next generation about our industry. We need to think about our industry’s marketing efforts and find new communication strategies that will resonate with Generations X, Y, and Z. Banks are not only the credit engine of our economy, but also a fundamental component of every life-changing event we experience—from purchasing our first car or home and saving for college to financing a new business and ensuring our dollars are safe from hackers and crackers. Our next generation—whether they are working as a manufacturer in David City, a rancher in Mullen, or a bank regulator in Washington, D.C.—must understand that Nebraska banks are their partners in success and that they can “Bank On Nebraska” financial institutions for financing their future.
Proud husband, father of two, and the president/CEO of the Nebraska Bankers Association (NBA). Avid about growing the Cornhusker State's banking industry.