Presented below are various Federal rulemaking activities that WBA has, or is planning on commenting on. If you have any questions or input on the topics below, please contact WBA’s Scott Birrenkott at While WBA will be commenting on the topics below, we highly encourage each bank to submit its own comments to go on record about the impact each rule will have upon the institution and its customers. 

CAMELS Rating System 
On Feb. 28, 2020 WBA commented on the Federal Deposit Insurance Corporation (FDIC) and Board of Governors of the Federal Reserve System’s (agencies) request for information on the Uniform Financial Institutions Rating System commonly referred to as CAMELS ratings. The agencies requested comments regarding the consistency of assigned CAMELS ratings, as well as feedback on the current use of those ratings in bank application and enforcement action processes. WBA wrote in support of the agencies’ efforts to review the CAMELS rating system and encouraged formal rulemaking to open the opportunity to comment on potential new frameworks. 

Community Reinvestment Act 
On Dec. 12, 2019 the OCC, Treasury, and FDIC (agencies) issued joint notice of proposed rulemaking (rule) to modernize Community Reinvestment Act (CRA) regulations. The agencies have proposed to create new criteria for which activities qualify for CRA credit, update where activities count for CRA credit, create a new method for measuring CRA performance, and revise CRA-related data collection, recordkeeping, and reporting requirements. WBA is concerned that the proposal will incur significant costs and burdens to meet the new standards. Comments are due April 8, 2020. 

Brokered Deposits 
On Feb. 10, 2020 the FDIC issued a notice of proposed rulemaking on revisions to its regulations relating to brokered deposits restrictions that apply to less than well capitalized institutions. Section 29 of the Federal Deposit Insurance Act restricts the acceptance of deposits from a “deposit broker” when an institution is less than well capitalized. The term “deposit broker” is not well defined, requiring reliance upon a multitude of FDIC staff guidance and advisory opinions. FDIC has issued a notice proposing to formalize that guidance. WBA is concerned that while this would provide clarity, it would formalize a definition of “deposit broker.” Comments are due April 10, 2020. 

For copies of this or other WBA comment letters, please contact the WBA Legal Department at 608-441-1200 or visit