Maintain a Deposit Insurance Fund that is stable and properly calibrated to risk. The FDIC should continue to use a risk-based approach when setting assessments and ensure its methodology is based on modern risk principles. Make deposit insurance assessments tax-deductible. Congress should reverse the Tax Cuts and Jobs Act of 2017’s sliding-scale method for determining the deductibility of FDIC assessments. Evaluate the potential costs and benefits of offering additional insurance for purchase by individual banks. Allowing banks to purchase excess deposit insurance would likely result in lower costs for banks relative to excess deposit insurance products provided by the private sector. The FDIC should evaluate the potential costs and benefits of such an approach. Bank Resolutions Broaden the scope of considerations applied in the determination of “least cost” to include potential contagion or other unwanted impacts. Congress should allow the FDIC to consider the cost of resolutions strategy on a wider range of banks or the industry, not just the deposit insurance fund. Enhance community bank participation in resolutions to preserve essential banking services. Congress should allow the FDIC to consider the cost of resolutions strategy on communities and provide the FDIC with the power to balance the least cost test for community bank failures with options to mitigate negative impacts, such as loss of essential banking services, on the relevant communities. Open resolution-associated asset auctions to a greater diversity of investors. This FDIC change would enhance fairness to the failed bank bidder qualification process, increasing the spectrum of institutions permitted to bid on failed institution franchises and assets. Publicly release resolution approaches considered in a given case and their respective estimated costs. FDIC should release the resolution approaches considered and the estimated costs of each failure to improve the transparency and accountability associated with failed institution resolutions. The Treasury has announced they are looking to reform Currency Transaction Reporting requirements. Currently, only 3-6% of reports are ever viewed — the system is flooded with reports, making it hard to detect actual criminal activity. We are urging an increased threshold for reporting. The $10,000 threshold has been in effect since the origination of the requirement. If increased by inflation, it would be $73,000. We are asking for an increase and that the increase be indexed to more in accordance with inflation. We are also seeking streamlining of the exemption and reporting processes. Bills have been introduced to increase regulatory asset thresholds and index them for inflationary growth. Congressman Barr (R-KY) has a draft that increases the current $10 billion threshold to $50 billion. The Senate doesn’t appear eager to take the threshold that high. Congressman Barr is trying to find what increase would pass. The Supervisory Modifications for Appropriate Risk-Based Testing Act of 2025 by Reps. Timmons (R-SC) and Foster (D-IL) would increase the threshold under for a limited-scope examination after an on-site, full-scope exam from $3 billion to $6 billion. The Tailored Regulatory Updates for Supervisory Testing Act of 2025 (TRUST Act), sponsored by Reps. Moore (R-NC) and Torres (D-NY), would increase the total asset threshold under which institutions qualify for an 18-month exam cycle from $3 billion to $6 billion. In Colorado, we just wrapped up a five-day special session called by Gov. Polis. The session addressed the budget shortfall and artificial intelligence. In 2024, Colorado passed the first AI law with 24-205. In his signing letter, Gov. Polis stated the structural flaws in the legislation would have to be addressed. During the 2025 General Session, legislation failed to pass committee to fix gaps in artificial intelligence law. During the special session, tech and business groups could not reach a consensus on language to fix the law. A bill was passed to extend the implementation deadline for the effective date of the AI law to June 30, 2026. We will now debate artificial intelligence during the 2026 General Session. Despite the fast pace of change, we stand ready to defend the industry. If you have questions on these or any other issues, don’t hesitate to contact Alison at alison@coloradobankers.org or me at jenifer@coloraobankers.org. 5 Colorado Banker
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