Pub. 2 2012-2013 Issue 3

O V E R A C E N T U R Y : B U I L D I N G B E T T E R B A N K S - H E L P I N G C O L O R A D A N S R E A L I Z E D R E A M S November • December 2012 5 It’s Time to Stand Up and Defend Our Industry Our industry needs to actively monitor the impending rules of Dodd Frank, which will be drafted in the coming months. Dear CBA Members, Recently a number of Colorado bankers traveled to Washington D.C. for what turned out to be a very informa- tive and important trip. We met with a number of other bankers from several western states. We were provided a briefing from the American Bankers Association. We learned about Basel III and the potential harmful impacts it may have on community banks as it relates to how we manage our capital. We discussed the rules coming our way from Dodd Frank and the serious challenges these rules will present to our industry, especially regarding mortgage lending. Perhaps the most interesting and frustrating part of our trip was our visit with the regulators. We met with the Department of Treasury where the OCC is housed. We also met with the Federal Reserve, the FDIC and the Consumer Financial Protection Bureau. We explained in great detail how the new onerous rules housed within Dodd Frank would impact banking, but also the negative unintended consequences these rules will have on our customers and the economy. The perfect storm of the convergence of mortgage rules written by the CFPB and the capital rules from Basel III will make it very difficult for community banks to underwrite mortgages and hold them on our books. While all the regulators we met with said they were listening and encouraged us to send detailed comment letters highlighting our concerns, none of them seemed to be in position to reverse the direction in which these rules are headed. The key issue is that the rules, except for Basel III, are required by Dodd Frank. We also met with many of our Colorado Members of Congress and expressed our concern and asked them to consider reforming parts of Dodd Frank. Regardless of what happens in this fall’s election, our industry needs to actively monitor the impending rules of Dodd Frank, which will be drafted in the coming months. Our elected representatives need to understand the impact these rules will have. There has never been a more important time for bankers to regularly communicate with our legislators and stand up and defend our industry and our customers. In particular, watch the rules pertaining to qualified mortgages and qualified residential mortgages. These rules, some 5,000 pages of them, will make it very difficult to underwrite mortgages, especially for our small business customers and our low and moderate income customers whose personal income is sometimes difficult to document. The Consumer Financial Protection Bureau may actually end up hurting the consumers they are charged with protecting.  Bruce Alexander, CBA Chairman President & CEO, Vectra Bank Colorado