2026 Pub. 14 Issue 3

systems against cyber threats, while sustained advocacy has led to progress in the battle against check fraud. With artificial intelligence raising new vulnerabilities, ICBA engaged with the White House and secured invitations to meetings to discuss new AI threats that had previously been extended only to the largest financial institutions. ICBA has also engaged the Treasury Department, Project Glasswing participants, community bank vendors and other organizations while releasing a new Community Bank AI Security Readiness Guide to help community banks navigate the current threat landscape. KEY CHALLENGES REMAIN 1. Threats From Stablecoin Yield and Nonbank Entities The current favorable environment for digital assets platforms and other nonbank competitors seeking bank-like powers without bank-like regulation has led to all-hands-on-deck battles over stablecoin yield, Federal Reserve master account access, and the OCC’s redefined national bank trust charters — with a new ICBA advocacy campaign warning of the risks posed by the crypto sector’s unpopular push for less accountability. While we push for a stronger prohibition on payment stablecoins’ ability to pay interest and yield as the debate over the CLARITY Act continues, we are urging policymakers to pause new policies on these issue areas to ensure “like risk, like regulation” for nonbank entities. We also continue to push back against the FDIC’s approval of new industrial loan companies from Edward Jones, Stellantis and others, while working to advance bipartisan Senate legislation to close the ILC loophole. 2. Keeping up the Push for Credit Union Parity We’ve seen growing interest among policymakers in the credit union tax exemption in recent years, including an ICBA-supported National Credit Union Administration proposal to facilitate credit union conversions to mutual banks, which aligns with our guide to conversion. To keep up the momentum, this year we unveiled our “Illusionists” advocacy and marketing campaign to pull back the curtain on growth-obsessed credit unions, complementing our data analysis on how credit union acquisitions of community banks are harming local communities. 3. Defending CDFIs Amid a Treasury Department review of community development financial institutions and ongoing challenges to the CDFI Fund’s budget, ICBA has worked hard to address these political pressures and ensure policymakers understand the role of these institutions in serving local communities. While policymakers have released withheld 2025 funding and fully funded the CDFI Fund for 2026, ongoing engagement on this critical sector will remain essential. 4. The Threat of Credit Card Restrictions Despite repeated success in fighting off Durbin-Marshall credit card routing mandates and misguided efforts to impose a credit card rate cap, these threats remain at the federal and state levels. ICBA and state community banking groups have commended Colorado’s veto of an unworkable interchange law, supported the Illinois General Assembly’s vote to delay its misguided law by another year and backed OCC efforts to preempt state restrictions. We will keep fighting federal and state threats to community bank credit card services. THE WAY FORWARD With our industry facing these high-stakes challenges every day, we will have to remain connected and fully engaged to ensure success. But in reviewing our latest advocacy wins — some of which required years of hard work — we see a track record of strength and achievement that we can sustain through the second half of this year. Thank you for all you have done to move the ball forward on so many critical issues. And let’s keep up the hard work to ensure our industry can continue helping Main Street communities thrive. Rebeca Romero Rainey is president and CEO of ICBA. Community Banker 23

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