“ICBA is adamantly opposed to having only a single banking regulator for federally chartered banking institutions. It is a flawed approach that would ultimately disadvantage our nation’s more than 8,000 community banks and the cities, towns and rural areas across America which they serve. Instead, ICBA favors a federal bank regulatory approach that brings balance and perspective through multiple agencies. ICBA also believes strongly in maintaining the dual-banking system because it allows for a diversity of financial institutions, is sensitive to financial institutions of various complexity and size and promotes consumer choice. The dual-banking system has served our nation well for generations and helped create a unique banking structure that is the envy of the world.

“Multiple regulators serve as a check and balance over the use (and sometimes the abuse) of power. The creation of a single regulator is both dangerous and shortsighted. We should no more eliminate the checks and balances in the current bank regulatory system than eliminate the multiple branches of government that are the foundation of our country. Overwhelming concentration of power in any governmental or economic sector is counterproductive and unwise. Further, ICBA supports independent bank regulatory agencies because they are more insulated from political pressures, and can deal more objectively with those they are charged to regulate.

“Congress and the Administration must focus on addressing the challenges posed by unregulated lenders and investment banks that helped create the systemic risks that have contributed to the financial crisis. New regulatory restructuring rules should target systemic-risk institutions to reduce the dangerous concentration of financial and economic assets.

“ICBA believes it is important to take our time implementing reforms to make sure we get it right for the long term. ICBA will work with Congress and the Administration to ensure that any changes to our current financial regulatory regime recognize the critical importance of the dual banking system and our nation's community banking sector.”