Action Alerts

Action Alerts

Make a difference in our industry by participating in IBA Action Alerts on issues impacting you, your bank, and your community.

Community Reinvestment Act (CRA) Public Comment Deadline Extension

The Department of Financial and Professional Regulation has extended the date for submission of written public comments on the Banking Community Reinvestment Rule (38 IAC 345),the Mortgage Lenders Community Reinvestment Rule (38 IAC 1055), and Credit Union Community Reinvestment Rule (38 IAC 185) to March 6, 2024. IDFPR’s Proposed CRA Rules were published in the January 12, 2024 Illinois Register. Please send all public comments on these rules to:

Craig Cellini, Rules Coordinator
Department of Financial and Professional Regulation
320 West Washington, 2nd Floor
Springfield, IL 62786
(217) 785-0810
Fax #: (217) 557-4451
Craig.cellini@illinois.gov

State: Illinois CRA Draft Rules

March 17, 2023 - IBA Submits Comment Letter on Proposed Illinois CRA Rules.

The IBA has submitted a comment letter to the IDFPR on our members’ concerns regarding the IDFPR’s proposed administrative rules implementing the Illinois Community Reinvestment Act (Illinois CRA). Our letter requests that the final rule adopt reasonable examination fees and limit expenses, lengthen the implementation period, ensure consistency with federal CRA rules and exam schedules, eliminate discrepancies with the proposed rules for credit unions and mortgage landers, and more. The IBA also contends that the proposal expands the IDFPR’s authority beyond the scope of the law by covering bank affiliates and foreign-headquartered banks. Read the IBA comment letter.

January 26, 2023 - Comment Period Extended for Illinois CRA Rules; Public Hearing Announced

Following an IBA request made jointly with the CBAI and credit unions, the IDFPR has provided notice that it will extend the comment period for the Illinois Community Reinvestment Act (IL CRA).  The Department will now accept regular public comments on the proposed rules up until March 16, 2023.

The Department has also finalized dates and times for three public hearings for the recently-proposed rulemakings pertaining to the Community Reinvestment Act (CRA). Remote participation will be available via Web-Ex for those not able to attend in person.  There will be a formal announcement (Notice in the Illinois Register) that will contain the Web-Ex information/links/phone numbers. We will provide that information to our members when it becomes available. Provide the IBA with your bank’s comments by emailing Carolyn Settanni.

Hearing for the Banking Community Reinvestment Rule (38 IAC 345):

Date: March 2, 2023 | Time: 10:00 a.m.

Location:  Illinois Department of Financial and Professional Regulation, 555 West Monroe, Tenth Floor-Champaign Room, Chicago, Illinois 60661

Hearing on Mortgage Lenders Community Reinvestment Rule (38 IAC 1055):

Date: March 2, 2023 | Time: 2:00 p.m.

Location:  Illinois Department of Financial and Professional Regulation, 555 West Monroe, Tenth Floor-Champaign Room, Chicago, Illinois 60661

Hearing for the Credit Union Community Reinvestment Rule (38 IAC 185):

Date: March 8, 2023 | Time: 10:00 a.m.

Location:  Illinois Department of Financial and Professional Regulation, 555 West Monroe, First Floor-Multipurpose Room, Chicago, Illinois 60661

December 21, 2022 - Update: IBA Drafts Joint Letter Requesting IL CRA Comment Period Extension

In a joint letter with the Community Bankers Association of Illinois and the Illinois Credit Union League, the IBA wrote to Director of Banking Chasse Rehwinkel and Director of Financial Institutions Francisco Menchaca requesting an extension on the comment period deadline for the proposed administrative rules implementing the Illinois Community Reinvestment Act. Our letter asks for at least a 90-day comment period reflecting the federal Community Reinvestment Act rules comment period. The current comment period deadline is January 30.

The proposed administrative rules implementing the Illinois Community Reinvestment Act (CRA) can be found here: Illinois-chartered banks, Illinois-chartered credit unions, and covered residential mortgage lenders.

December 16, 2022- Illinois CRA Draft Rules Released

The IDFPR has issued proposed administrative rules implementing the Illinois Community Reinvestment Act (CRA) for Illinois-chartered banks, Illinois-chartered credit unions, and covered residential mortgage lenders.

Comments are due by January 30, 2022. The IBA will be submitting comments and will be seeking input from our members throughout the comment period. We expect that the IDFPR will hold public hearings as well.

The proposed Illinois CRA rules for Illinois-chartered banks and savings banks are modeled on the federal banking agencies’ regulations under the federal Community Reinvestment Act (with minor adjustments), combined with assessment factors and other elements specified in the Illinois CRA law. One example of a departure from the federal CRA regulations — the proposed Illinois CRA rules provide that banks may be subject to IDFPR enforcement actions, as well as “referral[s] to law enforcement or administrative authority,” for failures to comply with the Illinois CRA.

The proposed rules also provide that IDFPR examinations will be conducted in coordination with a bank’s primary federal financial supervisory agency and authorize the IDFPR to establish “alternative examination procedures” for banks rated “outstanding” under the federal or Illinois CRA.

Under the proposed rules, banks would have six months from the effective date of the final rules to comply with these requirements but would not be examined until one year after this implementation period ends — unless the IDFPR has sufficient cause for an earlier examination, such as a “substantial noncompliance” rating under the federal CRA or discriminatory or other illegal credit practices.

Federal: Credit Card Routing Mandate

August 2023

Credit Card Routing Bill Excluded from Sen. Defense Spending Bill But Action Still Needed!

In a win for the banking industry, the Senate passed a major defense spending bill last week without attaching the financial industry-opposed credit card routing bill to the legislation. Thank you to everyone who contacted their lawmakers and urged them to reject these harmful provisions! We still need your help though! The Senate version must now be reconciled with a version previously passed by House, providing yet another opportunity for the credit card routing language to be attached to the defense bill.

The financial industry is united in opposition to this legislation. Let’s continue the momentum against these harmful provisions! Please contact your lawmakers today and urge them to reject the so-called Credit Card Competition Act. And please share this call to action with your colleagues and your customers!

July 2023

Oppose Retailers’ Latest Attempt to Disrupt the Payments System! Act Now and Share with your Customers!

A decade after the Dodd-Frank Act’s Durbin amendment imposed government price controls and routing mandates on debit card transactions, merchants have perpetually failed to pass any meaningful savings along to consumers. Undeterred, Senator Durbin and other allies of big-box retailers are pushing new legislation that would impose new routing restrictions on credit cards.

And this week, retailers are attempting to attach their proposal to an unrelated bill on national defense spending. This bill imposes new costs on banks and their customers and threatens the security of our country’s payments infrastructure. It may also force lenders to scale back or eliminate credit card rewards, just as debit rewards were extinguished when the original Durbin amendment was implemented.

The financial industry is united in opposition to this legislation. Write to your lawmakers today and urge them to reject the so-called Credit Card Competition Act. And please share this call to action with your colleagues and your customers!

December 2022

The IBA joined partner organizations from throughout the country urging congressional leaders to oppose passing “Durbin 2.0” during the end-of-year “lame duck” session of congress. The IBA-opposed legislation would expand the Durbin Amendment’s rate caps to credit cards and would impose routing mandates on credit card transactions. Read the letter.

August 2022

Senators Roger Marshall (R-KS) and Dick Durbin (D-IL) have recently introduced S. 4674, legislation expanding government routing mandates to the credit card market. 

Over ten years ago, the Durbin amendment imposed a price cap on interchange rates that financial institutions can receive on debit cards and mandated financial institutions offer at least two networks for routing debit card transactions. Rather than save consumers money as promised, merchants pocketed the savings they reaped from the government price cap. At the same time, community banks lost a revenue source to support important consumer benefits like free checking and debit rewards.

This new legislation would impose even more restrictions on credit card transactions. Rather than allowing banks to choose networks offering the best customer experience, security, and resiliency, they would be forced to choose among options set by the Federal Reserve. This means banks would be forced to do business with companies that may be less safe for consumers and unreliable.

This bill also would require banks to accept all transactions a merchant requests, forcing banks to reissue cards to meet new retailer demands. Community banks, which tend to have a lower volume of credit card transactions, may be forced to no longer offer credit cards. This government intervention would alter their options and negotiating power in private business decisions.

Write your lawmakers today! Urge them to oppose S. 4674, the Credit Card Competition Act. Also please consider sharing this request with your colleagues, so that we can speak up in significant numbers against the bill.

Federal: Credit Union Expansion

June 2022

Ask Your Member of Congress to “REMOVE” all elements of the credit union charter enhancement bill (H.R. 7003) from a pending legislative package! Next week, the U.S. House plans to vote on an IBA-opposed credit union charter enhancement bill, H.R. 7003, as part of a larger legislative package, H.R. 2543 - Financial Services Racial Equity, Inclusion, and Economic Justice Act.

H.R. 7003, if included in the larger bill, creates a new loophole for tax-exempt credit unions and expands their field of membership and business-leading capacities. Credit unions are engaged in a grassroots campaign on this bill – we need bankers to match their efforts if we hope to stop the bill. Please contact your U.S. House member today HERE! Also, please consider sharing this request with your colleagues, so that we can speak up in significant numbers against the bill.

We Welcome Your Feedback

We Welcome Your Feedback

We want to learn your thoughts and concerns as you read and digest the issues. Learning different points of view as it impacts your bank and community gives us an even better understanding and clear direction when working with our elected leaders and regulatory agencies. Your feedback is kept anonymous.

Submit your thoughts and concerns here.

Archived Action Alerts

State: Retailers’ Plan to Shift their Fraud Losses to Banks

April 2022

We are providing you with an update on the issues related to our grassroots action alert last week. We are pleased to report that the financial industry has successfully stopped an attempt by the Illinois retail industry to shift store fraud loss liability to card issuers, including banks.

Amendments to HB 1091 filed last night and this morning remove IBA-opposed language that would have allowed merchants to recover card-related fraudulent purchase losses directly from card issuers. The amendments also remove IBA-opposed language that would have restrained card issuers from following their dispute resolution responsibilities under federal regulations.

The amendments instead add language requiring card issuers to consider “a merchant’s timely submission of compelling evidence under the applicable dispute management guidelines of the card association with whom the merchant maintains an agreement.” This language goes on to require merchants to acknowledge their own obligations under similar network agreements. We also reached an agreement on parts of the legislation related to stored value card fraud.

Legislative successes like this are not possible without grassroots involvement by front-line bankers across Illinois. We sincerely thank all bankers who quickly took action by contacting their state senators. As the IBA lobbied against the bill over the last five days, it was clear that bankers’ outreach made a difference. Your calls and emails had a tremendous impact in supplementing our advocacy team’s efforts on-the-ground efforts at the state capitol.

If you have questions or comments, please contact the IBA's Government Relations team.

March 2022

Please contact your Senator today! Ask Them to VOTE “NO!” on the Retailers’ Plan to Shift their Fraud Losses to Banks!

The retail crime bill pending in the State Senate includes language that will inappropriately shift liability to banks, thrifts, and other card issuers for fraudulent merchant transactions. Senate Amendment #1 to House Bill 1091 primarily addresses organized retail crimes. The retail industry added the last-minute language that would make banks responsible for fraud losses when they restore a customer’s account after a fraudulent purchase is made or when a bank identifies fraud and freezes a transaction. In these situations, the legislation would require banks to restore the customer’s funds and reimburse the merchant for their losses. In addition, the bill places confusing and unworkable limits on prepaid and other stored value cards. The bill could be heard in the Senate Executive Committee as early as today, and if it passes the committee, it could be considered on the Senate floor very quickly. We ask all bankers to contact their State Senators immediately on this issue.

Take action in three easy steps:

  1. Look up your state senator by address here. Then view our Senate contact list to find your Senator’s phone number and email address. If you have your Senator’s direct mobile number, call or text them as well.
  2. Use our talking points below or our sample email HERE to express your strong opposition to your Senator.
  3. Finally, contact the IBA Government Relations team to let us know who you contacted, and please share any feedback you received from your Senator or their staff.

TALKING POINTS: Remove Fraud-Liability Shift Language in HB 1091 (Sen. Glowiak Hilton)

  1. This bill contains provisions inappropriately shifting big-box retailers’ fraud costs onto consumers’ financial institutions.
  2. This could amount to a double loss for the financial institution: they already pay to restore their consumer’s loss from fraudulent purchases that occur at a retail location. Then, under this bill, financial institutions would ALSO be required to directly pay merchants for fraudulent purchases that occurred on the retailer’s watch.
  3. Unlike the retailer, a financial institution or card issuer is not present for the acts of fraud contemplated in this legislation. And retailers do not protect their consumers in the same ways that banks do. Financial institutions spend billions per year and have thousands of dedicated employees across the country specifically to protect American consumers’ accounts.
  4. It is troubling that big-box retailers, who have opposed adopting bank-level consumer protections, are attempting to shift their own losses to financial institutions – in instances where the financial institution is simply stopping fraud and restoring their customers’ accounts.
  5. The bill also adds confusing consumer restrictions related to stored value cards like prepaid cards. These additions will harm legitimate customers purchasing gift cards by limiting their purchasing options.
  6. The banking related provisions of HB 1091 will harm consumers. They pad big-box retailers’ profits, creating even fewer incentives for retailers to protect their customers from fraud. The bill will create new, unnecessary scrutiny on customers experiencing legitimate fraudulent account activity.
  7. The card-related provisions of this bill have nothing to do with the bill’s underlying objectives. The Senate should COMPLETELY REMOVE the card-related provisions from this legislation.

Federal: Federal Home Loan Bank System

October 2022

The Federal Housing Finance Agency (FHFA) has extended the comment period until October 31 to provide input on FHLBank System at 100: Focusing on the Future, a review of the FHLBanks’ structure and mission. 

The IBA recently submitted our own letter. It describes how the FHLBank Chicago promotes stability in banking and empowers Illinois banks and thrifts to expand services in their communities. The letter emphasizes the crucial role that the FHLBanks play in affordable housing, including working with local banks to develop affordable rental units throughout Illinois. 

We urge the FHFA to refrain from adding additional non-depositories to the FHLB membership. “Shifting the System away from [its] well-tested structure — and worse, towards the priorities of untested, unregulated, or illiquid players in the financial market — jeopardizes the FHLBank System’s stability and its ability to serve local communities,” the letter says. 

Finally, we stress the importance of the System’s regional structure and local leadership. “Continued local control of the regional banks ensures that they are responsive to community needs in our rapidly-shifting financial marketplace,” the letter states. 

Share your bank’s story by October 31! The FHLBank of Chicago has created a toolkit for bankers to assist with the process. Please use thetoolkit and then submit your comments to share your bank’s story about how the FHLBank System benefits your communities! 

Please share a copy of your submitted letter with us and the Federal Home Loan Bank of Chicago. 

If you have questions, please contact the IBA's Government Relations team.