ICBA Announces Its “Plan for Prosperity” Legislative Agenda for Regulatory Relief by Supporting Key Provisions of the AMHC Endorsed Grimm Bill

The ICBA announced its legislative agenda in which it identifies its priorities for the new Congress. Interestingly, only two items peculiar to mutual holding companies are included in its comprehensive list. One relates to MHC dividend waivers. The other supports extending the small bank consolidated capital requirement exemption to S&L holding companies and raising the threshold to $5 billion in assets from $500 million. Both provisions have been in the Grimm Bill since its introduction. The ICBA excerpt to its release dealing with mutual holding companies is copied below.

We consider this progress as at least one national trade group has gone on record in support of legislative action to approve dividend waivers and expand the small bank holding company capital exemption. Both these measures are key provisions in the AMHC endorsed Grimm Bill.


Support Mutual Banks with New Charter and Dividend Rules:

  • Allow the Office of the Comptroller of the Currency to charter national mutual banks to provide flexibility for these institutions to choose the charter that best suits their needs and the communities they serve.
  • In addition, mutual holding companies that have public shareholders should be allowed to pay dividends to their public shareholders without having to comply with numerous “dividend waiver” restrictions as required under a recent Federal Reserve rule. The rule makes it difficult for mutual holding companies to attract investors to support their capital levels.
  • Easier payment of dividends will ensure the viability of the mutual holding company form oforganization, benefiting the communities they serve.


Support Additional Capital for Small Bank Holding Companies:

  • Require the Federal Reserve to revise the Small Bank Holding Company Policy Statement, a set of capital guidelines that have the force of law.
  • Applying the policy statement to both bank and thrift holding companies and increasing the qualifying asset threshold from $500 million to $5 billion would make it easier for small bank holding companies to raise additional capital by issuing debt.
  • This will help ease and simplify capital requirements for small bank and thrift holding companies.