Page 44 (Congress of the illnitch Satan‘s musliiugiuu. {NE 20515 March 24. 2020 The Honorable Randal K. Quarles Vice Chair for Supervision Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue. NW. Washington, D.C. 20551 The Honorable Jelena McWilliams Chairman Federal Deposit Insurance Corporation 550 17th Street, NW. Washington, DC. 20429 The Honorable Joseph M. Otting Comptroller of the Currency Office of the Comptroller ofthe Currency 400 2th Street. SW. Washington, DC. 20219 Dear Vice Chair Quarles, Chairman McWilliams, and Comptroller Otting: On March 13. 2020, President Trump declared the COVlD-l9 outbreak in the United States a National Emergency. Financial institutions are well positioned to stimulate and sustain critical economic activity with access to credit to struggling small businesses. families. and individuals, but more can be done to mitigate the economic impact of the COVlD-l‘) outbreak in our communities. Section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (EGRCCPA) directs the agencies to set a Community Bank Leverage Ratio (CBLR) between 8 and 10 percent. The CBLR offers relief from overly complex capital rules for qualifying community banks with assets of less than $10 billion that maintain a minimum ratio of tangible equity capital to average total consolidated assets. Banks that exceed the OBLR are deemed “well capitalized". and exempt from complex risk-based capital requirements, including Basel [11, which are intended for the largest and most complex institutions. The interagency proposal for the CELR is currently set for 9 percent, which cuts short the potential to provide needed lending to consumers and businesses. Additionally, a 9 percent leverage ratio is well above the current leverage ratio requirement for well-capitalized banks. A CBLR of 8 percent would draw in some 400 additional community banks and support credit in the thousands more communities across the country. That is why we believe a CBLR of 8 percent would be more than adequate to ensure community banks benefit from capital simplification while retaining enough high-quality equity capital to sustain and increase credit flows for vulnerable small businesses. We strongly urge you to use the full measure of discretion afforded by Congress to maximize capital simplification and regulatory relief for the greatest number of community banks consistent with the safety Page 45 and soundness of our banking system. The impact of your choices will extend to community financial institutions and the millions of businesses and consumers they serve. Thank you for your attention to this matter. Sincerely. \ ”I \Q 6&5? Denver Riggleman Member oi‘C-ongress Scott Ti pton Member ol’Congress Bill l-Iuizenga Member of Congress Barry Loudermilk Member ot'Congress Q.“- (flw— (72>L W fiver Ann Wagner ' Member of Congress John Rose Member of Congress Mm Frank Lucas Member of Congress Dwrcfl W David Kustoff Member of Congress Wee Blaine Luetkemeyer Member of Congress