Pub. 10 2019 Issue 2

Summer 2019 13 West Virginia Banker Perhaps that’s why when Promontory Interfinancial Network queried bankers for its second-quarter Executive Business Outlook Survey, executives from the 390 banks that responded pointed elsewhere when asked to identify the law’s most impactful provision. Yet, the provision involving SIFI directly impacts only a small number of commercial banks based in the United States — the dozen-plus with between $50 billion and $250 billion in assets. Perhaps that’s why when Promontory Interfinancial Network queried bankers for its second-quarter Executive Business Outlook Survey, executives from the 390 banks that respond- ed pointed elsewhere when asked to identify the law’s most impactful provision. Thirty-seven percent of respondents said the law’s provision that allows most reciprocal deposits to be treated as non- brokered deposits ranked highest on a scale of one to five, placing it first among the seven other provisions tested. It was up against stiff competition. The other provisions included those that eased the qualified mortgage rule, ex- tended the regulatory exam cycle and simplified capital rules for community banks, among others. “We think the change to reciprocal deposits is great,” says Christopher Cole, executive vice president and senior reg-  Relief for Community Banks Continued on Page 14