The Idaho Bankers Association, along with 44 state and regional associations and the Independent Community Bankers of America (ICBA), recently submitted joint comments in response to the OCC, Federal Reserve, and FDIC’s request for information on payments fraud. Together, this group represents thousands of community banks nationwide and is committed to ensuring the regulatory framework reflects the realities our institutions face on the front lines.
Collaboration is Key
Fraud does not stop at state borders, and neither should our response. Our comments emphasized that meaningful progress requires coordination among federal agencies, state regulators, law enforcement, and financial institutions of every size. At the same time, we urged regulators to recognize the resource constraints of community banks when designing collaborative efforts.
Educating Customers Where It Matters Most
Because of their close customer relationships, community banks are uniquely positioned to educate consumers and businesses about fraud risks. We highlighted the importance of in-branch materials and direct engagement, especially for elderly customers, rural communities, and small businesses where internet access may be limited.
Right-Sized Regulation for Community Banks
Our joint comments underscored that examiner expectations and fraud regulations must be appropriately tailored. A one-size-fits-all approach risks overburdening community banks. Check fraud remains a top concern, and we recommended targeted updates to Regulation CC—such as extending fraud return deadlines and clarifying definitions while protecting essential tools like hold times.
Smarter Tools and Data Sharing
Our comments call for affordable, automated tools that integrate with services community banks already use. Safe harbors for data sharing would encourage broader participation, and new services such as a fraud contact directory, check image verification, and confirmation of payee would strengthen our collective defenses.
Our Commitment
As associations representing community banks across the country, we remain united in our efforts to combat payments fraud. The IBA, alongside our peers and the ICBA, will continue working with regulators to protect customers while ensuring that new requirements are practical and balanced.