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Economic Growth and Regulatory Paperwork Reduction Act (EGRPRA) Public Meeting: Panel 3

Channel: Federal Reserve Published: 2026-04-08 09:52
Federal Reserve

This Federal Reserve panel is a discussion about how banking regulators can facilitate innovation without weakening safety and soundness. The speakers largely agree that community banks need better third-party risk management, more practical supervisory guidance, and easier paths to adopt technology, form new banks, and share infrastructure—while one speaker warns that “facilitating innovation” should not become a backdoor for crypto or weaker rules.

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Detailed summary

This panel from the Federal Reserve’s EGRPRA public meeting is centered on how regulation can support innovation in community banking. Todd Vermilier, the moderator, frames the session as a discussion of “facilitating innovation,” then invites remarks from Michael Emancipator of ICBA, Kelvin Chen of the Consumer Bankers Association, Philip Basil of Better Markets, and David Schroeder of the Community Bankers Association of Illinois. The discussion repeatedly returns to one core tension: how to let banks modernize quickly while preserving safety, soundness, consumer protection, and supervisory accountability. Michael Emancipator argues that community banks are naturally innovative but are constrained by vendor concentration, examiner caution, and burdensome due diligence. …

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Main takeaways

  1. The panel’s shared thesis is that innovation should be enabled inside the regulated banking system, not pushed into unregulated or less transparent channels.
  2. Community banks face unusually heavy dependence on third-party vendors, which makes supervisory expectations and due diligence a major bottleneck.
  3. Several speakers want more shared standards, clearer guidance, and better use of existing supervisory authorities rather than entirely new rulebooks.
  4. Philip Basil is the main dissenting voice, warning that innovation rhetoric can be used to weaken rules or advance crypto-related agendas.
  5. A major structural issue discussed is the decline in de novo community bank formations and the need to make new chartering materially easier.
  6. The group repeatedly argues that smaller banks should be able to share resources, vendors, and examination learnings to reduce cost and friction.
  7. The panel frames supervision as a risk-management exercise, not a punitive or “gotcha” process.
  8. There is broad agreement that regulators should focus more deliberately on community banks because they are tied closely to local lending and main street credit.

Market read by horizon

Short term

Near term, the actionable setup is incremental supervisory easing around third-party risk, due diligence, and information sharing rather than big legislative change. The immediate risk is that innovation gets pushed out of the regulated banking system if exam friction stays high.

  • The immediate tactical debate is around third-party risk management: clearer FAQs, faster guidance, and more workable supervisory expectations could reduce near-term friction.
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  • A near-term catalyst is whether agencies use sub-regulatory tools—guidance, FAQs, examiner coordination, and shared standards—rather than waiting for major rulemaking.
  • Community banks are currently constrained by vendor concentration and examiner caution, so the most actionable setup is relief on due diligence and service-provider oversight.
Mid term

Over the next few months, the likely path is gradual improvement through guidance, FAQs, and shared standards if agencies decide to prioritize community bank operations. Confirmation would be more practical examiner behavior and reusable frameworks; failure would leave de novo formation and vendor adoption constrained.

  • Over the next several weeks to months, the base case is incremental supervisory reform rather than sweeping legal change, especially on TPRM and service-provider oversight.
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  • If the agencies adopt more shared due diligence standards or clearer information-sharing rules, community banks could broaden vendor use and move faster on digital projects.
  • The panel suggests that de novo activity may improve only if capital expectations, operational burdens, and technology costs become more manageable together.
Long term

Structurally, the panel argues that community banks can remain viable only if regulation evolves into a platform for safe experimentation rather than a barrier to entry. If that does not happen, innovation and financial intermediation will keep migrating toward less supervised channels and large incumbent platforms.

  • Structurally, the panel argues that community banks remain essential to main-street credit, small-business lending, and relationship banking.
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  • The long-run implication is that banking innovation will be healthiest when it is embedded in a supervised ecosystem with shared standards and accountable third parties.
  • If regulators modernize their frameworks successfully, community banks could preserve their role even as fintech, AI, and alternative payment models reshape the industry.
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Key claims (9)

BULLISH bank regulation and fintech adoption community banks

Community banks are innovative but face structural barriers from vendor concentration and supervisory caution.

Michael says community banks rely heavily on third-party providers and are disadvantaged by concentration and examiner behavior.

BULLISH third-party risk management community banks

Shared due diligence frameworks could reduce duplicated compliance work and help banks adopt vendors more safely.

ICBA proposes standards and certification-based acceptance to lower burden while preserving oversight.

BULLISH supervision and innovation bank-fintech partnerships

Modernizing confidential supervisory information rules would make bank-fintech collaboration faster and more effective.

Michael argues fintech partners need supervisory context to fix problems without breaking confidentiality rules.

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Assets discussed (8)

community banks
BULLISH other

All panelists argue community banks should be supported through better regulation, lower friction, and more access to technology.

fintech
BULLISH other

Presented as a useful source of innovation, though only when supervision and risk management are workable.

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Speakers

HOST Todd Vermilier SPEAKER Michael Emancipator SPEAKER Kelvin Chen SPEAKER Philip Basil SPEAKER David Schroeder

Interview (4 Q&A)

open discussion

Would any of you like to react to what a panelist said or put additional ideas on the table?

de novo bank formation

How do we get back to a world where we're seeing more de novo community bank activity?

The speaker connects de novo activity to technology costs — noting that technology should get cheaper over time, similar to flat-screen TVs. They argue that one reason for few de novos is the significant capital required, partly to offset the cost of personnel and technology until the bank becomes viable. If technology were cheaper and easier to onboard, less capital would need to be burned through to meet regulatory requirements.

regulatory innovation expertise

Was there outside expertise from companies brought in to have conversations with banks using the technology, to get everyone in the same room during the process?

The respondent says they were trying to do a lot more of that — having offices of innovation where outside firms and non-banks would come to the board to talk about what they were doing, bringing in other regulators and consumer regulators to understand how the world is shifting. However, it's their understanding that this has become less frequent across the regulatory space in more recent administrations, which has detriments — for example, dealing with live legislation on stable coins without a shared understanding of how stable coin operators make their money.

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Where this transcript pushes against consensus

  • Philip Basil’s view that rules must remain strong conflicts somewhat with the others’ emphasis on easing supervisory friction and reducing burdens.
  • There is tension between calls for more transparency around service providers and the concern that regulators should not pick winners and losers.
  • Some speakers want more explicit rules and FAQs, while others stress principles-based flexibility; the panel does not fully reconcile that tradeoff.
  • The group agrees on innovation goals, but not fully on whether crypto-related activities should be treated as part of that agenda or kept out of it.
  • There is an unresolved practical question about how far regulators can go in using existing authority without formal rule changes.

Topics

community bank innovationthird-party risk managementsupervisory guidanceconfidential supervisory informationBank Service Company Actde novo bank formationcapital requirementsconsortia and resource sharingcrypto and banking regulationregulatory culture

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