Everyone has an interest in policies that will foster a strong economy and sustainable job growth. Some steps have been taken, but we are not getting the job done.
Over half of U.S. job growth is initiated by small businesses. In recent years many of our larger companies have been a declining source of new jobs as a result of outsourcing of manufacturing, assembly, customer service and technology functions to lower-cost countries.
While many factors stimulate small-business startups and growth, there are three overarching prerequisites: confidence in the future, available capital and access to credit.
Business and investor confidence remains weak, and improvement depends on a improved regulatory climate and sound monetary, fiscal and tax policies. New business funding is being curtailed as we await more clarity about these critical government functions.
Washington has encouraged banks to make additional credit available for small-business growth while routinely condemning the past actions of banks. Policymakers cite banker greed and mismanagement as principal culprits in nearly bringing down the financial system.
We agree that banks bear some responsibility for the 2008 financial meltdown, alongside poor government regulation and policies. But this charge is largely applicable to a comparative handful of big commercial and investment banks, mortgage banking companies, insurance companies, rating agencies and government-sponsored mortgage entities.
Thrown under the bus in this environment are some 7,000 community banks that are feeling the full brunt of the Dodd-Frank financial "reform" legislation. The 2,300-page bill will heap at least 10,000 pages of new regulations on community banks while doing almost nothing to solve the problems that brought us to financial panic in 2008.
Our government's one-size-fits-all mentality has a disproportionate effect on the smallest banks. Keep in mind that the average community bank (with assets of $230 million) is a thousandth the size of Bank of America. Yet that little bank is subject to the same public condemnation and regulatory backlash.
The Collins amendment to the Dodd-Frank legislation, which eliminates trust-preferred stock as a future source of capital, has a particularly insidious impact on small banks. While elimination of trust-preferred stock is likely a good policy for larger institutions, it cuts off one of the few alternatives for community banks to raise new capital.
To deny access to an important source of capital almost certainly forces increased consolidation among small banks, particularly when coupled with a heavier regulatory burden. Over the past 25 years the number of community banks has fallen at a rate of 3%-4% a year. Trends suggest the number could go from 7,000 to 3,500 within this decade.
At a recent meeting in Washington of 1,000 bankers from all size of banks, audience members were asked to raise a hand if they believed banks with assets of less than $100 million had a future. Virtually no hands were raised. The same question was asked about $500 million-asset banks and there was a 50% show of hands. This does not bode well for America's smaller communities and businesses. Community banks are the heart and soul of their communities, supporting much of the civic good while serving as the primary source of small-business credit.
The sad truth is that many community banks are weakened and no longer able to adequately support small business. It is past time for Washington to take note of this situation and restore the future of community banking.
The regulatory burden on community banks must be reduced, and we must remove unnecessary impediments to community banks' ability to raise capital. Years ago community banks were able to obtain capital in the form of subordinated debt from large correspondent banks. This worked exceptionally well because the correspondent banks were sophisticated creditors that imposed and enforced operating conditions on the safety and soundness of the community banks issuing the subordinated debt.
It is imperative that we foster stronger community banks more capable of meeting the needs of small businesses and helping to create job growth. We are running out of time to fix the problems that bad government policies have created for community banks and for those who depend on them.