Proclamation June 09, 2025 Doc #2025-10396

Agency Information Collection Activities: Information Collection Renewal; Comment Request; Survey of OCC-Supervised Community Banks

Economy Trade Foreign Policy Infrastructure

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In Simple Terms

The government wants to keep asking small banks questions to see how well they are doing. They are asking people to comment on this plan.

Summary

President Donald J. Trump issued a proclamation on June 3, 2025, to adjust tariffs on imports of steel and aluminum into the United States. This action increases the tariff rate from 25% to 50% ad valorem on steel and aluminum articles, including their derivatives, effective June 4, 2025. The decision aims to counteract foreign countries that are offloading low-priced steel and aluminum into the U.S. market, which threatens the national security by undermining the competitiveness of domestic industries. The proclamation also outlines specific measures for imports from the United Kingdom under a new economic deal, maintaining the previous 25% tariff rate for these imports.

Official Record

Federal Register Published

Signed by the President

June 03, 2025

Published in Federal Register

View on Federal Register View Printed Version (PDF)

June 09, 2025

Document #2025-10396

Analysis & Impact

💡 How This May Affect You

The presidential action described involves a survey conducted by the Office of the Comptroller of the Currency (OCC) to gather feedback from community banks, which are smaller, locally-focused financial institutions. This survey aims to assess the effectiveness of the OCC's support and technical assistance to these banks. While this action might seem administrative, it can have various real-world implications for different groups of Americans:

Working Families and Individuals

Access to Financial Services: Community banks often provide essential banking services in local communities, including personal loans, mortgages, and checking accounts. The feedback collected from these banks could lead to improved services and products tailored to local needs, potentially enhancing financial access for working families.
Local Economic Impact: Community banks play a critical role in local economies by providing loans to small businesses and individuals. Improvements in OCC support could lead to healthier community banks, which in turn might offer better loan terms or more competitive rates for personal banking services.

Small Business Owners

Easier Access to Credit: Small businesses often rely on community banks for financing. The survey could lead to changes that make it easier for these banks to extend credit, thus helping small business owners secure loans for expansion or operations.
Tailored Financial Products: Feedback from the survey might encourage the development of financial products that better meet the needs of small businesses, such as more flexible loan terms or specialized services.

Students and Recent Graduates

Student Loans and Banking Services: Although community banks are less likely to offer student loans compared to larger banks, they might still provide financial literacy programs or savings accounts that benefit students and recent graduates. Improved services could assist young adults in managing their finances more effectively.
Job Opportunities: Healthier community banks might lead to more job opportunities within these institutions, potentially offering positions suitable for recent graduates.

Retirees and Seniors

Stable Banking Services: Retirees often depend on stable banking services for managing pensions and savings. Enhanced support for community banks could ensure continued access to reliable banking services.
Community Engagement: Community banks often engage with local seniors through community events or financial education programs. Increased support might expand these initiatives, benefiting seniors.

Different Geographic Regions

Urban Areas: In urban areas, community banks might face stiff competition from larger banks. Improved OCC support could help level the playing field, allowing these banks to offer competitive rates and services.
Suburban Areas: Suburban community banks might benefit from tailored OCC support that addresses the specific needs of suburban customers, such as home loans or small business financing.
Rural Areas: Community banks are often the primary financial institutions in rural areas. Enhanced support could improve their ability to provide essential services, such as agricultural loans or personal banking, which are crucial for rural economies.

Overall Implications

The survey's findings could lead to regulatory changes or new initiatives that strengthen community banks, thereby improving their ability to serve their local communities. This, in turn, could lead to more robust local economies, better access to financial services, and potentially lower costs for consumers. The action underscores the importance of community banks in the financial ecosystem and the need for ongoing assessment to ensure they can effectively meet the needs of their customers.

🏢 Key Stakeholders

Primary Beneficiaries:

U.S. Steel and Aluminum Industries: These industries will benefit from increased tariffs as it provides them with a competitive edge against low-priced foreign imports, potentially boosting domestic production and employment. The policy aims to secure national security by ensuring these industries remain viable and capable of meeting defense needs.
Domestic Suppliers and Manufacturers: Companies supplying raw materials or components to steel and aluminum industries may see increased demand as domestic production rises. This could lead to growth in their operations and workforce.

Stakeholders Facing Challenges:

Foreign Steel and Aluminum Producers: These producers will face challenges as increased tariffs make their products more expensive in the U.S. market, potentially reducing their market share and revenue from U.S. imports.
U.S. Industries Dependent on Steel and Aluminum Imports: Industries such as automotive, construction, and machinery manufacturing may experience higher costs due to increased tariffs, potentially impacting their profitability and competitiveness.

Industries, Sectors, or Professions Most Impacted:

Manufacturing Sector: The increased tariffs will affect manufacturers reliant on steel and aluminum, potentially leading to increased production costs and price adjustments.
Construction Industry: As a major consumer of steel and aluminum, this industry may see increased material costs, impacting project budgets and timelines.

Government Agencies or Departments Involved in Implementation:

Department of Commerce: Responsible for monitoring the impact of tariffs and advising on national security implications.
U.S. Customs and Border Protection (CBP): Tasked with enforcing the new tariff rates and ensuring compliance with import regulations.

Interest Groups, Advocacy Organizations, or Lobbies with Strong Positions:

American Iron and Steel Institute (AISI): Likely to support the action as it aligns with their interests in promoting domestic steel production and reducing foreign competition.
National Association of Manufacturers (NAM): May express concerns about the impact of increased tariffs on manufacturing costs and competitiveness, advocating for balanced trade policies.

Each stakeholder group has vested interests either in benefiting from increased domestic production and reduced foreign competition or in mitigating the adverse effects of higher input costs and reduced market access.

📈 What to Expect

Short-term (3-12 months) Outcomes:

Immediate Implementation Steps:
- The Office of the Comptroller of the Currency (OCC) will initiate the process of collecting comments from stakeholders, primarily community banks, on the proposed information collection renewal.
- The OCC will revise its survey methodology to expand the scope beyond a specific subset of community banks, allowing for broader feedback collection.
Early Visible Changes or Effects:
- Community banks will begin receiving communications from the OCC regarding the survey, prompting them to participate and provide feedback.
- Initial feedback may highlight areas where the OCC's supervisory efforts are perceived as effective or lacking, providing early insights into the needs and challenges faced by community banks.
Potential Initial Reactions or Challenges:
- Some community banks may express concerns about the increased administrative burden of participating in the survey, particularly if they perceive the process as time-consuming or lacking in immediate benefits.
- There might be skepticism regarding the OCC's ability to implement meaningful changes based on survey feedback, especially if past interactions have not led to substantial improvements.

Long-term (1-4 years) Outcomes:

Broader Systemic Changes:
- Over time, the expanded survey could lead to more tailored regulatory and supervisory practices by the OCC, better aligning with the diverse needs of community banks.
- The feedback collected may influence policy adjustments that enhance the operational environment for community banks, potentially supporting their growth and stability.
Cumulative Effects on Society, Economy, or Policy Landscape:
- Improved regulatory practices could strengthen the resilience and competitiveness of community banks, which play a critical role in local economies by providing credit to small businesses and individuals.
- Enhanced support from the OCC might lead to increased innovation and service offerings by community banks, benefiting consumers and contributing to economic vitality.
Potential for Modification, Expansion, or Reversal by Future Administrations:
- Future administrations might build upon the survey's findings to further refine regulatory approaches, potentially expanding the survey's scope or frequency to capture evolving industry dynamics.
- Conversely, if the survey process is deemed ineffective or overly burdensome, there could be calls for its modification or discontinuation, particularly if it fails to deliver tangible benefits to community banks.

Overall, the survey's success will largely depend on the OCC's responsiveness to feedback and its ability to translate insights into actionable improvements in regulatory oversight and support for community banks.

📚 Historical Context

The recent proclamation regarding the Survey of OCC-Supervised Community Banks is a continuation of a historical pattern where federal agencies seek to balance regulatory oversight with the burdens imposed on financial institutions. This action fits within a broader context of federal information collection practices and regulatory adjustments, drawing parallels with several past presidential actions and policies.

Historical Precedents and Similar Actions:

Paperwork Reduction Act of 1995 (PRA): The practice of seeking public comment on information collection activities is rooted in the Paperwork Reduction Act of 1995. This act was designed to minimize the paperwork burden for individuals, small businesses, and others, and to ensure that the information collected by the government is necessary and useful. The current action by the OCC aligns with the PRA's goals by inviting public feedback to potentially streamline and improve data collection from community banks.
Community Reinvestment Act (CRA) of 1977: Historically, the federal government has shown a commitment to ensuring that financial institutions serve the needs of their local communities. The CRA, for example, was enacted to encourage banks to help meet the credit needs of all segments of their communities, including low- and moderate-income neighborhoods. The survey of OCC-supervised community banks can be seen as an extension of this commitment, ensuring that regulatory practices support community banking.
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010: This act significantly increased regulatory oversight of financial institutions in the wake of the 2008 financial crisis. It also emphasized the importance of transparency and accountability. The current survey initiative reflects these ongoing priorities by seeking to assess and potentially enhance the OCC's supervisory efforts.

Building Upon, Modifying, or Reversing Existing Policies:

The current action builds upon existing policies by continuing the tradition of soliciting feedback to refine regulatory practices. It modifies previous approaches by expanding the scope of the survey to include a broader range of community banks, allowing the OCC to gather more comprehensive data and tailor its supervisory strategies more effectively.

Relevant Historical Patterns:

Regulatory Feedback Loops: There is a long-standing pattern of regulatory agencies seeking feedback to adjust and improve their practices. This iterative process is crucial for maintaining effective oversight while minimizing unnecessary burdens on regulated entities.
Focus on Community Banks: Historically, community banks have been recognized for their role in supporting local economies. Federal policies have often aimed to ensure these institutions are not disproportionately burdened by regulations, acknowledging their unique challenges and contributions.

Unique or Noteworthy Aspects:

What makes this action noteworthy is its emphasis on flexibility and adaptability in regulatory oversight. By removing the subset limitation and allowing for a broader survey scope, the OCC demonstrates a commitment to responsive and dynamic regulation. This approach is crucial in an evolving financial landscape where the needs and challenges of community banks can vary significantly.

In conclusion, the OCC's action to renew and expand its survey of community banks is a continuation of historical efforts to balance regulatory oversight with the operational realities of financial institutions. It reflects a broader pattern of using feedback to refine policies and underscores the importance of community banks in the American financial system.