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Missouri Bankers Association urges Fed to modernize check‑hold, appraisal and call‑report rules

Federal Reserve System · April 8, 2026
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Summary

Keith Thornberg of the Missouri Bankers Association urged the Federal Reserve to update Regulation CC to allow extended holds for suspected check fraud, raise appraisal thresholds for low‑risk loans, streamline flood‑notice rules, and simplify call‑report schedules to reduce burdens on community banks.

Keith Thornberg, general counsel for the Missouri Bankers Association, used his panel remarks at a Federal Reserve consumer‑regulations session to press for several technical updates to banking rules.

Thornberg said banks and customers ‘‘are losing substantial amounts of money due to check fraud and Regulation CC is a contributing factor.’’ He said the Missouri Bankers Association proposed an amendment to Regulation CC to permit a nine‑day hold for suspected check or account fraud for the receiving bank, plus an additional nine‑day hold for the originating bank, and suggested revising check warranties to incentivize appropriate due diligence.

He asked regulators to modernize definitions in Regulation CC and Regulation D so that the rules reflect that non‑local checks are no longer a practical distinction. He also proposed eliminating 'NOW' account regulatory distinctions where functionally identical interest‑bearing demand accounts exist.

On appraisal regulations, Thornberg urged raising thresholds that require licensed appraisals for low‑risk transactions to reduce passed‑through appraisal costs to consumers. He called for streamlining flood‑notice requirements to avoid repetitive notices when flood insurance is already maintained on an existing loan.

Thornberg concluded with a plea to rationalize and simplify call‑report schedules so community banks can complete only fields relevant to their business lines, reducing compliance burden and improving data quality.

The panel did not vote on any of these technical proposals. Other panelists welcomed near‑term guidance on CDFI certification and clearer rules for CRA credit outside assessment areas, but the session produced no agency commitments and moved to an open comment period.