To review credit conditions in rural America

Transcription

1 Statement for the Record By the Independent Community Bankers of America Before the House Committee on Agriculture Subcommittee on Operations, Oversight, and Credit Hearing To review credit conditions in rural America April 14, 2011 Washington, D.C.

2 1 A Review of Credit Conditions in Rural America On behalf of its nearly 5,000 1 member banks, ICBA is pleased to submit this statement for the record for this hearing to Review Credit Conditions in Rural America. Role of Community Banks in Rural America Community banks play an important role in the nation s economy. There are over 7,500 community banks in the U.S. and the vast majority of these are located in communities of 50,000 or fewer residents. Community banks are the economic driving force of rural communities, helping to finance innovation, entrepreneurship and job creation. Community banks stimulate rural economies in a multitude of ways, including creating off-farm jobs, maintaining the local tax base and facilitating development of the infrastructure and public services necessary to keep rural communities vibrant. Because most community banks are locally owned and operated, they have strong ties to their local communities. These banks have a close relationship with their customers and are quite familiar with their customers financial condition and history and ability to repay. The success of community banks are tied directly to the success or failure of their customers and their communities. For these reasons, community banks stick with their customers and their communities through thick and thin, through good times and bad. Community banks have consistently been the largest provider of agricultural credit within the commercial banking sector. In rural areas, a community s economic fortunes are often tied to the agricultural economy. Community banks with assets under $10 billion provide over 70 percent of all commercial bank agricultural loans, and banks with assets less than $1 billion provide nearly 60 percent of all commercial bank agricultural financing. Even more astounding, community banks under $500 million in assets extend over 50 percent of all agricultural credit from the banking sector. Commercial banks extend approximately 53 percent of non-real estate farm loans and 38 percent of the farm real estate credit. Community banks have only 12 percent of all bank assets but make 20 percent of all small business loans. Small businesses are important in rural America since many farmers and/or their spouses have off-farm jobs. In addition, the more than 26 million small businesses in the U.S. have created 70 percent of the net new jobs over the past decade. Community banks are small businesses themselves and specialize in small business relationship lending. Community banks provide a substantial number of Small Business Administration (SBA) loans, and provide more than 60 percent of small business loans between $100,000 and $1 million. 1 ICBA represents 5,000 community banks throughout the country. Community banks are typically independently owned and operated and are characterized by personal attention to customer service and are proud to support their local communities and the nation s economic growth by supplying capital to farmers and ranchers, small businesses, and consumers.

3 2 Outlook for the Farm Economy As we have all heard in this era of unusually high commodity prices, the farm economy is robust and generally healthy. Net farm income is forecast by USDA to be up nearly 20 percent in 2011 at almost $95 billion, up about $16 billion from 2010 levels. The 2011 forecast is the second highest inflation-adjusted value for net farm income recorded in the past 35 years. There may be some troubled spots in certain sectors such as dairy, and last year in livestock, and in regions impacted by severe weather such as a lingering drought. However, many bankers have said that producers are flush with cash; are purchasing land with cash; updating equipment; and have paid down their loans or operating debt. Higher farm income has improved farm credit conditions and has led to an increase in loan repayments, and a decrease in renewals and extensions of credit. Most lenders believe that credit demand will increase although some states report weakening farm credit demand. Higher input costs for such inputs as feed, seed, fuel and fertilizer has generally increased production costs for many farmers resulting in an increase in individual borrowing needs. Collateral requirements are expected to remain unchanged. Interest rates continued to decline throughout Agricultural lending has therefore been a very healthy business for community banks over the last several years. The return on assets (ROA) for agriculturally oriented banks was approximately 0.7 percent in the fourth quarter of 2010, compared to a ROA of 0.1 percent for non-agricultural banks. Even so, this ROA level is much smaller, or only about onehalf the level of the Farm Credit System s (FCS) ROA level. The FCS is clearly able to leverage its considerable tax and funding advantages as a government sponsored enterprise (GSE) to undercut community banks in the agricultural marketplace and cherry-pick the prime loans out of the portfolios of community banks. A Rural Farmland Bubble? It is true that the price of farmland has increased significantly, even dramatically, in recent years due to high farmland demand from both farmers and investors. Many bankers also add that inflated appraisal practices by the FCS are leading to inflated land values and represent an unsustainable trend. These higher land values have led some regulators to urge stricter underwriting standards on the part of community banks. The FDIC, for example, released guidance on farmland values last December. Most of the underwriting standards incorporated into the guidance were already common practice among agricultural banks, many of which lived through the farm credit crisis of the 1980s. For example, many banks do not calculate land values at today s prices when structuring ag credit for borrowers; rather they use valuations based on land prices from five years ago. Many banks may require higher collateral amounts to secure farmland loans or a larger down payment. Banks also want to see that a loan can cash flow to indicate the likelihood of repayment. Banks run various stress-testing

4 3 calculations to ensure their loan portfolio can withstand economic shocks or unexpected downturns in either the general or farm economy. Community banks also rely on crop insurance and farm programs as a safety net for their producers ability to repay loans and therefore support a strong farm bill. One area where community banks take issue with the FDIC s guidance and that of other federal bank regulators would be the suggestion that banks should limit the concentration of farm loans to 300 percent of capital, similar to the guidance for commercial real estate loans. Community banks would disagree and note that many rural communities are heavily agricultural in nature and most of the loan demand is agriculturally related. Community banks believe there are other, more appropriate risk mitigation strategies that can be unutilized in lieu of loan concentration limits as mentioned above and will be discussing this issue further with regulators to ensure that community banks and their customers are not harmed by the unintended consequences of arbitrary guidelines. Rising farmland prices are being spurred by rising commodity prices, low interest rates, a weak dollar over the past decade and expectations of higher returns. Some worry that a significant decline in commodity prices combined with a sustained level of high input costs or rapidly rising interest rates could, over an extended period of time, have serious negative ramifications for the farm economy. That is not the situation in today s farm economy, however, and banks have incorporated sound underwriting practices to guard against such an outcome. We will continue to monitor these trends. The Importance of a Strong Farm Safety Net and Guaranteed Farm Loan Programs The volatility of crop input prices and uncertainty in economic conditions and commodity prices can make it extremely difficult for farmers as well as lenders to make long term plans. In addition, government regulations have had a very negative effect on both farmers and lenders. This would include a very harsh lending environment by banking regulators. Banker frustration is high because of the current exam environment. Congress can help by reducing regulatory burdens. Farm bills are very important to helping bankers and their farm and ranch customers make long-term plans. In the current budget environment, it will be extremely difficult, yet extremely important to keep farm bill policy in place that adequately supports our farmers and ranchers. This includes healthy support for not only farm programs and crop insurance but also for government guaranteed loan programs. Community bankers are strong users the guaranteed farm loan programs and the business and industry loan program. ICBA believes these programs should be continued and because they leverage a small amount of money into billions of dollars of loans for farmers, ranchers and small businessmen and women, funding to these programs should be increased.

5 4 The farm loan programs are an important safety net for America s farmers by providing a source of credit when farmers and ranchers are temporarily unable to obtain credit from commercial sources and can do so only with a guaranteed loan. These programs turned a small amount of money into $3 billion of loans in While we are currently reviewing possible recommendations for the next farm bill regarding guaranteed farm loan programs, we would offer the following suggestions. First, since the administration proposes to eliminate money for the Interest Assist (IA) program, which has a Fiscal Year 2010 and 2011 budget authority of $24 million, Congress should ensure that these funds be reinvested in guaranteed loan programs, which effectively and efficiently utilize banks money to finance farmers and rural America. Second, the administration proposes in its FY 2012 budget to provide no budget authority for farm ownership loans and apparently intend to raise fees to pay for the program at no cost. This can be a slippery slope of sharply higher fees. However, if the program has no budget costs due to minimally higher fees, ICBA questions why the program is capped at $1.5 billion in the proposed budget. If fees are raised, we believe there should be no cap since it would be self-sustaining. We also suggest that if the IA program s budget is eliminated or reduced, a portion of those funds can be directed to the guaranteed loan program to meet increased demand. As land values and input costs have risen, many borrowers are increasing the size of their loans and this is not an appropriate time to limit funds in the guaranteed loan programs. Third, ICBA supports swift enactment of S. 368 and H.R. 1422, bipartisan legislation to suspend term limits on FSA guaranteed loans until Dec. 31, 2013 to allow this issue to be decided in the next farm bill. Ultimately, we believe that term limits on guaranteed loans should be eliminated since banks provide the financing and whether a borrower takes out a loan should be a local decision between the local bank and the farmer/rancher. Fourth, funds for the Business and Industry (B&I) guaranteed loan program should be increased or the fee structure changed to facilitate a greater number of loans. This could potentially be accomplished by lowering fees for smaller loans while raising fees on larger loans or providing authority to transfer unused funds or grant money to the guaranteed B & I program. We will further explore this option and make recommendations to the committee. The administration has effectively improved the operation of the B&I program and has stimulated interest in the program by many more lenders. Now that the infrastructure of lenders and networking has been built up, we should look for ways to further leverage this program to spur rural business activity. Unfair Farm Credit System Competition Farm Credit System lenders enjoy an unfair advantage over rural community banks in competing for loans by leveraging their tax and funding advantages. The FCS, a government sponsored enterprise (GSE) chartered by Congress to serve bona fide farmers

6 5 and ranchers, seeks numerous non-farm lending powers in an effort to compete directly with commercial banks for non-farm customers. These new powers would essentially make FCS institutions the functional equivalent of commercial banks and tax-exempt credit unions, but with intrinsic GSE tax and funding advantages. While the FCS s legislative proposals were not included in the 2008 farm bill, FCS has sought to push its legislative agenda through its regulator, the Farm Credit Administration (FCA). In addition to the broad consumer, housing, and retail and business lending legislative proposals that FCS lobbied for during the last farm bill, FCS s regulator is now advocating a Rural Community Investments proposal aimed at allowing non-farm financing if such financing is labeled as investments. Such financing would be very broad, allowing FCS institutions to finance otherwise illegal lending in any city of under 50,000 residents, including non-agricultural business loans, light manufacturing, apartment complexes, dental facilities, doctors and lawyers offices, and many other types of loans currently prohibited by law. FCA has also recently and inappropriately changed the definition of rural to apply to localities within metropolitan statistical areas (MSAs) if any other federal program with rural users also targets such areas. In recent years, FCA has also allowed various deposit-taking programs by FCS lenders that siphon local funds out of rural communities and has expanded the FCS mission without informing the public. Recently, the FCA has proposed allowing FCS lenders to purchase loans or pools of loans of failed banks from the FDIC. This grant of illegal authority would include allowing FCS lenders to purchase non-farm loans outside of their geographic territories. Large, multi-state or regional FCS entities enjoy tax advantages allowing them to siphon away high-quality loans from much smaller community banks. These tax advantages include exemptions from paying taxes on real estate and mortgage loans, and avoidance of state and local taxes including sales taxes and state franchise taxes and an exemption of taxes on retained earnings providing a huge advantage over community banks in their ability to grow. Approximately 40 percent of FCS institutions now average $2 billion or more in assets and growing. These are hardly small local lenders in touch with their local communities. ICBA adamantly opposes the FCS s expansionist agenda. The FCA and FCS are working together to try and morph the FCS into a generalized rural lender instead of a farm or agriculturally exclusive lender. The FCS has been granted unique tax advantages and unique funding advantages in exchange for their focus on agriculture. Now, FCS desires to utilize these advantages and expand their lending scope and purposes to any type of rural loan. This is grossly inappropriate and self-serving.

7 6 The cumulative impact of such changes represents a dramatic departure from FCS s historic mission and congressional intent to serve bona-fide farmers and ranchers and has no basis in the law or legislative history. We believe these non-farm power grabs are blatantly illegal and will harm community banks the engines of rural economic activity. We urge the committee to oppose FCS non-farm expansion proposals whether they come through the legislative or regulatory arena. Closing ICBA looks forward to working with this committee, the Administration, and the community banking industry in preparation for a new farm bill and in an effort to keep rural America and our rural communities strong and vibrant for years to come. Thank you.