Consumer Alliance for a Strong Economy

On behalf of the Consumer Alliance for a Strong Economy (CASE), we commend the Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation for advancing a regulatory proposal that preserves and strengthens access to credit for America’s small businesses, farmers, agricultural companies, and entrepreneurs. Small businesses rely on access to affordable credit in order to finance payroll, inventory, equipment purchases, expansion, and day-to-day operations. By freeing up additional capital for lending, this proposal will help banks approve more small business loans at lower rates, expanding access to affordable credit for entrepreneurs who often lack access to larger capital markets. This is especially important for our membership — minority-owned businesses, family farms, and startups that are most vulnerable when credit conditions tighten. Meanwhile, the proposal also helps improve American competitiveness at the global level. For too long, American businesses have quietly had to absorb the cost of high capital requirements, leading to higher interest rates, tighter credit, and fewer opportunities to build wealth. All this while peer nations are subject to much lower borrowing costs. By bringing U.S. capital requirements closer in line with international norms, this proposal helps close this gap in the cost of credit. This will give America a more competitive footing in the global marketplace and place more affordable credit within reach of small business, farmers, and rising entrepreneurs who need it the most. CASE encourages the agencies to build on this approach and continue advancing policies that promote responsible lending, economic growth, and long-term opportunity for Main Street businesses across the country.