Main Street Capital Access Act
What changed between versions
Section 101's original provisions on 3-year capital phase-in for new banks, business plan deviation approval (with 30-day deemed approval), rural community bank leverage ratio (7.5% cap), agricultural loan authority for federal savings associations, and a de novo bank study were all removed.
New Section 101 amends the 21st Century ROAD to Housing Act, shortening a period from 180 days to 90 days and adding a safety-and-soundness determination mechanism that could either make a pilot program permanent or terminate it for new banks after January 2031.
New sections added to the table of contents include Section 703 (Failing Bank Acquisition Fairness) in Title VII and Section 803 (Discretionary surplus fund) in Title VIII, expanding the bill's reach into resolution processes and bank capital management.
Several sections present in the Introduced version were dropped entirely: Section 304 (Tailored Regulatory Updates for Supervisory Testing), Section 305 (Stress Testing Accountability and Transparency), Section 306 (Community Bank Representation), Section 404 (American Financial Institution Regulatory Sovereignty and Transparency), and Section 503 (Community Bank Deposit Access).
Section 103 (Bank Failure Prevention) was removed from Title I. It had established 90-day deemed-approval deadlines for bank holding company, savings and loan holding company, and insured depository institution merger applications, with detailed complete-record procedures and third-party information exclusions.
Bank Failure Prevention was moved to new Section 604 in Title VI (Promoting Bank Competition and Merger Clarity), suggesting a recontextualization of the provision within merger policy rather than new bank formation.
A new GAO reporting requirement was added to Section 201, requiring the Comptroller General to submit a report within 18 months evaluating the effects of the tailoring section on specified factors.
New Section 103 requires the Treasury Secretary to annually testify before Congress about CDFI Fund operations, the mentor-protege program, and coordination with regulators on streamlined certification for community development financial institutions.
New Section 104 reauthorizes and improves the CDFI Bond Guarantee Program through December 31, 2028 (previously expired in 2014), sets a minimum guarantee of $25 million with an annual cap of $1 billion, changes the fee from a fixed 10 basis points to a range of 10-15 basis points, and requires a Treasury report on program effectiveness within 3 years.
Section 202 (Small Bank Holding Company Relief) lowered the consolidated asset threshold for simplified Federal Reserve supervision from $25 billion to $6 billion, significantly narrowing the class of institutions eligible for relief.
The original Section 203 (Community Bank Leverage Improvement) was removed. It would have raised the CBLR asset threshold from $10 billion to $15 billion and lowered the leverage ratio range from 8-10% to 6-8%, plus required a Federal Reserve-led review of the CBLR framework.
Section 201's 'limited look-back application' provision was removed. It had required agencies to review all final regulations issued in the prior 15 years and apply tailoring requirements to them within 3 years of enactment.
Section 204 was completely rewritten. The original version specified concrete threshold increases (e.g., $250B to $370B for enhanced prudential standards, $100B to $150B for Federal Reserve assessments). The new version replaces these with a broader periodic indexing mechanism covering over 12 additional statutes (CRA, DILIA, FCUA, FDI Act, FHLB Act, HMDA, HOEPA, RESPA, etc.) with granular rounding rules down to $50 increments.