ICBA sent a letter to the Financial Accounting Standards Board regarding its Proposed Accounting Standards Update, Transfers and Servicing-Servicing Assets and Liabilities Mortgage Servicing Rights-Recapture. ICBA noted that community banks generally do not have large recapture programs, so the proposal would add significant cost, complexity, and reporting burden with limited benefit, potentially making mortgage servicing less attractive for smaller institutions. ICBA recommended that the FASB slow down the process, seek broader industry input, exempt community banks using the amortization method, and adopt a standardized methodology if it moves forward.