Comment letter to the Federal Reserve, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency Urging Them to Strengthen CRA Q&As on Retail Banking

141010_CRAqa_retail_final.pdf

This letter to prudential financial regulators urges them to strengthen their proposed revisions to the Community Reinvestment Act (CRA) Questions and Answers (Q&As) regarding retail banking and community development in order to ensure that financial institutions adequately meet the needs of low- and moderate-income (LMI) people. The letter asks the regulators to incorporate principles about the retail financial services needs of LMI consumers into the retail CRA Q&As, assess the extent to which retail products and services offered by financial institutions are actually adopted by a broad range of LMI consumers, recognize the importance of full-service branches in meeting LMI community needs, banks to offer safe and affordable small dollar loan products or secured credit cards to meet LMI consumers’ need for emergency credit, penalize banks for undermining LMI people’s access to the banking system, and allow CRA credit only for products and services adopted by LMI people in the bank’s assessment area