Engage Bank Advisory Councils  

By Brent Adams

Bank advisory councils are an ideal forum to have a thoughtful discussion on the OCC/FDIC Community Reinvestment Act Proposal. Advisory councils are meant, in part, to establish a bridge of communication between communities and banks and to enable the bank to fully understand the community’s perspective as the bank decides on whether to pursue a particular course action.

If you serve on a bank advisory council, we urge you to encourage the bank to establish a mechanism by which the council could discuss and advise the bank on the OCC/FDIC CRA Proposal before the March 9, 2020, comment deadline.

If the bank has an advisory council meeting before March 9, 2020, the bank could simply make the Proposal an agenda item at the next meeting.

If no advisory council meeting is scheduled to occur before March 9, 2020, there are other options for enabling the council to advise the bank on the Proposal before the March 9 deadline. Among the options are:

  1. Convene a special meeting of the council devoted to the issue;
  2. A special conference call, or;
  3. Invite council members to submit written feedback to the bank sufficiently in advance of the March 9 deadline to enable the bank to consider the feedback as it decides how and whether to submit a comment.

An in-person meeting is ideal, of course, because it best ensures that bank staff are receiving your input.

If you succeed in getting the advisory council to consider the Proposal (or if the bank was planning to have the council discuss the Proposal anyway), please let us know!