Here at Woodstock Institute, we focused on retail financial services in our comment letter and urged regulators to:


  • Focus on the retail financial services needs of LMI consumers and 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;
  • Require banks to offer safe and affordable small dollar loan products or secured credit cards to meet LMI consumers’ need for emergency credit;
  • Grant negative CRA credit to banks that engage in behaviors that undermine LMI people’s access to a safe, fair, and affordable financial system;
  • Allow CRA credit only for products and services adopted by LMI people in the bank’s assessment area;
  • Admit that revisions to the CRA Q&As are not sufficient to address the major changes in the financial services industry and work to make the necessary changes in the law and regulations (as recommended in the 2010 public hearings), including redefining assessment areas based on areas in which banks conduct significant business, regardless of branch and ATM locations.


Congress passed the CRA  in 1977 to combat red-lining and  encourage banks to meet the credit needs of the communities in which they operate, including LMI people and communities, but many people, businesses, and communities remain underserved by banks and use alternative financial services such as payday loans or high-cost online business loans. Woodstock Institute recently shared this continuing trend in our report on disparate access to credit for businesses. The report found that businesses in predominantly white and wealthier communities were more likely to receive small loans than businesses in lower-income areas and communities of color. Businesses create jobs and help communities prosper, so it slows down growth when banks don’t offer safe and affordable products in underserved communities..


We encourage you to personalize our sample letter and send it to regulators by Monday, November 10.