The CFE Fund recently submitted a comment letter to the Federal Reserve Board on Community Reinvestment Act (CRA) modernization. Citing experiences from the Bank On movement, as well as the FECPublic initiative, the CFE Fund recommended that the CRA examination process should credit financial institutions’ provision of safe and affordable banking accounts and support for meaningful financial inclusion efforts. CFE Fund recommendations included:
- The CFE Fund recommended that regulators examine the number of no-overdraft, low-fee transaction accounts (such as nationally-certified Bank On accounts) newly opened per reporting period.
- The CFE Fund encouraged the Board to examine the Bank On Data hub data tracking strategy, specifically the collection of zip-code level account opening and usage metrics, when evaluating the provision of deposit products for individuals with low incomes.
- Based on Bank On successes, the CFE Fund also recommended that regulators examine the number of account-opening programmatic partnerships begun during the reporting period, and how many people are served in such programs.
- The CFE Fund also encouraged the Board to distinguish and credit support of high-quality financial counseling from financial education efforts by incorporating impact metrics such as credit score improvement, debt reduction, and increased liquid savings into evaluation of community development service investments.