CBA, ABA, and BPI Letter to Treasury on Financial Inclusion
The Bank Policy Institute, the American Bankers Association, and the Consumer Bankers Association (together, “the Associations”) appreciate the opportunity to comment on the Department of the Treasury’s Request for Information to help inform its development of a national strategy for financial inclusion as required by The Financial Services and General Government Appropriations Act, 2023. The Associations support the goal of the Act to develop a national strategy to broaden access to financial services among underserved communities and improve those communities’ ability to benefit from such services. Banks and credit unions are continuously innovating to develop new ways to reach underserved communities and consumers, including by expanding access to low- and no-cost bank accounts, credit products, and digital payments products. The Federal Deposit Insurance Corporation (FDIC)’s most recent survey of the unbanked demonstrated significant progress – the lowest percentage of unbanked Americans since the survey began – but banks and credit unions remain committed to ensuring all Americans have access to safe and affordable financial products and services.
For this reason, we are concerned that recent regulations finalized or proposed by the federal banking agencies could reverse this progress. We recommend that the Treasury and other policymakers—as part of a national strategy—task the banking agencies with considering the potential effect of any regulatory proposal on low- and moderate-income (LMI) and underserved consumers’ access to financial products and services, including bank accounts and credit products. Regulatory restrictions could preclude banks from expanding underserved communities’ access to products that promote wealth building, small business growth and economic resilience. We make additional, targeted recommendations for policymakers to consider that could help further advance financial inclusion.
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