CBA Comments on the Proposal to Amend the Q&A Regarding the CRA

November 10, 2014

Washington, D.C. (November 10, 2014) – The Consumer Bankers Association today submitted comments to the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Federal Reserve Board regarding the proposed revisions to the Community Reinvestment Act Q&A, the vehicle collectively used by the agencies to interpret regulations. Among other points, the comments included the following:

  • CBA supported the expansion of consideration of alternative delivery channels in the Service Test, as a greater recognition of the expanded role played by such channels in providing services to low- and moderate-individuals. At the same time, CBA stressed the value of retaining branch location for the identification of the assessment area of traditional banks.
  • In general, CBA applauded the additional guidance given throughout the Q&A, while stressing the importance of examples being not exclusive, terms being used consistently, and flexibility being accorded wherever possible.
  • CBA’s comments emphasized the importance of examiner training in fully understanding bank performance and obtaining the full measure of the proposed Q&A revisions.

The full comment letter can be found here.

About CBA

Founded in 1919, the Consumer Bankers Association (CBA) is the trade association for today's leaders in retail banking - banking services geared toward consumers and small businesses. The nation's largest financial institutions, as well as many regional banks, are CBA corporate members, collectively holding well over half of the industry's total assets. CBA’s mission is to preserve and promote the retail banking industry as it strives to fulfill the financial needs of the American consumer and small business.