OCC Comptroller Delivers Remarks at NCRC

On Friday, March 18, 2016, Comptroller of the Currency Thomas Curry delivered remarks at the National Community Reinvestment Coalition (NCRC) conference where he addressed how national banks and federal savings associations can more effectively serve the credit needs of rural communities, especially those who are economically distressed.  During his remarks, Comptroller Curry mentioned changes to the Interagency Community Reinvestment Act Questions and Answers finalized in November of 2015.  He said he hoped the changes will lead banks to consider more opportunities to lend and invest in rural communities located outside of their assessment areas.  His specific remarks focused on customer delivery and the challenges faced by the industry. 


On the issue of alternative delivery channel, he indicated:

  • Technological advances are shaping the way financial products are delivered.
  • Consumers prefer alternative delivery systems and are able to use them anytime. 
  • Banks’ legacy systems and extensive branch networks are expensive to maintain.
  • “Through innovation banks can and will be able to reach more customers, lower the cost of financial products and services, expand product offerings to better serve customers, and make their branch networks more efficient.”
  • “Although the large bank CRA service test places primary emphasis on branches, alternative systems for delivering retail banking systems are also considered.”
  • Banks are benefitting from smaller size branches, smart ATMs, cross-training staff.


He also discussed challenges facing the industry, adding:

  • Technology may not substitute for physical presence in low- and moderate-income communities.
  • Not only are banks financial service providers, but they also are a “stabilizing force” to determine if communities “thrive or just barely survive.”
  • Small businesses are dependent on branch access for deposits and face to face expertise.
  • Senior citizens are more comfortable with banking in branches due to face to face interactions.
  • Consumers and businesses rely on branches for assistance and service issues.
  • Brick and mortar plays an important role in bank strategy for building a brand.
  • The vast majority of new accounts are opened in a branch.