The 15-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008.
In this 2014 letter, the Coalition weighs in on proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. The Coalition recommends a number of factors that the Community Reinvestment Act (CRA) examination process should take into account. First, the Coalition encourages the addition of CRA-based incentives for municipal financial empowerment services, such as for financial institutions that partner with municipalities to offer Bank On appropriate accounts, support children’s savings strategies, and invest in or support integrated financial counseling and coaching services. The Coalition urges that any consideration of alternative product delivery system be balanced by the fact that many low and moderate-income customers rely on full service bank branches, and highlights that cost and range of services, information about account availability, public awareness and customer support are all critical factors. The Coalition also recommends that the Q&A provide specific examples of how community development services can be distinguished from retail banking services, with suggested examples ranging from improving account screening to targeted outreach to low and moderate-income communities and training employees on serving these communities. Finally, the Coalition strongly recommends that assessment areas be revised to include all areas where banks do business, instead of being limited to where banks have a physical presence.