The CFE Fund recently submitted a letter to the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Federal Reserve Board in response to their request for information about Bank-FinTech partnerships. The letter highlighted our concerns about the importance of access to mainstream bank accounts and the significant safety risks associated with alternative FinTech provided products. We specifically highlighted the limited impact of increased transparency and education on the ability to understand differences between the mainstream and alternative products.
Author: Katie Plat
The Skyline: How Two Cities Leveraged Financial Empowerment as Connective Tissue for Housing Success
By connecting financial empowerment to rental assistance programs, two cities supercharged social service success and brought together a range of partners to build a cohesive ecosystem around longer-term financial stability. Read the full issue here.
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FEC Public: The Movement to Date
The CFE Fund has spent more than a decade supporting and enhancing financial counseling as a public service, resulting in a sustainable, proven program model that works in a range of local contexts.
CFE Comment Letter to National Association of State Workforce Agencies on Open UI Initiative
The CFE Fund recently submitted a comment letter to the National Association of State Workforce Agencies (NASWA) in response to their request for information on the Open Unemployment Insurance Initiative. Citing evidence from a range of CFE Fund work—including the success of our national Bank On initiative in assisting the Internal Revenue Service connect stimulus recipients to banking for direct deposit and our partnerships with the State of Illinois’s Department of Employment Security and the State of Maryland’s Division of Unemployment Insurance, incorporating access to safe and affordable banking accounts into the benefits application processes—the letter highlighted the importance of leveraging government payment systems to promote safe banking access.
CFE Fund Comment Letter to Treasury on Financial Institution Customer Identification Requirements
The CFE Fund recently submitted a letter to FinCen at the U.S. Department of Treasury in response to their request for information about updating the process of requiring full Social Security Numbers when opening a bank or credit union account. Drawing from our Bank On experience, our letter highlighted the barriers faced by consumers from marginalized communities from the current structure and application of customer identification requirements, the importance of financial institution acceptance of alternative forms of ID to facilitate banking access integrations and urged FinCEN to provide financial institutions with clear guidance on the acceptability of these alternative identifications.
Five U.S. Cities Selected to Create Local Wealth Building Strategies Addressing Racial Wealth Equity
In this April 2024 press release, the CFE Fund announced that a third cohort of five cities have been selected to join the CityStart initiative. The initiative helps local leaders develop and implement proven strategies to support local families and communities in building financial stability, with a specialized focus on racial wealth equity. Bloomberg Philanthropies’ Greenwood Initiative, whose mission is to accelerate the pace of Black wealth accumulation in the U.S., is partnering with the CFE Fund and selected municipal partners to design and execute this latest iteration of the CityStart initiative.
The CFE Fund will partner with local government leaders in Buffalo, NY; Chicago, IL; Indianapolis, IN; Little Rock, AR; and Philadelphia, PA to help craft innovative, actionable blueprints tailored to their communities that foster financial stability across generations, especially for Black residents. Each of the five cities will also receive a $75,000 planning grant to help address pressing issues in their localities related to rising gentrification, disinvestment in key historically Black neighborhoods, and the racial wealth divide.
CFE Fund Comment Letter to Consumer Financial Protection Bureau on Overdraft Lending Regulations
The CFE Fund recently submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to a Request for Comment on the CFPB’s proposal to update regulations that govern overdraft lending services. Citing evidence from the CFE Fund’s national Bank On initiative, the letter notes the role that overdraft fees play in breeding mistrust and destabilization, and points out the robust market of over 450 Bank On certified accounts across the country that do not allow overdraft, demonstrating the value of transparency and affordability in banking. This comment letter stresses the value of connecting safe and affordable credit options to basic transaction accounts like those certified through the Bank On National Account Standards, such as with overdraft lines of credit. It is critical that the un- and underbanked, a population overrepresented by people of color, can access transparent and safe short-term credit.
CFE Fund Comment Letter to Treasury on Financial Inclusion Strategy
The CFE Fund recently submitted a comment letter to the U.S. Department of Treasury Office of Consumer Policy in response to a Request for Information on developing a national strategy for financial inclusion. The letter cites evidence from the CFE Fund’s network of Financial Empowerment Center (FEC) municipal partners that demonstrates that access to mainstream banking accounts plays a pivotal role in people’s ability to save money, improve their credit scores, and build strong financial futures. The CFE Fund’s national Bank On movement has also highlighted the unique power of integrating banking access strategies into government service streams to address common access barriers like identification, language, and fees. In this letter, the CFE Fund urged Treasury to focus on large-scale government program and payment opportunities to connect unbanked Americans to mainstream banking, outlining a range of promising “bankable moments” related to federal programs.
The Skyline: How Three Cities Expanded Banking Access to Residents with Alternative IDs
Regulatory requirements to verify a customer’s identity have posed notable barriers to banking for those who may not have traditional government-issued IDs. But local government leaders and community organizations around the country are partnering with financial institutions to flexibly connect consumers to safe banking. Read the full issue here.
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CFE Fund Comment Letter on HUD Eviction Proposal
The CFE Fund recently submitted a comment letter to the U.S. Department of Housing and Urban Development in support of the proposal to provide tenants residing in public housing or receiving housing assistance with at least 30 days‘ notice before initiating formal eviction proceedings. The letter cites the success of a recent CFE Fund pilot focused on eviction prevention, which explored how Financial Empowerment Center (FEC) public counseling services could integrate and support existing emergency rental assistance and eviction prevention efforts. The pilot demonstrated that the period between notice of eviction and formal eviction proceedings is crucial to productive service coordination that benefits both tenants and landlords. The CFE Fund noted that our experience shows that additional time and space to coordinate comprehensive services such as rental assistance, legal aid, housing and financial counseling increases the likelihood that clients will seek them out and achieve positive outcomes and reduce the risk of eviction. Read the full letter here.