Category: Letter

The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) released a Notice of Proposed Rule Making regarding the future of Community Reinvestment Act (CRA) rules.

The CFE Fund submitted comments on the proposed future rulemaking, urging regulators to consider the multi-sector Bank On successful partnerships, and highlighting the important role of mainstream deposit products in opportunities like credit building and broader financial stability. Read the comment letter here.

The CFE Fund recently submitted a letter to the U.S. Department of Treasury Office of Consumer Policy regarding the Financial Literacy and Education Commission (FLEC)’s annual review of the U.S. National Strategy for Financial Literacy. Citing the findings of the Bank On movement, we urged FLEC to take advantage of this review as an opportunity to identify bankable moments–recurring points at which individuals receive income or engage with public systems and are making immediate decisions about how to manage their money. In particular, we identified 9 examples of bankable moments — from IRS tax refunds to veterans benefits to Housing Choice vouchers. By leveraging these moments, the federal government can help bring more consumers into the financial mainstream.

Read the full letter here.

The CFE Fund recently submitted a letter to the Federal Deposit Insurance Corporation in response to their request for comment on the proposed rulemaking rescinding the 2023 Community Reinvestment Act Final Rule (CRA). Citing the findings of our Bank On and Financial Empowerment Center initiatives—which have demonstrated how access to safe and affordable banking accounts is imperative to individual financial stability—we urged supervising agencies to ensure that banks offering accounts that benefit the local community receive CRA credit, regardless of the rule set chosen by regulators. This credit serves as a significant motivator for financial institutions to continue offering these pivotal accounts.

Read the full letter here.

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.

Read the full letter here.

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. 

Read the full letter here. 

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.

Read the full letter here.

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.

Read the full letter here.

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.  

Read the full letter here. 

 

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.

The CFE Fund recently submitted a comment letter to the Board of Governors of the Federal Reserve System regarding their proposal to update the maximum interchange fees that can be charged by covered debit card issuers. The letter notes the CFE Fund’s learnings from our national Bank On initiative, which partners with financial institutions, community organizations, government leaders, and banking regulators to create pathways for un- and underbanked individuals to enter or reenter the financial mainstream with safe banking accounts; Bank On certified accounts have played a key role in programmatic banking access connections from local summer youth jobs programs to the U.S. government’s emergency pandemic relief funds. The fee limitations and features designated under the Bank On Standards were designed not just to meet consumer need but to be economically sustainable for financial institutions. The CFE Fund noted that our experience shows that interchange fees are a key part of that market sustainability. Read the full comment letter here.