CFE Comment Letter to the FDIC on Reform of the Community Reinvestment Act

The CFE Fund submitted a comment letter to the Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency in response to their request for comment on the proposed reform of the Community Reinvestment Act (CRA). The letter expresses the CFE Fund’s concern that a change to the CRA evaluation methodology that focuses purely on quantifiable CRA activities may undermine support for broader financial inclusion efforts that are more difficult to value, such as increasing access to safe and affordable banking accounts and investments in account opening partnerships.

CFE Fund Comment Letter to CFPB on Overdraft Rule

The CFE Fund submitted this 2019 comment letter to the Consumer Financial Protection Bureau (CFPB) in response to the Bureau’s request for feedback on review of the Overdraft Rule. Based on its programmatic experience working with over 80 municipal governments and community organizations across the country, the CFE Fund urged the CFPB not to change the Overdraft Rule. Overdraft fees push millions of consumers outside of the financial mainstream, and serves as a barrier for the previously unbanked to rejoin the system – joining the financial mainstream is a critical component of financial stability. In addition, the market is already moving in a positive direction towards no-overdraft products; changing the Overdraft Rule risks slowing the success of this positive shift.

CFE Coalition Comment Letter to CFPB (2019)

The 16-member CFE Coalition has weighed in on key federal policy issues since its founding in 2008. In this 2019 letter, the Coalition responds in opposition to the Consumer Financial Protection Bureau’s (CFPB) Notice of Proposed Rulemaking (NPRM) rescinding ability-to-repay requirements governing payday, vehicle title, and certain high-cost installment loans. The Coalition believes these underwriting provisions are crucial, and rescinding them would weaken a much needed rule intended to protect individuals and families from the harmful effects of high-cost and often predatory payday and car-title loans.

This letter focuses on local governments’ experiences with consumer financial instability, and both individual’s and businesses’ need for a fair and dependable consumer financial marketplace. The CFE Fund’s letters also emphasized governments’ interest in preserving and protecting social service gains from predatory business practices that would strip them away, and offered to assist current leadership to help achieve these critical priorities.

CFE Fund Comment Letter to the Federal Reserve on Faster Payments

The CFE Fund submitted a comment letter to the Board of Governors of the Federal Reserve System in response to their request for public comments on the need for new infrastructure that can enable ubiquitous, nationwide access to safe and efficient faster payments. Speaking from the CFE Fund’s programming and research experience working with nearly 70 mayors across the country, particularly in regard to those that are unbanked, this comment letter calls out the lack of real-time payment and settlement systems as one of the top barriers discouraging people from connecting into the stability of the financial mainstream, and urges a real time payment system.

CFE Coalition Comment Letter to the Office of the Comptroller of the Currency

The CFE Coalition submitted a comment letter to the Office of the Comptroller of the Currency (OCC), in response to their request for public comments on amendments to the Community Reinvestment Act of 1977 (CRA). This letter focused on the CFE Coalition’s support for modernizing the CRA to meet the changing needs of member banks, while preserving the original intent of the law. Based on the Coalition’s on-the-ground experience expanding financial access to millions of people, the CFE Coalition offers recommendations regarding the definition of CRA assessment areas, the eligibility of activities that could receive consideration during the examination process, maintaining and strengthening the service test and ensuring that any proposed evaluation methodology does not undermine the value and incentive for banks to work with local communities.

 

CFE Fund Comment Letters to the Consumer Financial Protection Bureau

The CFE Fund submitted Comment Letters to the Consumer Financial Protection Bureau (CFPB) in response to their request for public comment. Topics include: Civil Investigative Demands and Associated Processes, Rules of Practice for Adjudication Proceedings, Enforcement Processes, Supervision Programs, External Engagements, Public Reporting Practices of Consumer Complaint Information, Rulemaking Processes, Adopted Regulations and New Rulemaking Authorities, Inherited Regulations and Inherited Rulemaking Authorities, Guidance and Implementation Support, Financial Education Programs, and Consumer Complaint Handling Processes.

These letters focused on local governments’ experiences with consumer financial instability, and both individual’s and businesses’ need for a fair and dependable consumer financial marketplace. The CFE Fund’s letters also emphasized governments’ interest in preserving and protecting social service gains from predatory business practices that would strip them away, and offered to assist current leadership to help achieve these critical priorities.