Association of Military Banks of America

Community Reinvestment Act Official Comments Submitted to OCC

The Office of the Comptroller of the Currency (OCC) recently issued an Advance Notice of Proposed Rulemaking (ANPR) inviting comments on ways to modernize its Community Reinvestment Act (CRA) regulations.

AMBA submitted our comments on 16 November.  We invite you to read our comment letter.  Our overarching objective was to seek CRA credit for any bank that provides financial support, services, and education to military members, their families, and veterans.  We also recommended that CRA credit be given to banks that employ veterans and military spouses.

We hope the OCC will embrace the ideas underlying our proposals.  If it does, perhaps we can balance a CRA benefit that will incentivize banks to serve the military and veteran communities against laws and regulations (e.g., MLA and SCRA) that don’t.