CUNA strongly advocated against efforts to have the Office of the Comptroller of the Currency (OCC) recommend that the Community Reinvestment Act be expanded to apply to credit unions in a letter written Tuesday. CUNA responded to an advanced notice of proposed rulemaking from the OCC on reforming the CRA regulatory framework.
“As the OCC considers the steps needed to modernize the CRA, it is essential for the Agency to be mindful of the distinctions between banks and credit unions,” the letter reads. “Accordingly, CUNA, credit unions, and the 110 million members they serve, urge the OCC to reject calls to recommend expanding CRA to apply to credit unions. We believe that a recommendation to that effect would be wholly inappropriate given CRA’s inapplicability to credit unions and the OCC’s lack of authority over credit unions.”
The letter goes on to note that, without being subject to the CRA, credit unions have a strong record throughout their history of meeting the needs of traditionally underserved communities as part of their mission.
“For example, since 2010, federal credit unions’ efforts to expand into underserved areas gave nearly 30 million individuals living in traditionally underserved communities new access to credit union services,” the letter reads. “This expansion in outreach stands in stark contrast to the actions of banks—which have closed nearly 9,000 bank branches since 2010.5 Countless studies, reports, and analysis have shown that those bank branch closures have disproportionately impacted traditionally underserved or low- and moderate-income communities.”
CUNA also pointed out that expanding the CRA to apply to credit unions is unnecessary, burdensome and could have an unintended impact of reducing access to credit.
“Because the mission obligations of credit unions already provide the impetus to serve underserved communities and individuals, any decision to expand CRA to include credit unions would not only be duplicative, but would also impose unnecessary additional costs for compliance,” the letter reads.