Voices of CDFIs, MDIs, and LICUs: A Listening Session on CRA Proposed Rulemaking

July 14, 2022

• Should the agencies [the Federal Reserve, OCC, and FDIC] also include in the MDI definition insured credit unions considered to be MDIs by the National Credit Union Administration?
• Should the agencies consider activities undertaken by an MDI or WDI [women’s depository institution] to promote its own sustainability and profitability? If so, should additional eligibility criteria be considered to ensure investments will more directly benefit low- and moderate-income and other underserved communities?
• Should the proposed factor focused on activities supporting MDIs, WDIs, LICUs, and Treasury Department-certified CDFIs exclude placements of short-term deposits, and should any other activities be excluded? Should the criterion specifically emphasize equity investments, long-term debt financing, donations, and services, and should other activities be emphasized?
• Should the agencies provide more specific guidance regarding what credit products and programs may be considered especially responsive, or is it preferable to provide general criteria so as not to discourage a bank from pursuing impactful and responsive activities that may deviate from the specific examples?