OCC Responsible Innovation Comment Letter
May 31, 2016
Office of the Comptroller of the Currency
400 Seventh Street, SW
Washington, DC 21219
RE: Supporting Responsible Innovation in the Federal Banking System
Dear Sir or Madam:
The undersigned national organizations – representing developers, owners, investors and lenders of affordable rental housing in urban, suburban, and rural areas – appreciate the opportunity to comment on the OCC’s white paper on Supporting Responsible Innovation in the Federal Banking System. Banks are a critically important source of financing for affordable rental housing.
We support the OCC’s recognition that ensuring fair access to financial services includes financing affordable rental housing. We are further encouraged to read that: “The OCC may also issue guidance on its expectations related to products and services designed to address the needs of low- to moderate-income individuals and communities and may encourage innovative approaches to financial inclusion by promoting awareness of other activities that could qualify for Community Reinvestment Act [(CRA)]consideration.” (page 8)
Our members variously seek and provide financing for affordable housing. We frequently hear that CRA would far more effectively encourage financing for affordable housing, including through innovative financial products and delivery systems, if the OCC and its colleague banking agencies provide greater clarity, certainty, and consistency with regard to how affordable housing activities will receive CRA consideration. Indeed, changes in the affordable housing and banking industries make improved guidance increasingly urgent. We note that the following recommendations would not require changes to the CRA regulation or to the underlying statute.