The Center for Responsible Lending, National Community Reinvestment Coalition, the National Consumer Law Center, on behalf of its low-income clients, and Arthur E. Wilmarth, Jr., Professor Emeritus of Law at George Washington University Law School appreciate the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the Board) supplemental notice and request for comment on the proposed Guidelines for Evaluating Account and Services Requests.
These comments address our concerns about, and opposition to, providing access to Tier 2 and Tier 3 entities, which are not insured depository institutions. In brief, providing this access would inappropriately provide banking privileges to entities that do not have the full oversight or responsibilities of insured depository institutions. Doing so is, we believe, outside the Board’s authority, would enable evasion of reinvestment obligations, would pose risks to the financial system, and would encourage evasions of consumer protection laws. As described in more detail below.