August 3, 2020 — Letter

As the Office of the Comptroller of the Currency (OCC) reassesses digital activities permitted by national banks and federal savings associations, the undersigned civil rights and racial justice advocates write to urge the OCC to heed concerns regarding disparate impact, “predatory inclusion,” “digital redlining,” and the “color of surveillance.” We urge the OCC to adopt a precautionary approach to digital banking activities, refraining from assuming these activities are similar to those already permitted via regulations, or that they should be permitted at all.