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CoverStory

• Community Reinvestment Act Renard thanked House Financial Institutions subcommittee chairman
(CRA): The Community Rein- Blaine Luetkemeyer, R-Mo., and senior House Financial Services Commit-
vestment Act of 1977 requires tee member Carolyn Maloney, D-N.Y., for their ongoing support. Their
banks to "demonstrate that Oct. 17, 2018, letter petitioned the Comptroller of the Currency, FDIC
their deposit facilities serve the and Federal Reserve, requesting an end to bank account closures, stating
convenience and needs of the "there is no evidence or indication of any improper or unlawful conduct
communities in which they are being undertaken in or through [independent, nonbank ATM owner/op-
chartered to do business." NAC erator] accounts.
members propose amending
the CRA to ensure that alterna- "The unfortunate reality is that this issue is not limited to independent
tive systems for delivering retail ATM operators alone," wrote Reps. Luetkemeyer and Maloney. "Many
banking services, such as bank
and nonbank ATMs and a vari-
ety of other phone and Internet
services, are available to con-
sumers.

Ideally, assessing a bank's
CRA performance would
entail considering whether the
institution's practices restrict
the effectiveness of alternative
methods for delivering retail
banking services. Historically,
despite the Act's unambiguous
statutory language, enforcement
has centered more on financial
institution activities in
providing credit services than
on providing alternative deposit
services, NAC representatives
stated.

• Bank account closures: ATM
owners and deployers must
meet rigorous compliance and
licensing standards but are
still viewed as high-risk busi-
nesses by financial institutions,
Renard said. Problems began
with Operation Choke Point,
an anti-fraud initiative that of-
ficially ended on Aug. 16, 2017,
but led to stringent "de-risking"
policies. These policies continue
to inhibit NAC members and
other business owners in desig-
nated high-risk industries from
opening and maintaining bank
accounts, according to NAC
representatives. NAC contin-
ues to advocate on behalf of its
members, working to eradicate
OCP's unwelcome residual ef-
fects on the independent ATM
community and resolve this
emotionally charged issue, Re-
nard stated.

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