Comments on Developing National Strategy for Financial Inclusion

Overall, ICBA believes a national strategy on financial inclusion will help identify policies and programs that can augment community bank efforts to deploy capital in their local communities.

Specifically, ICBA believes that financial inclusion can be increased so long as Treasury’s national strategy incorporates the following recommendations: (1) reexamine policy to promote creation of de novo bank charters, (2) produce guidance that encourages certain behaviors, (3) create a consistent regulatory environment that promotes innovation, (4) measure indirect cost of regulations on low-to-moderate income (“LMI”) populations, and (5) facilitate collaboration among the Federal Banking Agencies.