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611

The Meeting of the Advisory Committee on Economic Inclusion 

of the

Federal Deposit Insurance Corporation 

Held in the Board Room

Federal Deposit Insurance Corporation Building 

Washington, D.C.

Open to Public Observation via Webcast 

November 2, 2023 – 9:00 A.M.

The meeting of the FDIC Advisory Committee on Economic 

Inclusion (ComE-IN or Committee) was called to order by Martin

J. Gruenberg, Chairman of the Board of Directors of the Federal

Deposit Insurance Corporation (Corporation or FDIC).

The members of ComE-IN present at the meeting were Steven

L. Antonakes, Executive Vice President for Enterprise Risk

Management, Eastern Bank; Marla Bilonick, President and CEO,

National Association for Latino Community Asset Builders;

Raphael Bostic, President and CEO, Federal Reserve Bank of

Atlanta; Michael Calhoun, President, Center for Responsible

Lending; Naomi Camper, Chief Policy Officer, American Bankers

Association; Kenneth Kelly, Chairman and CEO, First Independence

Corp and First Independence Bank; Margaret Libby, CEO and

Founder, MyPath; Brandee McHale, Head of Community Investing and

Development, Citi and President, Citi Foundation; Jonathan

Mintz, President and CEO, Cities for Financial Empowerment Fund;

Marietta Rodriguez, President and CEO, NeighborWorks America; and

Susan Weinstock, President and CEO, Consumer Federation of

America.

Members Thomas Foley, Executive Director, National 

Disability Institute; Ida Rademacher, Vice President, Aspen 

Institute and Co-Executive Director, Aspen Financial Security 

Program; and Jennifer Tescher, President and CEO, Financial 

Health Network, were absent from the meeting.

Members of the Corporation’s Board of Directors present at 

the meeting were Martin J. Gruenberg, Chairman; Travis J. Hill, 
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Vice Chairman; and Michael Hsu, Director, Acting Comptroller of 

the Currency. 

Corporation staff who attended the meeting included James L.

Anderson, Alys V. Brown, Watina (Renee) Cash, Kymberly K. Copa, 

Angela Dean, Debra A. Decker, Paola L. Diaz, Lewis Dorman, 

Camron A. Doss, Keith S. Ernst, Lekeshia Frasure, Pamela A.

Freeman, David J. Friedman, Fasil Getachew, Shannon N. Greco,

Deva Helmand, Nicholas S. Kazmerski, Candace B. Matzenauer, 

Katheleen M. McDill, Jonathan N. Miller, Steven R. Murphy, John 

E. Ochoa Espitia, Elizabeth Ortiz, Mark E. Pearce, Harrel M.

Pettway, Ariana L. Rambuyan, Ryan M. Rappa, Kristopher Rengert,

Marguerite Sagatelian, David L. Sharp, James P. Sheesley,

Nefretete A. Smith, Jacqueline R. Steller, Jessica L. Thurman,

Lauren A. Whitaker, Kenneth R. Worthey, Montrice G. Yakimov, and

Clarisse A. Young.

Chairman Gruenberg presided over the proceedings. Elizabeth 

Ortiz, Deputy Director, Consumer and Community Affairs, Division 

of Depositor and Consumer Protection (DCP), and the Committee’s 

Designated Federal Officer, served as moderator.

Opening Remarks

Chairman Gruenberg opened the meeting by welcoming the 

members of the Committee and recognizing the newest member of the

Committee, Marietta Rodriguez, President and CEO of NeighborWorks 

America. Next, Chairman Gruenberg provided an overview of the 

meeting Agenda. Regarding the first matter on the Agenda, 

Chairman Gruenberg commented on the significance of the recent 

Community Reinvestment Act (CRA) rulemaking. Chairman Gruenberg

then invited Acting Comptroller Hsu to make brief opening 

remarks. Acting Comptroller Hsu thanked Chairman Gruenberg and 

echoed his comments on the significance of the CRA rulemaking, 

noting that it comes at a critical time. Following these 

remarks, Chairman Gruenberg invited Ms. Ortiz to introduce the 

first panel presentation. 

Ms. Ortiz first read a notice regarding the Government in 

the Sunshine Act (Sunshine Act). The statement explained that 

the meeting is not a meeting of the FDIC Board of Directors under 

the Sunshine Act. Ms. Ortiz explained that the Board members 

present would only engage in general or preliminary discussions 

that do not relate to specific proposals for action pending 

before the FDIC, and that any specific issues for Board 
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resolution will remain open for full consideration by the Board 

after the meeting.

Community Reinvestment Act (CRA) Final Rule

Ms. Ortiz introduced Jonathan Miller, Deputy Director, 

Policy and Research, DCP, to moderate the presentation on the 

CRA Final Rule. Mr. Miller introduced the panelists: Pamela 

Freeman, Senior Examination Specialist; Kristopher Rengert, 

Senior Consumer Researcher; and, Jessica Thurman, Chief, Fair 

Lending and CRA Examination. 

Mr. Miller began by highlighting the four objectives behind 

the CRA Final Rule (Final Rule): (1) encouraging banks to expand 

access to credit investment and banking services in low- or 

moderate-income (LMI) communities; (2) adapting to changes in the 

banking industry, including mobile and online banking; (3) 

providing greater clarity and consistency in the application of 

CRA regulations; and (4) tailoring CRA evaluations and data 

collection to bank size and business model. Ms. Freeman then 

compared the evaluation framework from the current rule with the 

Final Rule and discussed the Final Rule’s community development 

activity provisions. Ms. Thurman discussed the four performance 

tests for large banks under the Final Rule: the Retail Lending 

Test, Retail Services and Products Test, Community Development 

Financing Test, and Community Development Services Test. Mr. 

Rengert remarked on the Final Rule’s different assessment areas, 

ratings, and tailoring of data requirements and Ms. Thurman 

commented on the tailoring of tests to each geographic area, 

based on local opportunities and economic conditions.

Following the presentation, Committee members congratulated

the panelists on issuing the Final Rule. The Committee members 

also asked questions about a number of topics, including: 

consideration of auto lending; future guidance on the data 

expected to be collected by banks for examinations; consideration 

of responsive deposit products; how community development 

activities occurring outside of the facility-based assessment 

area will be considered; the scope and frequency of future CRA 

examinations; the role of community development organizations in 

implementing the Final Rule; the role of race and ethnicity in 

defining assessment areas; examiner training on the Final Rule; 

the Final Rule’s asset size thresholds, and the “illustrative 

list” of CRA qualified community development activities. 
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The meeting then recessed from 10:24 a.m. to 10:47 a.m.

Updating the FDIC Economic Inclusion Strategic Plan

When the meeting resumed, Ms. Ortiz introduced Montrice 

Yakimov, Acting Associate Director, Community Affairs, DCP, to 

moderate a panel presentation on Updating the FDIC Economic 

Inclusion Strategic Plan. Ms. Yakimov introduced the panelists: 

Zoya Aleem, Senior Analyst, Abt Associates; Dr. Lianne Fisman, 

Science and Research Senior Director, Abt Associates; and Sarah 

Wolff, Senior Associate, Abt Associates. 

Ms. Aleem began by providing an overview of the research Abt 

completed to inform the update to the FDIC 2019 Economic 

Inclusion Strategic Plan (Plan) and to shape the primary focal 

areas (opportunity areas) in the next Plan. The research 

included a literature review, stakeholder interviews, and 

listening sessions with FDIC staff and external stakeholders. 

Stakeholders desired the Plan to be a tool for communicating to 

external audiences: (1) that economic inclusion is an area of 

interest for the FDIC; and (2) opportunities for partner 

engagement, while maintaining flexibility for emerging 

opportunities. Ms. Aleem also discussed the opportunity areas 

from the 2019 Plan.

Dr. Fisman offered further insights from the interviews and 

research, most notably the desired reconceptualization of 

opportunity areas in the Plan to emphasize consumer and community 

outcomes, particularly for underserved populations, instead of 

utilization of bank products. As an example, Dr. Fisman noted 

that the 2021 FDIC National Survey or Unbanked and Underbanked 

Households indicated only 4.5% of US households are unbanked, 

while it also showed continued disparities across demographic 

groups, particularly households of color as compared to White 

households. Dr. Fisman further acknowledged that there are 

external forces, like inflation and climate change, that can 

inhibit progress on economic inclusion. Furthermore, Dr. Fisman 

explained that consumers cited trust and related issues, such as 

transparency, as the main barrier for them from achieving greater 

economic inclusion. Dr. Fisman also noted that banks cited 

barriers to greater economic inclusion, such as a perception of a 

lack of profitability, compliance concerns, and internal 

infrastructure that prevent adoption of technologies that may 

better serve LMI consumers.
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Ms. Wolff spoke about tools and strategies banks can use to 

advance economic inclusion. These include developing products 

and making product changes to better meet the needs of 

underserved consumers, developing partnerships with other 

organizations that work with those communities, and applying 

different marketing and communications approaches with those 

communities. Ms. Wolff commented that the next Plan can focus on 

the desired outcomes for consumers and communities and provided

some examples of how the FDIC can approach different emerging 

opportunity areas. 

Committee members then posed questions to the panel. 

Members asked about: the timeframe for the research conducted, 

the panel’s thoughts on the shift from a product-focused 

framework to an outcome-focused framework in the next Plan, and 

how the FDIC will leverage its strengths as a regulator while 

taking an outcome-focused approach. Committee members also 

provided a number of comments based on the research and insights. 

In particular, Committee members displayed support for taking an 

outcome-focused approach. One member noted that the outcome 

focus helps to inspire and empower the FDIC, along with others, 

to work together to take “big swings” towards economic inclusion. 

Other members commented on the importance of trust between LMI 

communities and their financial institutions.

The meeting then recessed from 12:03 p.m. to 1:21 p.m.

Members’ Roundtable

Ms. Ortiz next introduced the members’ roundtable discussion

before turning the meeting over to the Committee members to 

provide updates on what is happening in their organizations and 

the communities they serve. The Committee members discussed a 

wide range of topics, including the following: affordable housing 

challenges, fraud attempts related to bank products, the racial 

wealth gap, concerns over inflation, and partnership 

opportunities to better reach LMI communities. A couple of 

members made note of inflationary pressures creating strain on 

the housing market, where affordable stock is already low. One 

member mentioned that these factors are making community 

investment deals more complex and sophisticated, which in turn is 

making it more difficult to attract and retain well-trained staff

given the challenging environment. Members also discussed certain 

programs conducted by their organizations, including those which: 

provide training opportunities for Black mortgage loan officers, 
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find housing counselors and financial coaches representative of

communities of color, offer loan guarantees on automotive 

lending, administer bilingual campaigns to protect consumers 

against fraud, and provide financial education for young adults 

aged 18-24. Additionally, members provided updates on other 

current happenings and work streams occurring at their 

organizations. Multiple members also thanked the FDIC for their 

commitment to economic inclusion and praised the CRA Final Rule. 

The meeting then recessed from 2:39 p.m. to 2:51 p.m.

Bank Small Dollar Lending Programs (SDLPs)

Ms. Ortiz welcomed Vice Chairman Hill to the meeting. She 

then introduced David Friedman, Special Advisor to the Director, 

DCP, as moderator for the panel presentation on Bank Small Dollar 

Lending Programs (SDLP or SDLPs). Mr. Friedman was joined by 

fellow panelists Chuck Bevan, Product Management Executive, Bank of 

America; Alex Horowitz, Project Director, Housing Policy Initiative, 

The Pew Charitable Trusts; Tiffany Pack, Product Group Manager, 

Standby Cash, Huntington National Bank; and, Melanie Stern, Vice 

President, Community Reinvestment Act Officer, and Director of 

Consumer Lending, Spring Bank. 

Mr. Friedman began by noting that small dollar lending was 

the focus of the inaugural Committee meeting in 2007. He also 

highlighted 2020 interagency guidance issued by the FDIC, OCC, 

Federal Reserve, and NCUA that provides lending principles for 

offering responsible small dollar loans. Mr. Horowitz then 

provided some background statistics to emphasize the opportunity 

for SDLPs in the market. Mr. Horowitz focused his presentation 

on SDLPs from six of the eight largest banks. He shared that 

SDLP products need to meet customers where they are, by providing 

speed, ease of access, and certainty of approval. 

Mr. Bevan, Ms. Pack, and Ms. Stern each discussed details of 

their organizations’ SDLPs. Mr. Bevan described Bank of 

America’s Balance Assist SDLP, which offers loans up to $500, 

repayable in three equal monthly installments, to clients through 

their Bank of America mobile application. Mr. Bevan explained 

that borrowers must have a 12-month checking history with Bank of 

America and cannot take out more than six (6) Balance Assist 

loans in a 12-month period. He also stated that the Balance 

Assist program has disbursed 1.1 million loans since launching in 

March 2021.
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Ms. Pack described Huntington Bank’s Standby Cash SDLP. Ms. 

Pack explained that Standby Cash, launched in May 2021, is a line 

of credit up to $500 offered to checking account customers. She 

stated that customers are given three months to repay and are not 

charged interest with autopay (otherwise, the charge is 1% per 

month). Ms. Pack noted that these loans are underwritten 

strictly from deposit behavior; however, Huntington does report 

the loans to credit bureaus in order to help consumers build 

their credit history. She also emphasized the importance of 

convenience and access for SDLPs. 

Ms. Stern spoke about Spring Bank’s Employee Opportunity 

SDLP, in which the bank partners with employers and uses 

employment status in lieu of a credit score to offer small dollar 

loans. She highlighted that Spring Bank was founded in the 

poorest congressional district in the country, the South Bronx, 

to demonstrate the need for SDLP products offering by Spring 

Bank. Ms. Stern also remarked on technology being essential to 

operate a program like this. Ms. Stern stated that Spring Bank’s 

SDLP has disbursed $9 million to date. 

Following the presentation, Committee members provided some 

comments and asked a number of questions. Topics discussed 

included: loss rates and performance of the SDLPs; barriers to 

expansion of SDLPs; overdraft practices; how banks are discussing 

SDLPs internally; the predictiveness of different eligibility 

criteria; experimenting with built-in savings requirements 

alongside the loans; and how the SDLP products have impacted 

consumers’ account balances. Members also discussed how changes 

to bank practices related to overdraft and NSF fees is an 

important development related to consumers’ use of SDLPs.

Closing Remarks

Chairman Gruenberg delivered closing comments on the content 

of the presentations and thanked the members and the staff for 

their contributions to the meeting. 

There being no further business, the meeting was adjourned 

at 4:07 p.m.

____________________________________

Debra A. Decker

Executive Secretary
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618

Federal Deposit Insurance Corporation

And Committee Management Officer

FDIC Advisory Committee on Economic 

Inclusion
Minutes

of

The Meeting of the FDIC Advisory Committee on Economic Inclusion

of the

Federal Deposit Insurance Corporation

Held in the Board Room

Federal Deposit Insurance Corporation Building

Washington, D.C.

Open to Public Observation

November 2, 2023 – 9:00 A.M.

I hereby certify that, to the best of my knowledge, the attached minutes are accurate and 

complete.

________________________________

Martin J. Gruenberg 

Chairman

Board of Directors

Federal Deposit Insurance Corporation