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The Meeting of the Advisory Committee on Economic Inclusion 

of the 

Federal Deposit Insurance Corporation 

Held virtually via WebEx 

Open to Public Observation via Webcast 

June 28, 2022 – 1:00 P.M. 

The meeting of the FDIC Advisory Committee on Economic 

Inclusion (Committee) was called to order by Martin J. 

Gruenberg, Acting Chairman of the Board of Directors of the 

Federal Deposit Insurance Corporation (Corporation or FDIC). 

Other members of the Corporation’s Board of Directors 

present at the meeting: Michael J. Hsu, Director, Acting 

Comptroller of the Currency, Office of the Comptroller of the 

Currency (OCC); and Rohit Chopra, Director, Consumer Financial 

Protection Bureau (CFPB). 

Committee members present at the meeting: Steven L. 

Antonakes, Executive Vice President for Enterprise Risk 

Management, Eastern Bank; Michael Calhoun, President, Center for 

Responsible Lending; Naomi Camper, Chief Policy Officer, 

American Bankers Association; Thomas Foley, Executive Director, 

National Disability Institute; 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; Jennifer Tescher, President and CEO, 

Financial Health Network; and Christina Tetreault, Deputy 

Commissioner, Office of Financial Technology Innovation, 

California Department of Financial Protection and Innovation. 

Committee members absent from the meeting: Lisa Mensah, 

President and CEO, Opportunity Finance Network; and Raphael 

Bostic, President and CEO, Federal Reserve Bank of Atlanta. 

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585

Corporation staff in attendance: Alys V. Brown, Luke H. 

Brown, Zachary N. Brown, Sylvia W. Burns, Mary Calkins, Cathy 

Choe, Karyen Chu, Kymberly K. Copa, Debra A. Decker, Richard B. 

Foley, Lekeshia Frasure, Pamela A. Freeman, Peggi J. Gill, 

Shannon N. Greco, Patricia S. Gurneau, Emerson B. Hall, Robert 

D. Harris, Stuart L. Hoff, Glenn A. Kivlen, Jonathan N. Miller, 

Elizabeth Ortiz, Jason A. Pan, Mark E. Pearce, Nikita Pearson, 

Harrel M. Pettway, Ryan M. Rappa, Luke W. Reynolds, Marguerite 

Sagatelian, Richard M. Schwartz, Patience R. Singleton, Mona L. 

Thomas, Whitney Thomas Toussaint, John F. Vogel, Lauren A. 

Whitaker, and Meron Wondwosen. 

Acting 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 

Ms. Ortiz opened the meeting by explaining that 

participation by members of the Board of Directors did not 

constitute a Board meeting subject to the public notice 

requirement under the Government in the Sunshine Act (Sunshine 

Act). Hence, general discussions that may occur among Board 

members at the Committee meeting on subjects relevant to the 

FDIC’s responsibilities, but that do not pose specific issues 

for Board resolution, would not constitute a meeting required to 

be open to the public and subject to the Sunshine Act’s 

notification requirements, provided that any such discussions 

are preliminary in nature, that there are no relevant proposals 

for action pending before the Corporation, and that the merits 

of any proposed agency action will be opened to full 

consideration by the Board at a later time. Ms. Ortiz further 

stated that during the meeting if staff identifies matters that 

should be discussed by Board members at a subsequent Board 

meeting to comply with the Sunshine Act, staff would advise the 

Board members that those matters should be deferred and 

presented to the Board in a meeting at a later date, at which 

time Board members would engage in full deliberation on the 

proposals. 

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Ms. Ortiz then introduced Acting Chairman Gruenberg, who 

presided at the meeting. 

Acting Chairman Gruenberg welcomed members to the 

Committee’s first meeting of 2022 and expressed his hope that it 

would be the last virtual meeting. He then introduced the five 

new Committee members present at the meeting: Steven Antonakes, 

Michael Calhoun, Thomas Foley, Brandee McHale, and Kenneth 

Kelly. 

Next, Acting Chairman Gruenberg previewed the members’ 

roundtable and upcoming panels and invited comment by Acting 

Comptroller Hsu, who shared that he had been looking forward to 

this meeting since the October 2021 meeting which he recalled as 

providing a valuable range of perspectives. He said he would 

need to excuse himself from the meeting at 2:00, but was 

interested to hear how higher rates and a more volatile 

environment affect members’ thoughts on inclusion. 

Next, Acting Chairman Gruenberg invited CFPB Deputy 

Director Zixta Martinez to comment on behalf of the CFPB, as 

Director Chopra would join later. Deputy Director Martinez 

discussed the need to increase access to affordable banking 

products and emphasized banks’ obligatory and leading role in 

expanding access to electronic payments. She also mentioned that 

banks should reduce banking and financial inequities by serving 

all areas of the country, including banking deserts, rural 

areas, and communities of color, and ensuring that arbitrary 

customer-level revenue or profitability targets do not impede 

lower-income household access to affordable banking products. 

Deputy Director Martinez also highlighted a few provisions of 

the interagency proposed rule modernizing the Community 

Reinvestment Act (CRA). 

Ms. Ortiz then introduced the members’ roundtable 

discussion. 

Members’ Roundtable 

Member Tetreault highlighted California’s new crypto asset 

executive order aimed at regulatory clarity using existing 

statutory authorities. She noted that the California Department 

of Financial Protection and Innovation has invited public 

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comment on the relationship between crypto assets and financial 

inclusion. 

Member Tescher discussed several recent publications by the 

Financial Health Network (FHN) focusing on the cost of financial 

products and services. She highlighted FHN’s Annual FinHealth 

Spend Report that examines how households manage their finances 

and access credit. She said the report shows a decline in 

spending on interest and fees overall, but also exposes racial, 

ethnic, and income-based disparities in the fees and interest 

paid by customers. She also mentioned FHN’s brief on Buy Now, 

Pay Later programs, its paper on the challenges that revolving 

credit card balances pose to financial health, and potential 

solutions. She also mentioned FHN’s report on medical debt and 

its forthcoming financial health pulse data. 

Member Mintz highlighted growth and development of the 

BankOn program that has grown to 248 certified accounts. He 

discussed his work on scaled banking access integrations, which 

involves inserting banking into programming with payments to 

encourage consumers to open certified accounts. He noted 

BankOn’s work with the IRS and FDIC to encourage people to open 

certified accounts to receive their COVID stimulus payments as 

well as BankOn’s current work involving unemployment payments. 

He said BankOn is currently focused on helping veterans and 

foster youth service recipients open certified accounts. Lastly, 

he discussed BankOn’s direct digital advertising research and 

strategy. 

Member McHale emphasized that this is a period of economic 

volatility as well as financial inclusion and innovation. She 

said that collaboration and the elimination of barriers to 

closing income and wealth gaps are key factors in promoting 

innovation. She cautioned that recent data suggest that wealth 

gaps are worsening and queried whether innovation in the 

financial system is driving effectiveness. She highlighted Citi 

Foundation’s new Action for Racial Equity strategic initiative 

and their commitment to community development financial 

institutions (CDFIs) and minority depository institutions 

(MDIs). 

Member Libby discussed MyPath’s mission, how its youth 

banking standards address how banks can offer quality, 

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accessible accounts for young people, and how the new youth 

economic bill of rights provides information on how to improve 

the entire financial and banking system to make it more 

accessible and useful for young people. Member Libby also 

discussed emerging issues important to young people, including 

guaranteed income and access to financial mentoring and credit 

information. 

Member Kelly discussed the history and growth of First 

Independence Bank in the Minneapolis market following the social 

unrest of 2020. He said work is needed to create educational 

opportunities and awareness to increase appraiser diversity. 

Member Kelly called the CRA proposed rule a once in a lifetime 

opportunity and emphasized that banks are no longer confined by 

geography. He also mentioned requiring financial literacy 

education in schools. 

Member Foley discussed several data points on the 

relationship between people with disabilities and the financial 

system. He encouraged people collecting data to ask questions 

designed to elicit information about the disability community. 

He expressed his excitement about the CRA proposed rule, but 

suggested deeper investment in the disability community. He also 

highlighted digital accessibility issues with bank websites and 

apps not addressed in the CRA proposed rule. 

Member Camper provided an update on the inclusion 

initiatives of the American Bankers Association (ABA), 

specifically BankOn, including its training program for banks 

that offer BankOn certified accounts and its encouragement of 

banks to market BankOn accounts to customers. She also noted 

that the ABA has formed a special MDI advisory council and 

relaunched its “Banks Never Ask That” campaign. 

Member Calhoun discussed COVID-19 pandemic effects on the 

financial system and the wealth gap across the country, 

highlighting the current housing affordability crisis and high 

volatility among lower wealth households. He challenged the 

Committee to think of new ways to build the financial system to 

meet current needs rather than relying on solutions designed for 

previous generations. He noted that the Center for Responsible 

Lending launched a program to help borrowers deal with income 

and expense shocks by creating reserve funds for loans with 

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higher loan-to-value ratios. Member Calhoun also called for 

coordinated regulatory action to address overdraft fees. 

Member Antonakes provided background on Eastern Bank, based 

in Boston with nearly 1 in 3 of their offices located in low and 

moderate income census tracts. He then highlighted economic 

inclusion challenges facing the bank including housing values, 

affordable housing stock, the racial wealth gap, inflation, 

increased cost of living, and public transportation and 

infrastructure. He noted Eastern Bank’s overdraft program 

changes and elimination of non-sufficient funds fees and shared 

that Eastern will soon launch a special-purpose credit program 

for women and minority-owned small businesses. 

Following the roundtable discussion, Ms. Ortiz declared the 

meeting in recess. 

Home Mortgage Appraisal Bias and Efforts to Engender Change 

The Committee reconvened at 2:40 p.m. Ms. Ortiz introduced 

Luke Brown, Associate Director, DCP, FDIC, who launched the 

panel discussion of home mortgage appraisal bias and efforts to 

engender change. He then introduced his fellow panelists: 

Maureen Yap, Senior Counsel, National Fair Housing Alliance 

(NFHA); Kenon Chen, Executive Vice President, Corporate 

Strategy, Clear Capital, who represented the Real Estate 

Valuation Advocacy Association for purposes of the panel; and 

Melody Taylor, Regional Director, Mid-Atlantic Office of Fair 

Housing and Equal Opportunity, Housing and Urban Development 

(HUD), who serves as Executive Director of the Interagency Task 

Force on Property Appraisal and Valuation Equity (PAVE). 

Ms. Yap provided historical context for the appraisal bias 

issue and described proposals for reforming the appraisal 

system. Mr. Chen provided the perspective of appraisal 

management companies and residential property valuation 

providers on the current state and modernization of the 

appraisal system. Ms. Taylor shared information and updates 

about PAVE and its report. 

After the panel concluded its presentation, Member Mintz 

asked where the appraisal profession has fallen short on selfregulation in this area, and how the industry professional 

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association might find their “value-add” to become part of the 

solution. 

Ms. Taylor responded that PAVE’s close work with the 

Appraisal Subcommittee (ASC) on the upcoming legislative 

proposals will be game-changing in expanding governance and 

regulation of appraisers, qualifications, and appraisal 

standards. She said the National Fair Housing Alliance report 

reflects a deep dive into these issues and provides 

recommendations. 

Mr. Chen added that the mortgage industry’s investment in 

moving toward digitized processing affords more transparency and 

oversight, with data being more readily available for analysis, 

and sharing the appraisal data already collected is valuable for 

examining root cause and analysis. 

Next, Director Chopra explained that the ASC mentioned in 

Ms. Taylor’s presentation is a panel of regulators including HUD 

and the Federal Housing Finance Agency (FHFA), and is currently 

chaired by CFPB, with a focus on oversight of the Appraisal 

Foundation. In response to Member Mintz’s question, Director 

Chopra added that many appraisers already feel they have unique 

value to add, but that appraisal management companies limit 

individual appraisers’ ability to do their jobs. Consequently, 

Director Chopra said, a balance must be struck between human 

appraisals and algorithmic appraisals, including automated 

valuation models. He added that the work of NFHA and PAVE has 

moved the appraisal bias issue higher on regulators’ agenda. 

Mr. Brown then asked Ms. Taylor about the biggest 

opportunities and obstacles for government agencies addressing 

the issues in the PAVE action plan. Ms. Taylor responded that 

the main obstacle is time. The action plan allows 2 years to 

reach certain milestones, she explained, so it is important to 

ensure that each federal agency embeds appraisal as part of its 

book of business or portfolio, rather than merely an initiative. 

Despite the time obstacle, she said dialogue and collaboration 

among industry, academia and the Federal Government is an 

important opportunity created by the listening sessions PAVE 

held throughout development of its report. She highlighted the 

synergy among the advocates, industry and government 

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participants on a civil rights issue, on which they are coming 

together to speak with one voice. 

Mr. Brown then asked Ms. Yap what surprised her during her 

work on the PAVE report. She said she was surprised by the 

state of the appraisal industry, where many methodologies have 

not changed in decades. Subjective appraisal measures like 

“character” and deference to appraisals remain “more art than 

science.” She was also surprised by how well the PAVE report 

had been received and how excited the appraisal industry is to 

learn and help shape the conversation. 

Acting Chairman Gruenberg called the PAVE report a case 

study on how to bring to light an important issue of public 

policy. He asked the panelists whether appraisers themselves 

are aware of the extraordinary insularity of the appraisal 

profession, as Mr. Chen had described earlier, and whether they 

are aware of the need for change, and aware that that change 

needs to start with them. 

Mr. Chen responded that growing awareness of the appraisal 

industry’s insularity is one of the unexpected effects of the 

pandemic, which awoke appraisal industry participants to the 

need to depart from traditional approaches. He said the 

pandemic created record volume, requiring new talent, and 

required social distancing and related appraisal flexibilities 

departing from traditional methods, such as embracing technology 

to see into properties without physically visiting. 

Ms. Yap responded that the appraisal industry reacted 

overwhelmingly positively to the report, and is interested in 

what to do next. She emphasized that nothing focuses industry 

like potential enforcement, so she encourages quick action on 

the action plan’s call to federal regulators and enforcement 

agencies to quickly issue public exam procedures and 

investigation procedures so that appraisers, lenders, and 

appraisal management companies know that federal regulators are 

serious about the issue. 

Mr. Brown noted that the banking agencies are extremely 

focused on exam procedures in this area, with more to come. 

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Ms. Taylor likewise responded to Acting Chairman 

Gruenberg’s question by emphasizing enforcement. As the number 

of complaints rises, she said, HUD and its Office of Fair 

Lending and Equal Opportunity are working hard to create quality 

control standards around enforcement work, ensuring there is 

public interest relief when cases or complaints are conciliated 

and that investigators evaluate cases consistently. She added 

that her agency is working closely with the Department of 

Justice (DOJ) and CFPB in discussions around those cases. 

Following the appraisal discussion, Ms. Ortiz thanked the 

panelists and declared the meeting in recess. 

Community Reinvestment Act 

The meeting reconvened at 3:55 p.m. Ms. Ortiz introduced 

Jonathan Miller, Deputy Director, DCP, to moderate the panel on 

the Community Reinvestment Act (CRA). Mr. Miller noted that a 

summary of the CRA discussion would be made part of the public 

record as a comment since the comment period for the proposal is 

still open. Mr. Miller introduced the three panelists: 

Patience Singleton, Senior Policy Analyst, DCP; Pamela Freeman, 

Chief, Fair Lending and CRA Examinations, DCP; and Richard 

Schwartz, Counsel, Legal Division. 

Mr. Miller then described the Corporation’s objectives for 

the proposed rulemaking, which is meant to strengthen the CRA’s 

role in financial inclusion by considering activities that 

address inequities in credit access for low- and moderate-income 

communities. 

Next, Mr. Schwartz provided an overview of key CRA topics 

including assessment areas and qualifying activities. Then Ms. 

Singleton and Mr. Miller discussed the overall evaluation 

framework. Finally, Ms. Freeman described the community 

development financing test and data collection and reporting 

requirements. 

After the presentation, the panel welcomed questions. 

Member Kelly asked how implementation of the plan would look 

five, ten, or fifteen years hence, considering that in 1977 the 

original CRA had the same goal of dealing with inequities. 

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Mr. Miller responded that the goal of the proposed 

rulemaking is to expand the CRA’s reach by evaluating banks 

more broadly geographically. He explained that the proposed 

rulemaking accomplishes that by increasing the current amount of 

lending required for a bank to receive a low satisfactory, high 

satisfactory, or outstanding rating. Therefore Mr. Miller 

expects that if the rule is finalized as proposed (and 

accounting for comments), more credit will be available to low 

and moderate income borrowers and communities. 

Ms. Singleton noted that since rural areas are often 

underserved and metropolitan areas also sometimes lack branch 

access, the proposed rule would increase credit and capital in 

those areas. 

Ms. Freeman added that the proposed rule would address 

inequities and credit access for low and moderate income 

communities, individuals, and families in part by expanding the 

areas where retail lending is considered, which was not done 

before. In other words, she explained that community 

development would be considered everywhere, under a clear list 

of qualifying activities, with preapprovals so banks have 

assurance that their activities will count. She emphasized that 

the standards and implementation will be more rigorous and that 

the proposed rule encourages partnerships with MDIs and 

Treasury-certified CDFIs, and included that as a specific 

definition for community development. 

Member Camper then commented that the proposed change to 

the CRA is historic and acknowledged the significant work that 

went into it. She noted that different banks have different 

capacities for implementation and that her organization and some 

others had submitted a written request for a 30-day extension to 

comment. She anticipated commenting on the retail lending 

assessment area to help the Corporation understand smaller 

institutions’ perspective on whether purely numerical triggers 

make sense for lesser-known banks in a given geographic area, 

and raising alternative methods for the Corporation’s 

consideration that could supplement just a simple loan count. 

She emphasized that the industry understands the momentous 

nature of the proposed rule, and wants both banks and the 

regulators to get it right. 

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Member Mintz noted that in the BankOn world, banks are 

focused on the proposed new retail services and products test, 

about which he made two comments: First, he said it dovetails 

with research on financial empowerment counseling, which shows 

the connection between having a safe bank account and the 

ability to save money and improve credit scores. For that 

reason, he said, industry feels the test correctly identifies 

the metrics indicating that customers are financially ready to 

become homeowners. 

Second, he hoped that data collected concurrently in the 

BankOn world and stored in the Federal Reserve Bank of St. Louis 

BankOn data hub would be useful for examiners to help banks and 

credit unions successfully answer the 15 percent part of the 

CRA’s proposed test. 

Finally, Mr. Mintz asked whether any part of the retail 

services test particularly rewards the ability to open new 

accounts online, consistent with expansion of assessment areas. 

Ms. Singleton responded that the ability to open new 

accounts online is not expressly included in the proposed rule, 

but is covered by the distribution of the bank’s digital and 

other systems. She said the ability to open new accounts online 

could be included under evaluation of a bank’s digital and other 

divisions prong. She agreed it is important and could be 

considered as the Corporation moves forward in the rulemaking 

process. 

Mr. Miller noted the general standard that any product or 

service particularly responsive to low and moderate income 

consumers would receive special consideration, which could 

include opening accounts digitally. 

Mr. Schwartz added that the Corporation would create a list 

of qualified activities, and banks can write in to inquire 

whether certain activities are covered. He said that makes it 

likely digital account opening will be covered. 

Next, Member Foley asked about credit for financial 

literacy activities regardless of income level and whether the 

proposed rule captures the need for accessible housing, which is 

even more difficult to find than affordable housing. 

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In response to Member Foley’s first question, Ms. Freeman 

indicated that there was no required income levels to track 

financial literacy activities because banks reported that when 

they held financial literacy outreach activities, it was 

difficult to actually obtain attendees’ income information. 

Plus, she said the Corporation views financial literacy as 

important across the board. 

With regard to Member Foley’s second question, the 

panelists did not recall accessible housing being included in 

either the preamble or the rule. 

Member Antonakes then asked two questions about thresholds: 

First, had the Corporation considered how to bridge the large 

gap between banks with 2 billion in assets and those at 2 

trillion in assets and whether a “megabank” category was 

considered; and second, if there had been any concern about any 

unintended consequences of the data collection provisions 

kicking in at 10 billion in assets in terms of increased 

compliance cost leading to further consolidation? 

Mr. Miller responded that the threshold discussions 

considered the desired balance between increased efforts that 

would be required to collect and report data and the benefits 

from collecting and having that data. He said they drew the 

line where the assets would cover the increased costs. 

Next, Member Libby encouraged the Corporation to be open to 

including non-custodial accounts for young people in certain 

subcategories, and to consider small, entry level, safe creditbuilding products that were previously more widely available as 

a pathway to credit. 

Ms. Singleton confirmed that credit-building products would 

be considered under the services test, have always received CRA 

consideration, and that under the proposal there is an increased 

emphasis on the quantitative and qualitative aspects. 

Closing Remarks 

Director Chopra then made a statement about the CRA, 

emphasizing that policymakers should consider not just the 

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596

creditworthiness of consumers, but whether credit is worthy of 

the people it serves, and how to ensure all mortgage lenders are 

serving all qualified applicants, especially in neighborhoods 

that have been historically excluded. 

Acting Chairman Gruenberg said he expects the Committee’s 

next meeting, on October 27, 2022, to be held in person. He 

noted that the Corporation’s latest household survey of who is 

unbanked and underbanked in the nation would be released at that 

October meeting. 

There being no further business, the meeting adjourned at 

4:55 p.m. 

/s

Debra A. Decker 

Deputy Executive Secretary 

Federal Deposit Insurance Corporation 

and Committee Management Officer 

FDIC Advisory Committee on Economic 

Inclusion 

June 28, 2022 
 

 

 

________________________________ 

Minutes 

of 

The Meeting of the FDIC Advisory Committee on Economic Inclusion 

of the 

Federal Deposit Insurance Corporation 

Held Via Webcast 

Federal Deposit Insurance Corporation Building 

Washington, D.C. 

Open to Public Observation 

June 28, 2022 – 1:00 P.M. 

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

complete. 

/s

Martin J. Gruenberg 

Acting Chairman 

Board of Directors 

Federal Deposit Insurance Corporation