First, a bank has to want to do business in Indian country. If it doesn't have the desire, if it's paralyzed by fear or ignorance or apathy, then a thousand CRA laws won't make it happen. Second, a bank must have patience. Progress doesn't happen overnight. Tribal officers come and go.
Bank officers come and go.
Trust takes time and commitment. There has to be continuity. Third, bankers have to understand Indian customers as they would any other customer. Get out and meet them. Get acquainted with tribal leaders.