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CRA Modernisation Comment Letter

by Varo Bank

August 15, 2022

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Why we need a strong, modernized CRA

Varo Bank is an ardent supporter of the Community Reinvestment Act (CRA) and we applaud the cross-functional collaboration of the OCC, FRB, and FDIC on this CRA modernization proposal. The interagency process is essential for ensuring that the CRA is applied consistently and transparently across all depository institutions, regardless of their primary regulator.

The last major overhaul of the CRA was in 1995, a time when bank branches were the primary provider of financial services. The financial services industry has evolved substantially since that time, most noticeably with the proliferation of mobile and online banking. At Varo Bank, we currently have millions of retail customers across the country and no bank branches. We are using technology to meet the evolving needs of consumers living in a digital-first world and to serve unbanked and low- to moderate-income populations that have been excluded from the traditional financial system. Our work and our mission at Varo is consistent with the spirit of CRA and we hope our unique voice as a digital-only bank can help ensure the final CRA rule achieves the goals of better serving LMI communities and underserved populations.

 

Read our full letter on modernizing the Community Reinvestment Act here.

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