WASHINGTON- The National Bankers Association (NBA), the leading voice for the nation’s Minority Depository Institutions (MDIs), today expressed deep disappointment with the Office of the Comptroller of the Currency’s (OCC) June 16 revision to its policy statement on minority depository institutions, which narrows the long-standing standard used to designate national banks and federal savings associations as MDIs. At the same time, the Association emphasized that the change applies only to OCC-supervised institutions, that existing MDI designations remain in place, and that a constructive path forward, anchored in the statute and in partnership with the U.S. Department of the Treasury, remains open.
For more than three decades, Section 308 of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 has reflected a bipartisan national commitment to preserve and promote MDIs — the community institutions that serve millions of Americans and small businesses in neighborhoods too often overlooked by the broader financial system. MDIs have long extended credit, built wealth, and strengthened local economies far beyond their size. That mission has not changed, and neither has the NBA’s resolve to advance it.
The OCC’s revised policy removes the established understanding that ownership by members of minority communities satisfies the statutory designation standard, replacing it with an undefined test and eliminating prior agency flexibility. While current designations are maintained, the NBA is concerned that the change introduces real uncertainty; for institutions seeking designation and for existing MDIs navigating future growth and capital transactions, uncertainty that could chill the very formation and preservation of MDIs that the law was enacted to encourage.
Importantly, this is, for now, an OCC-only action. The frameworks administered by the Federal Deposit Insurance Corporation, the Federal Reserve, and the National Credit Union Administration remain unchanged, and the overwhelming majority of the nation’s MDIs continue to operate under the established standard. The NBA respectfully urges those agencies, and the Treasury Department in its statutory coordinating role, to preserve continuity and a uniform federal approach, so that the progress of the last thirty-five years is not unwound.
Section 308 directs Treasury to consult with the federal banking agencies on the best methods for achieving the statute’s goals, and the agencies report annually to Congress on their efforts. The NBA stands ready to work with Treasury, the OCC, and the other regulators to ensure the MDI framework remains faithful to its statutory purpose: durable, workable, and clear for the institutions that rely on it.
“Minority depository institutions are a proven, bipartisan success story — they bring banking, credit, and opportunity to communities that need it most,” said Nicole Elam, President and CEO of the National Bankers Association. “We are disappointed by the OCC’s decision, but we are clear-eyed and constructive about the path ahead. The overwhelming majority of MDIs are unaffected today, and we intend to keep it that way. We are asking Treasury and the other banking regulators to stand with us in preserving a framework that Congress built and that has served this country well.”
“This is a moment to come together, not to retreat,” Elam added. “Our member institutions, our partners, and the communities we serve have overcome far greater challenges. We will engage every constructive avenue; with the regulators, with Treasury, and with Congress, to protect and strengthen the MDI mission.”
The Association calls on its members, partner institutions, community organizations, and supporters across the public and private sectors to stand together in support of MDIs and the communities they serve.
About the National Bankers Association
Founded in 1927, the National Bankers Association (NBA) is the premier trade association representing the nation’s mission-driven banks. NBA’s mission is to strengthen mission-driven banks through advocacy, research, partnerships, and innovation, ensuring that financial services are accessible, affordable, and inclusive for all. For more information visit nationalbankers.org.