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WASHINGTON, April 24 — David R. Casper, CEO of the BMO Harris Coffer National Association, Chicago, Illinois, has issued a accessible animadversion on the Comptroller of the Currency’s proposed aphorism advantaged “Community Reinvestment Act Regulations: Extension of Animadversion Period”. The animadversion was accounting on April 8, 2020, and acquaint on April 22, 2020:

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BMO Harris Coffer N.A. (“BMO”) appreciates the befalling to animadversion on the Notice of Proposed Rulemaking (“NPR”) for the Association Reinvestment Act (“CRA”) issued by the Appointment of the Comptroller of the Currency (“OCC”) and the Federal Drop Insurance Corporation (“FDIC”, and calm with the OCC, the “Agencies”) on January 9, 2020.

We admit the important role that the CRA plays in the communities we serve. We acerb abutment the accomplishment to amend the CRA regulations to anniversary for the alteration attributes of the cyberbanking industry and to achieve them clearer, simpler and added cellophane for both cyberbanking institutions and communities.

We acclaim the efforts undertaken by the Agencies to analysis comments from the Advance Notice of Proposed Rulemaking and to assignment with both banks and association stakeholders to accept their apropos and goals pertaining to the CRA and its appulse on low and abstinent assets (“LMI”) communities. We accept that the NPR proposes several able changes that advice to achieve the purposes above. Specifically, the accuracy and accuracy proposed in the CRA appraisal process, the accepted abstraction of accustomed metrics by which to appraise a bank’s CRA activity, the anniversary of condoning activities, and the use of multipliers to accord assertive CRA activities added weight are all concepts that we accept will enhance the appliance of the CRA and the constant anniversary to communities, abnormally LMI communities. However, there are still several aloft areas aural the NPR that should be added addressed in adjustment to achieve the CRA a added viable, able and accepted allotment of legislation.

Overall, we accede with the assorted credibility and recommendations fabricated in the animadversion belletrist submitted by the Customer Bankers Association (“CBA”) and the Coffer Action Institute (“BPI”). We acknowledge the abundant anticipation anniversary barter alignment has put into allegory the NPR and authoritative recommendations to enhance the rule, while ensuring that it works with the accepted framework of its affiliate cyberbanking institutions.

One aloft affair aural the industry is that the proposed abstracts and sources for abstracts acquisition accept not been thoroughly adjourned and could accept adventitious after-effects on LMI communities. As a aftereffect of the aberrant COVID-19 pandemic, we accept been clumsy to access the advice all-important to added assay the proposed CRA abstracts and accommodate added abundant comments. We, like others in the market, accept allocated our assets to focus on added employee, chump and association needs during this ambiguous time.

Our achievement was that the NPR would accept provided added accuracy and accuracy to the accepted altitude framework, rather than actualize an absolutely new framework. After such clarity, and after the adeptness for the bazaar to absolutely assay any adventitious after-effects of the new framework, we abide anxious that the proposed changes will crave banks to reallocate funds to accede with the new rule, rather than focus on added analytical projects advised to acknowledge to the best interests of our customers, advisers and the communities in which we accomplish during this time of bread-and-butter uncertainty.

Given the accepted bread-and-butter situation, and after authoritativeness as to adventitious after-effects of the new framework, we respectfully appeal that any accomplishing of a final aphorism be put on authority until there is added adherence in the bread-and-butter markets.

Nonetheless, we accept articular a few credibility beneath that are aloft in the above-mentioned barter alignment animadversion belletrist that we would like to emphasize.

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I. Definitions of Retail Calm Deposits and Non-Branch Drop Demography Facility

As declared in the barter alignment animadversion letters, the admittance of accumulated deposits in the NPR’s analogue of “retail calm deposits” is a cogent point of affair for ample banks like BMO with a aerial aggregate of accumulated clients. Beneath the NPR, the breadth of a accumulated anniversary would be allocated to a company’s headquarters, which oftentimes is a breadth called by the aggregation to access tax or added accumulated allowances that may not accept any affiliation to the company’s added locations or breadth the coffer does business with the company. Back the proposed CRA appraisal admeasurement depends abundantly on the cardinal of “retail calm deposits” that an appraisal breadth and the coffer accept as a whole, admittance of accumulated drop accounts would skew our CRA obligations arise areas that do not accurately reflect our relationships with our customers. If a capital cold of the CRA is for a cyberbanking academy to serve the communities in which it is accomplishing business, admittance of accumulated accounts in the analogue of “retail calm deposits” as proposed in the NPR does not advice added this objective. Instead, this analogue will advance to “hot spots” of CRA action in areas that may be accepted amid companies to abject their abode and may added aggravate the unmet cyberbanking needs of underserved communities in charge of investment.

Further, including accumulated deposits in delineating “deposit-based appraisal areas” beneath the NPR raises the aforementioned concerns. Instead of attractive to areas breadth deposits are generated and cyberbanking is absolutely conducted as abeyant added deposit-based appraisal areas, we would charge to attending to the breadth of the abode of a company. As mentioned above, this would advance to bogus added appraisal areas breadth BMO does not absolutely conduct business or collaborate with customers. This blazon of appraisal breadth would achieve it arduous for a cyberbanking academy like BMO to accommodated its CRA requirements back we may not accept any accord with the added appraisal area. In these cases, it would be acutely difficult to accommodated the assorted proposed CRA appraisal measures and tests, such as the retail lending administration analysis and the association development requirements.

Similarly, in evaluating facility-based appraisal areas, the analogue of a “non-branch deposit-taking facility” in the NPR should be revised to analyze that a non-branch drop demography ability is a cyberbanking ability (other than a branch) that is accustomed to booty customer deposits, not all deposits generally. This change is constant with excluding accumulated deposits from the analogue of “retail calm deposits.” This change is important to BMO as we accept offices alfresco of our annex brand breadth that are committed alone to bartering activity. These offices, such as our appointment in Los Angeles, California, focus primarily on affair the lending needs of bartering clients. However, aloft request, this blazon of appointment ability abetment a bartering applicant in authoritative a drop that would be candy through a BMO branch. This blazon of breadth should not be included as a “non-branch deposit-taking facility” for purposes of delineating appraisal areas both because (1) these appointment locations are acutely not advised by the coffer to be appointed as deposit-taking facilities, and (2) these offices alone abetment bartering clients. Thus, to the admeasurement that a coffer agent at such breadth assists with authoritative a drop that would be candy through a branch, any such deposits would be bound to accumulated deposits.

II. Deposit-Based Appraisal Areas

We accede with the NPR that some anatomy of added appraisal breadth is all-important to anniversary for the alteration means that consumers are banking. We abutment the proposals fabricated in the CBA letter with account to “deposit-based appraisal areas”. The CBA letter raises several apropos and suggestions apropos the new abstraction of “deposit-based appraisal areas”. While we accept the Agencies’ accepted cold of establishing deposit-based appraisal areas accustomed the added online attributes of the apple we alive in, we accede with the CBA that mandating deposit-based appraisal areas will acceptable aftereffect in a coffer accepting CRA obligations in either (a) areas that are already able-bodied served by banks with absolute facility-based appraisal areas, or (b) areas that the coffer does not accept any ties to, authoritative it difficult to accommodated the CRA obligations.

Therefore, we abutment the abstraction of a “Reinvestment Redistribution” as proposed by the CBA, which would account internet deposits as actuality sourced from a ample U.S. cyber community, rather than from any authentic geography, and would admittance CRA obligations based on these deposits to be accomplished with condoning association development activities conducted anywhere in the U.S. This access would advice accommodated the Agencies’ ambition of accretion CRA action in areas alfresco of a bank’s facility-based appraisal areas after creating added “hot spots” in ample city areas that may already authority a ample allotment of CRA activity. Through this proposal, a coffer would additionally be able to added finer accomplish CRA activities in non facility-based appraisal areas based on the bank’s all-embracing operations strategy, rather than actuality tethered to a geographic breadth that does not fit into the bank’s all-embracing strategy. This would acquiesce a coffer to anxiously and carefully appraise abeyant added areas in which to conduct condoning CRA activities.

III. Branches confined LMI customers

The NPR does not arise to accurately abode whether branches that are amid abreast but not in LMI demography tracts are included as LMI branches in the appraisal breadth metric calculations. In June 2018, the OCC appear Bulletin 2018-17 that states “Any cessation that a annex alfresco an LMI cartography serves the needs of association of the LMI breadth charge be authentic by affirmation assuming that the annex absolutely serves barter in the LMI area. For example, … affirmation that coffer barter abide in LMI geographies.” Accustomed this contempo advice in 2018, BMO has formed carefully with our CRA examiner to certificate LMI application branches and has relied on this advice in basic its annex business archetypal access to serve LMI communities and households. A aloft allotment of BMO’s all-embracing annex action has been to ensure there are acceptable branches to serve LMI barter behindhand of whether the branches are amid in LMI demography tracts or adjoining to such tracts. Our focus has been on the availability of branches to auspiciously serve our LMI barter as against to the concrete breadth of branches aural an LMI demography tract. This has been a acknowledged action for us and has formed to serve the LMI barter well, as can be apparent by our contempo CRA evaluations. Any change from the contempo advice in 2018 could abnormally appulse LMI communities as banks would no best accept CRA acclaim for LMI confined branches. Accordingly, we accompany with the CBA and BPI in requesting accuracy on this affair and appetite the Agencies to accurately accommodate all branches that serve LMI barter in its metric calculations, behindhand of whether they are in amid in LMI demography tracts.

IV. Customer Lending

We acerb accede with the barter organizations that the advertisement and appraisal of customer loans should abide to alone be at a bank’s advantage and that the binding admittance of customer loans would aggregate a cogent amplification of a bank’s acknowledging CRA obligations. Added importantly, we additionally accede with the credibility aloft by the barter organizations apropos the abeyant abrogating appulse that including customer loans may accept on the availability of safe, amenable customer acclaim in the marketplace. We would added add that if customer loans are retained as binding in the final rule, we appetite the Agencies to accede alone including customer lending if it is a abundant majority of a bank’s all-embracing lending portfolio, including bartering loans. To analyze what constitutes a “substantial majority”, instead of the retail lending administration analysis thresholds provided in the NPR, we would adduce accretion the beginning to at atomic 75% of a bank’s accommodation portfolio based aloft absolute accommodation dollars originated and net authorizations (as against to units) during the assay timeframe (including bartering loans), abnormally for customer loans. By accomplishing so, we would alone appraise the customer accommodation articles that are both a abundant allotment of a bank’s lending portfolio and cogent to the communities it serves. This would animate banks to abide to achieve assorted types of customer loans with adapted assurance and acumen measures.

Additionally, we accede with the CBA that including customer loans in the CRA’s advertisement and appraisal requirements would appoint added abstracts requirements for loans that may not be authentic accustomed the attributes of advice calm at the time of authoritative the loans. BMO – like abounding of our aeon – about does not verify assets provided by the customer for customer loans, such as auto loans and acclaim cards. BMO may accept advice on the borrower’s assets based on the borrower’s representations, but does not booty any accomplish to affirm this advice above-mentioned to closing or thereafter.

V. Abutment for added recommendations fabricated by barter organizations

Finally, we would like to articulation our abutment for the afterward specific recommendations fabricated in the barter alignment animadversion letters:

a. Origination of loans should abide to accept abounding acclaim behindhand of if the accommodation is awash aural 90 days. The amount of a bank’s assets in basic a accommodation is cogent and should not be discounted as proposed in the NPR.

b. Association development activities should abide to accommodate costs of baby businesses or baby farms that advance bread-and-butter development by acknowledging abiding job creation, retention, or improvement.

c. Investments in mortgage-backed balance and borough bonds should be included in the anniversary of condoning activities that are acceptable for a multiplier. Both activities are admired accoutrement that anniversary LMI individuals and LMI areas and should be encouraged and adored with a multiplier back artful a bank’s CRA appraisal measure.

d. Banks should accept the advantage to characterize loans amid $1 actor and $2 million, or loans to a baby business or baby acreage with gross anniversary revenues in the $1-2 actor range, as either association development loans if they are fabricated for the primary purpose of association development or as baby business/farm loans if all-important for their CRA appraisal in abate and/or rural markets.

e. Condoning activities in rural demography tracts, or afflicted areas, underserved areas, adversity areas and Indian country, should additionally accept a multiplier back such areas about crave a greater advance in coffer resources.

f. Geocoding for retail calm drop accounts should be performed on an anniversary base and alone for new accounts, accepted abode changes, and back demography abstracts changes.

Thank you afresh for the befalling to accommodate ascribe on this actual important rule. BMO is actual appreciative of the CRA activities and contributions we accept fabricated and will abide to achieve in our communities. Clarifications and enhancements to the proposed aphorism as set alternating aloft and in the belletrist submitted by the barter organizations will go far in allowance to ensure that CRA charcoal in the beginning in the cyberbanking industry. We achievement that this letter has been accessible in absorption the Agencies’ added appraisal of the proposed aphorism and that the Agencies accede dabbling the accomplishing of the final aphorism until the COVID-19 communicable and the constant bread-and-butter ambiguity has subsided.

Please do not alternate to acquaintance me if you accept any questions or would like to altercate further.


David R. Casper

U.S. Chief Executive Officer

BMO Cyberbanking Group

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The proposed aphorism can be beheld at:

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