The Financial Health Network is submitting this letter in response to the request for comment by the Federal Deposit Insurance Corporation, published on September 10, 2014. We appreciate the opportunity to respond to the FDIC’s request for comments on proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. Like you, we recognize that financial services and financial service providers continue to evolve and provide new opportunities for consumers and that these changes need to be reflected in Community Reinvestment Act evaluations.

The Financial Health Network is a national authority on consumer financial health. We lead a network of financial services innovators committed to building higher quality products and services. The Financial Health Network informs, advises, and connects its network to seed innovation that will transform the financial services landscape. We believe that finance can be a force for good in people’s lives and that meeting consumer need responsibly is ultimately good for both the consumer and the provider.

The Financial Health Network is interested in assuring that financial service providers are able to continue to innovate as technologies and markets evolve. Our vision is to see a strong, robust, and competitive financial services marketplace, where the diversity of consumer transaction, savings, and credit needs are met by a range of providers offering clear, transparent, and high-quality products and services at reasonable prices. This vision is guided by our Compass Principles – Embrace inclusion, Build trust, Promote success, and Create opportunity. These principles are built on a solid foundation that recognizes the core market values of profitability and scalability, deep customer knowledge, safety, variation and choice, consumer-provider relationships, and cross-sector participation.