AMBA Urges OCC and FDIC to Preserve CRA Recognition for Banking Services Supporting Military and Veteran Communities
The Association of Military Banks of America (AMBA) has submitted comments to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC), urging the agencies to preserve meaningful Community Reinvestment Act (CRA) consideration for banking services that support servicemembers, veterans, and their families.
In its October 13, 2026 letter, AMBA supported provisions recognizing the distinctive circumstances of military banks while raising concerns about a proposed change that could reduce recognition for helping unbanked and underbanked veterans establish banking relationships.
The central concern is the proposal to exclude deposit products from the retail banking services evaluation. Through programs such as the Veterans Benefits Banking Program (VBBP), AMBA works with the Department of Veterans Affairs and participating financial institutions to help veterans and other eligible VA beneficiaries obtain banking services and receive benefits through direct deposit.
An accessible, affordable transaction account can help a veteran receive benefits, pay bills, manage household finances, and build a banking relationship that supports access to appropriate credit over time. AMBA’s comments emphasize that these services deserve meaningful consideration when regulators evaluate banks’ responsiveness to community needs.
“Financial education can complement account access, but recognition of education alone would not adequately address the distinct work involved in bringing an unbanked or underbanked individual into the banking system,” AMBA wrote.
AMBA asked the agencies to retain CRA consideration for responsive deposit products and account-access services, including qualifying activities conducted through programs such as VBBP. If the agencies proceed with the exclusion, AMBA requested an explicit alternative pathway for consideration. If statutory limitations prevent that recognition, the agencies should explain those limitations and identify which related services remain eligible.
The letter also supports retaining the military-bank definition’s recognition of current and former members of the armed forces and their dependents, along with provisions accommodating military banks’ geographically dispersed customers. AMBA requested consistent definitions across OCC and FDIC rules and clarification of how services to military customers stationed overseas would be treated.
These recommendations reflect the realities of military life. Servicemembers and their families relocate frequently, maintain banking relationships across state and national boundaries, and face financial decisions during deployments and transitions to civilian employment.
AMBA also emphasized that qualifying services should receive consistent consideration even when the institution providing them does not meet the regulatory definition of a military bank. Many banks serving veterans and participating in VBBP fall into this broader category. The comments seek clearer guidance on activities benefiting spouses, dependents, survivors, caregivers, and other eligible VA beneficiaries.
To reduce unnecessary administrative burdens, AMBA requested practical documentation standards, greater use of information already available to regulators, and clear guidance explaining how activities conducted under the existing framework would be evaluated during a transition.
The submission follows Comptroller Jonathan Gould’s September 28 remarks at AMBA’s Military Banking Summit, where he recognized the financial needs of military and veteran communities and invited feedback on the CRA proposal and remaining regulatory obstacles.
AMBA’s regulatory comments complement its ongoing pursuit of targeted legislation to provide clearer CRA recognition for financial services benefiting veterans, servicemembers, and their families. The letter explains that military-bank provisions are valuable but do not independently resolve the full range of activity and eligibility questions AMBA seeks to address.
Through these efforts, AMBA is advocating for consistent rules that recognize the work banks do to help military and veteran families establish financial stability and access the services they need.
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