On October 13, Connect Humanity submitted comments to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) on their proposed changes to the Community Reinvestment Act (CRA) rules.

We made two requests. First, regulators should state clearly that broadband counts as essential infrastructure. Second, bank capital should be able to reach rural and underserved communities that sit outside banks’ usual service areas, without weakening what banks do in the communities they already serve.

Read our full comment letter (PDF)

What is the Community Reinvestment Act, and why does it matter for broadband?

The CRA is a federal law that encourages banks to meet the credit needs of the communities where they operate, including low- and moderate-income neighborhoods. Regulators evaluate banks on their lending, investment, and community development activity, and those evaluations shape where banks put capital.

Broadband networks need long-term, patient financing. Public grants like the Broadband Equity, Access, and Deployment program provide vital investment, but they are time-limited. If the CRA treats broadband clearly as community development, it can help bring private capital into projects that would not get built with grants alone, and create a lasting market for broadband finance.

Broadband is the starting point. Communities will need financing for other digital infrastructure in the years ahead, such as community-scale data centers, and clear CRA treatment now helps build a community finance ecosystem that knows how to invest in it.

What did Connect Humanity ask for?

The proposed rule recognizes “essential telecommunications infrastructure” as a form of community development, which we strongly support. We asked regulators to confirm two things: that this includes broadband, and that broadband projects qualify whether or not they are structured as public-private partnerships. Broadband is built by community networks, cooperatives, Tribal providers, and small local internet service providers. The rule should reflect that range.

Many communities that most need broadband have few banks nearby with the capacity to finance it. Regulators themselves acknowledge that the current rules leave many rural areas as ‘CRA deserts.’ The proposal would let banks earn CRA credit for activity outside their usual service areas once they meet a minimum level of community development activity at home. We asked regulators to keep that pathway usable for regional projects like broadband networks, which often cross county lines, while making sure it adds to what banks already do in the communities they serve rather than replacing it.

What happens next?

The comment period closed on October 13. The OCC and FDIC will review public comments before issuing a final rule. These changes would apply to banks supervised by those two agencies, not to Federal Reserve-supervised banks.

We will keep following the rulemaking. If you work at a bank and want to understand how broadband projects can fit your community development strategy, get in touch.