Yes, fee waivers for deposit account holders could be considered for CRA credit. The “Joint Statement on CRA Consideration for Activities in Response to the COVID-19” issued on March 19 (and page 61-62 of the training manual), states,
Pursuant to the Community Reinvestment Act (CRA), the agencies will favorably consider retail banking services and retail lending activities in a financial institution’s assessment areas that are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected by COVID-19 and that are consistent with safe and sound banking practices. These activities may include, but are not limited to
• Waiving certain fees, such as:
o Automated teller machine (ATM) fees for customers and non-customers,
o Overdraft fees,
o Late payment fees on credit cards and other loans, and
o Early withdrawal penalties on time deposits;
• Easing restrictions on cashing out-of-state and non-customer checks;
• Expanding the availability of other short-term, unsecured credit products for creditworthy borrowers;
• Increasing credit card limits for creditworthy borrowers;
• Providing alternative service options to customers in light of limited ability to access branches; and
• Offering payment accommodations, such as allowing borrowers to defer or skip payments or extending the payment due date, which would avoid delinquencies and negative credit bureau reporting, caused by COVID-19-related issues.
Some bankers have been denied credit in this situation. The credit is not automatic. Must document that the waiver is are responsive to the needs of low- and moderate-income individuals, small businesses, and small farms affected by COVID-19.