Displaying items by tag: CRA

Our members include community reinvestment organizations, community development corporations; local and state government agencies; faith-based institutions; community organizing and civil rights groups; minority and women-owned business associations as well as local and social service providers from across the nation.

NCRC pursues its work through a variety of partnerships and programs. Our National Homeownership Sustainability Fund leverages the expertise of a national network of mortgage finance advisors. They work with servicers and lenders, on behalf of homeowners, to keep working families from losing their homes to foreclosure.

NCRC’s National Training Academy provides training and technical assistance on topics such as understanding how to use the Community Reinvestment Act (CRA), fair lending laws, Home Mortgage Disclosure Act (HMDA), Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA), Homeownership and Equity Protection Act (HOEPA), fair housing and foreclosure prevention. Our Economic Justice Campaign sites pilot innovative community partnerships to enhance the delivery of financial, technical, and social services to individual consumers, homeowners, and small business.

NCRC’s work is enhanced by two financial service advisory councils consisting of the nation’s largest banks and mortgage finance companies. Quarterly roundtables examine issues involving responsible financial service-related policies, regulations and legislation, as well as innovative products, services and best practices.

NCRC represents its members before Congress, federal regulatory agencies and the press. NCRC routinely testifies before the U.S. Congress, and meets with the leadership of banking and lending regulatory agencies. NCRC frequently provides expert commentary on national television, and our research and policy papers have been cited in hundreds of newspapers in the US.

Published in About Us

Call for Swift Passage of Responsible Banking Act (Intro. 485)


Council members, advocates and community residents gathered on the steps of City Hall today to demand that banks be held accountable, and to call for the passage of the recently introduced Responsible Banking Act (Intro. 485 – Vann, Recchia). The press conference followed a hearing on the legislation in the New York City Council Committees on Community Development and Finance, also held today.

The Responsible Banking Act is important new proposed legislation that will create a ranking system of banks seeking city deposits based on how responsive they are to the needs of New York City’s neighborhoods. By holding banks that store the city’s money more locally accountable, the bill would incentivize  these financial institutions to engage in practices that are beneficial to all New Yorkers and strengthen their community development efforts in New York City. An evaluation of how these banks contribute to the needs of the City and its communities would be a transparent and important tool of the city in determining which banks it deposits its funds.

The bill is not only a response to the aftermath of predatory lending and other harmful bank practices that contributed to the national financial crisis, but also to continued disengagement by banks within underserved communities. As the effects of this continue to be felt in our city, it is imperative that New York City take affirmative steps to rebuild and strengthen its partnerships with the banking community.  The Responsible Banking Act creates the transparency and oversight necessary to achieve this. The bill would require the Department of Finance, in its role on the NYC Banking Commission, to collect important information related to community development activities performed by banks wanting to be city depositories. These would include whether they provide: mortgage loan restructuring for struggling homeowners; financing for the construction of affordable housing; and/or credit and financial services for small businesses, among other criteria.

Published in Press Releases

Hundreds of NCRC members expected to comment and testify before bank regulators this summerCharles Harris

Atlanta, GA – Today, eight members of the National Community Reinvestment Coalition testified before the bank regulatory agencies regarding ways to improve the Community Reinvestment Act (CRA) to leverage hundreds of billions of dollars more in private investments for job creation and sustainable homeownership. The NCRC members and national partners testifying include: the Center for Responsible Lending, the Housing Assistance Council, National Council of La Raza, Operation Hope, Inc., the Atlanta Neighborhood Development Partnership, the Community Reinvestment Association of North Carolina, Community Development Corporation of Marlboro County, and Housing Education and Economic Development (HEED) of Mississippi (Exec. Director, Charles Harris pictured right). This is the second of four regulatory hearings that NCRC and its members will be attending and testifying at throughout the summer; NCRC’s testimony from the first hearing can be found here: http://bit.ly/8Y3Gke

“While the financial reform brought about by the Dodd-Frank act will guard against abusive and reckless behavior, it will not ensure that small businesses and responsible homeowners have access to the credit that they need to prosper. The whole of the private market must be engaged in the provision of capital and credit, the lifeblood of vibrant communities. The Community Reinvestment Act has encouraged banks to pursue their commitment to communities in a safe and sound manner. It should be expanded and improved, to better promote job creation and sustainable homeownership,” said John Taylor, president and CEO of the National Community Reinvestment Coalition. “I want to congratulate the hundreds of NCRC members who will comment or testify this summer before the bank regulatory agencies. Banking may seem to be an arcane subject to some, but if the financial crisis has taught us anything, it’s the centrality of the financial system to the health and vibrancy of our neighborhoods.”

A complete set of recommendations from the National Community Reinvestment Coalition can be found here: http://bit.ly/8Y3Gke. Specific topics to be discussed at the Atlanta hearing include access to banking services to the under-banked and un-banked individuals in underserved and distressed areas, and improvements to the CRA performance tests with a concentration on rural communities and small institutions.

About the National Community Reinvestment Coalition (NCRC):

The National Community Reinvestment Coalition is an association of more than 600 community-based organizations that promote access to basic banking services, including credit and savings, to create and sustain affordable housing, job development, and vibrant communities for America's working families.

http://www.ncrc.org/

Click here to download press release as a PDF

Published in Press Releases
 
 
How to Use the Community Reinvestment Act (CRA)
to Promote Housing and Economic Opportunity in Your Community
 
 


Why is the Community Reinvestment Act (CRA) important?

CRA is a federal law that imposes an affirmative obligation on banks to serve the credit needs of low- and moderate-income communities and to take steps to provide equal access to responsible financial products and services to traditionally underserved populations.  Thanks to CRA, banks have actively promoted housing and economic opportunity for underserved groups by providing affordable mortgage programs, small business loan products, community development financing, funding for non-profit housing and economic development programs, etc.

Banks are regularly examined by the federal government to determine if they are meeting their CRA obligations.  Because an unsatisfactory CRA rating or questions about CRA performance can result in delays or denials of mergers, acquisitions or the expansion of services, banks often look for ways to maintain or improve their CRA records.


How can I or my agency maximize the benefits of CRA to promote housing and economic opportunity in my community?

To maximize the benefits of CRA within local communities, NCRC encourages community stakeholders to develop a CRA strategy that involves a combination of any or all of the following activities:

  • Submit written comments on the community reinvestment performance of banks in your local area when these banks undergo their regular CRA examinations;
  • Monitor bank mergers, acquisitions and expansions to identify strategic opportunities to encourage banks in your local area to improve their community reinvestment records;
  • Meet periodically with banks operating in your local area, even if they are performing well on their CRA exams, to discuss your community’s credit/capital/bank service needs and to suggest actions a bank can take to better meet those needs;
  • Meet with bank regulators to discuss the performance of specific banks, as well as improvements to the CRA exam process;
  • Encourage your local government or other local institutions with substantial bank accounts (e.g., churches, foundations, etc.) to establish a linked deposit program to ensure that only those banks with reasonable community reinvestment records are eligible to benefit from a financial relationship with major local depositors; and
  • Become a shareholder advocate – owning even a small number of shares in a publicly-held bank allows you to introduce, vote on and/or speak at shareholder meetings about shareholder resolutions that address community reinvestment concerns.


Remember to This e-mail address is being protected from spambots. You need JavaScript enabled to view it if you need assistance implementing any of these CRA-related activities.


How can I or my agency participate in the CRA exam process to benefit my community and clients?

Comments made by community stakeholders (including non-profits, local government agencies and individuals) that highlight strengths or weaknesses in a bank’s performance with regard to lending, investments or service provision that benefit underserved groups can have a strong influence on a bank’s CRA rating, as well as on the ongoing actions a bank takes to promote housing, financial and economic opportunity for traditionally underserved populations.

You can submit comments on a bank’s community reinvestment performance at any time.  If a bank is not undergoing a CRA exam at the time you submit your comments, simply instruct the bank and its federal regulator to place your CRA comments in the bank’s public file.  The next time a CRA exam occurs, the federal examiner is required to look at comments in the public file and the bank is required to report how it responded to any concerns raised.

NCRC can provide guidance and data analysis to help you develop your comments on a bank’s CRA record.


Why should community stakeholders meet regularly with banks to discuss CRA-related activities?

Community agencies and other stakeholders can approach banks, particularly those that receive poor CRA ratings, to suggest ways that financial institutions can improve their community reinvestment performance.  The development of mutually beneficial relationships between banks and community stakeholders has resulted in funding for housing counseling programs; new loan products that better serve small business entrepreneurs; increases in the number of bank branches in underserved neighborhoods; investments in local community and economic development loan programs and projects; financing for affordable mortgage products; sound credit alternatives to predatory payday loan products; etc.

To see if there are any specific issues you may want to discuss with a bank, you can check the results of that bank’s last CRA exam at http://www.ffiec.gov/craratings/default.aspx or you can contact NCRC for an analysis of a bank’s CRA-related performance.  NCRC can also help you prepare for your meetings with banks.


Why do bank mergers, acquisitions and expansions present a strategic opportunity to encourage banks to enhance their product/service offerings and/or to support programs that benefit traditionally underserved groups?

If valid questions about a bank’s CRA performance record are raised when financial institutions are engaged in a merger, acquisition or expansion process (particularly if the bank received a low CRA score on it’s last exam) federal regulators may delay or deny the merger, acquisition or expansion application involving that bank.  To avoid such costly delays, the financial institution(s) involved will often work with community stakeholders to develop a community reinvestment plan that addresses the problem(s) and that identifies specific funding and/or new products, services or investments the bank will offer in order to promote housing and economic opportunity for traditionally underserved groups.

To find out if there are any pending merger, acquisition or expansion applications that may impact your community and/or for assistance in preparing your response, call NCRC’s Membership Department at (202) 628-8866.


How can NCRC help me or my agency prepare CRA-related comments or engage in CRA-related discussions with banks?

NCRC can provide a detailed analysis of a financial institution’s community reinvestment record that addresses how well the bank serves the needs of low- and moderate-income and/or minority households through its basic banking, lending and investment services.  This analysis is provided FREE to NCRC members.

NCRC staff can also provide guidance on how to prepare CRA-related comment letters and engage in negotiations with financial institutions to secure funding, products and services that promote housing and economic opportunity for low- and moderate-income and minority clients.  Staff can help members frame and support their appeal and determine what community investment commitments it might be appropriate to ask a bank to make (e.g., develop new products that better serve small business entrepreneurs, fund housing counseling programs, invest in a housing/community development or small business loan fund, etc.).

In addition, NCRC members can communicate with other coalition members via our listserv to find out what has worked in other communities, see examples of comment letters written to regulatory bodies and, of course, elicit support from other allies for their CRA-related activities.


How can I or my agency get help from NCRC to support our CRA-related activities?

Staff from NCRC's Membership, Research and Legislative/Regulatory Affairs Departments are available to provide you with the support you need to utilize CRA to promote housing and economic opportunity in your community. To start the process, contact NCRC at (202) 628-8866 or This e-mail address is being protected from spambots. You need JavaScript enabled to view it .

Washington, DC - Today, in reaction to the newly released final revisions to the Interagency Question and Answer (Q&A) document regarding the Community Reinvestment Act (CRA), the National Community Reinvestment Coalition’s (NCRC) President and CEO, John Taylor, made the following statement:

“It is very disappointing that the Q&A does not address a critical issue: the definition of a CRA assessment area. An assessment area is currently a geographical area containing bank branches. But modern banking is conducted through a variety of conduits, beyond traditional brick and mortar branches. Regulators should have presented processes for the consideration and evaluation of performance through all of these conduits. The current system is inaccurate, and most importantly, it does not adequately protect the interests and needs of working Americans. While the new Q&A addresses community development activities, it overlooks this critical geographical assessment area issue. The regulatory agencies’ timid approach on this issue will result in fewer bank loans, investments, and services in low- and moderate-income communities. As is, CRA exams will continue not to evaluate a large number of loans for non-traditional and large banks that lend through brokers, correspondents, and other non-branch means.”

“The agencies are proceeding backwards and are not giving themselves the tools with which to measure their proposed changes. This is not an effective method for improving the effectiveness of the nation’s reinvestment requirement to ensure that low- and moderate-income neighborhoods have a fair chance to grow and rebuild. The agencies will continue to erode CRA’s future effectiveness if they fail to address how exams will capture home and small business lending made beyond bank branch networks.”

In the changes in the Q&A document, the agencies addressed the inadequacies in assessment areas regarding community development lending and investments such as equity investments in small businesses or Low Income Housing Tax Credits. Previously, the Interagency Q&A document stated that “considering its performance context,” an institution can received favorable consideration for community development activities outside of its assessment area provided that it has “adequately addressed community development needs of its assessment areas.” In the revision released last week, the new language states that an institution can receive favorable consideration for community development outside of assessment areas “as long as the institution has been responsive to community development needs and opportunities in its assessment areas.”

“The agencies are thinking about this backwards. Instead of bending over backwards to permit community development outside of assessment areas, the major emphasis on reform should be expanding assessment areas to include those areas in which a bank makes significant amounts of retail loans but does not contain branches. If the agencies undertook this reform, then the number of assessment areas would expand and banks would not feel as great a need to expand beyond their assessment areas to find community development lending and investment opportunities.”

“The agencies are also missing important opportunities to monitor the effects of their changes. In order to determine whether community development lending and investments are reaching geographical areas in greatest need, the agencies need to collect and analyze data on the counties in which community development loans and investments occur. Despite NCRC calling for this data for several years, the agencies have not adopted this data collection proposal.”

“The agencies held hearings in 2010 and invited hundreds of community organizations and stakeholders to submit ideas for CRA reform. It is deeply disappointing that, several years later, regulators have fallen far short of what needs to be done with this Q&A and the CRA regulation.”

About NCRC

The National Community Reinvestment Coalition is an association of more than 600 community-based organizations that promote access to basic banking services, including credit and savings, to create and sustain affordable housing, job development and vibrant communities for America's working families. To find out more, visit http://www.ncrc.org

Published in Press Releases

Congressman Luis Gutierrez (D-IL) has issued this video call to action, calling on his colleagues to support our efforts to strengthen and expand the Community Reinvestment Act. We’re working with the Congressman and his colleagues to move legislation expanding and strengthening CRA in the coming months, and we thank him for his leadership on this issue.

Published in NCRC Videos

Washington, DC -- In the wake of a troubling new report from SNL Financial showing major banks pulling out from low-income areas, the National Community Reinvestment Coalition (NCRC) has called for banking regulators to investigate the trend and take action. The SNL Financial report, entitled "Banks follow the money and exit lower-income areas," finds that the major banks have primarily built bank branches in higher income areas since 2006, while pulling out of low- and moderate-income communities.

NCRC President and CEO John Taylor made the following statement:

"This is a highly disturbing trend. Bank branches are critical to building wealth in low-income communities. When banks divest from these communities, they are replaced with check cashers, pay day lenders and other fly-by-night outfits that charge exorbitant fees."

"Some banks have publicly said they are closing branches in low-income communities because they can't charge the same kind of overdraft fees anymore. If the banks are addicted to abusing poor people with high fees for revenue, then they need to kick that habit without closing branches. Branches in low-income neighborhoods can be very profitable without being abusive."

"We're calling on the regulators to take immediate action. The banks are abandoning low-income neighborhoods on the watch of Chairman Ben Bernanke of the Federal Reserve, Comptroller of the Currency Thomas Curry, and Acting Chairman Marty Gruenberg of the Federal Deposit Insurance Corporation. This abandonment of lower-income communities likely violates numerous fair lending laws, such as the Community Reinvestment Act and the Equal Credit Opportunity Act. We call on the Federal Reserve, the OCC, the FDIC as well as the Consumer Financial Protection Bureau to investigate the banks and enforce the law."

In April, NCRC released an issue brief entitled "Why Bank Closures are Bad for Communities." The issue brief highlighted the trend of diminishing bank branches in modest income neighborhoods and communities of color, and highlighted a series of policy remedies to rectify the problem.

 

About the National Community Reinvestment Coalition (NCRC):
The National Community Reinvestment Coalition is an association of more than 600 community-based organizations that promote access to basic banking services, including credit and savings, to create and sustain affordable housing, job development, and vibrant communities for America's working families.  

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Published in Press Releases
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