Regulatory agencies should consider loans per thousand people to identify Community Reinvestment Act assessment areas for branchless banks.
How Can Geographical Areas on CRA exams Work for Branchless banks? Read More »
(Download) January 8, 2021 Stephanie Li Chief of Regulations Loan Guaranty Service, Veterans Benefits Administration, Department of Veterans Affairs 810 Vermont Avenue NW Washington, DC 20420 RE:     RIN 2900-AR05—Loan Guaranty: COVID-19 Veterans Assistance Partial Claim Payment Program To whom it may concern: On behalf of the clients, communities, and industries that we represent, we write
Joint Consumer-Industry Comments to Veterans Administrations Partial Claims Proposal Read More »
(Download) January 13, 2021 John Conneely Regional Director Federal Deposit Insurance Corporation 300 South Riverside Plaza, Suite 1700 Chicago, IL 60606-3447 RE: NCRC Comment Letter on GM Financial Bank Application Dear Director Conneelly: The National Community Reinvestment Coalition (NCRC) maintains that GM Financial Bank’s application for an Industrial Loan Charter (ILC) has not demonstrated a
NCRC Files Comment Opposing Charter Application from GM Financial Read More »
President Obama promised to use the president’s power to increase opportunity for all Americans, regardless of race or class. Despite this promise, little to no progress was made in bridging Black/White inequality in wealth, income and homeownership.
Why Biden Must Build Back Better Than Obama For Blacks Read More »
The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on Oportun’s application for a national bank charter. We request that the OCC extend the comment period for this application by 30 days to address numerous Community Reinvestment plan, loan pricing and debt collection practices raised by this application. Until these outstanding issues are addressed, we believe that the OCC does not have sufficient information to approve this application.
NCRC Submits Comment on Oportun’s Application for a National Charter Read More »
If you are still in need of gifts this season, please consider purchasing them from a D.C. small business in our DCWBC Holiday Gift Guide.
Holiday Gift Guide Read More »
(Download) December 14, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) outline of proposals under consideration
(Download) Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (the Bureau) outline of proposals under consideration and alternatives
In this report, NCRC extended our previously published analysis of bank branch closures to look at changes from 2017 through 2020.
Research Brief: Bank Branch Closure Update (2017 – 2020) Read More »
The government’s flawed COVID relief program underscored the need for equity in small business financing, and for stronger enforcement of fair lending laws.
NCRC Paycheck Protection Plan Preliminary Analysis Read More »
The board’s question invites a dialogue about whether and where the Federal Reserve’s framework might affirmatively consider race more explicitly. While we are not yet committing to support various aspects of the Federal Reserve’s proposed framework for CRA examinations, this paper is designed to explore where and whether regulators could insert race in a framework like this from a statutory and constitutional perspective.
CRA & Race: The Federal Reserve’s Proposal on the Community Reinvestment Act (CRA) Read More »
(Download) December 7th, 2020 Mr. Louis Gittleman Director for District Licensing Western District Office 1225 17th Street, Suite 300 Denver, CO 80202 RE: Figure Bank, National Association: Charter application Dear Director Gittleman: Please accept this comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the
(Download) December 1, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information on the Equal Credit Opportunity Act; Docket No. CFPB-2020-0026 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request For Information (RFI) on the Equal Credit
NCRC Comment on the CFPBs RFI on the Equal Credit Opportunity Act Read More »
(Download) Kathy Kraninger Director Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Dear Director Kraninger: The undersigned civil rights, community, and consumer organizations appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request for Information (RFI) on the Equal Credit Opportunity Act (ECOA), which “seeks comments and information
Group sign-on letter on the CFPBs RFI on the Equal Credit Opportunity Act Read More »
The OCC has proposed yet another data collection effort to develop thresholds for its flawed 2020 Community Reinvestment Act final rule. This is another tacit admission by the OCC that all along it has lacked the data and factual basis for developing its flawed revisions to CRA examination performance measures. Instead of creating more consistency
Initial NCRC Analysis of OCC Proposal to Establish Thresholds for its New CRA Measures Read More »
