NCRC comment letter on AmeriNat charter application

September 12, 2019 RE: NCRC Comment Letter on AmeriNat Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that AmeriNat’s application for an Industrial Loan Charter (ILC) has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served as required per the Federal […]

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Letter to regulators on CRA regulatory actions

September 9, 2019 The Honorable Jerome H. Powell Chairman, Federal Reserve Board of Governors 20th Street and Constitution Avenue NW Washington, DC 20551 The Honorable Joseph Otting Comptroller of the Currency 400 7th St SW Washington, DC 20219 The Honorable Jelena McWilliams Chairman, Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Dear […]

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Comment on HUD’s Opportunity Zone policy

(Download) June 17, 2019 Public Finance and Regulatory Analysis Division Office of Policy Development and Research Department of Housing and Urban Development 451 7th Street SW, Room 8216 Washington, DC 20410-0500 Via Federal eRulemaking Portal Re: Docket No. FR–6155–N–01 Request for Information Review of HUD Policy in Opportunity Zones  Dear Secretary Carson: On behalf of […]

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The purpose and design of the Community Reinvestment Act (CRA): An examination of the 1977 hearings and passage of the CRA

A version of this article appeared first in Conference of Consumer Finance Law, Quarterly Report, Vol. 72, No. 4 Introduction In 2019, the Community Reinvestment Act (CRA) will be forty-two years old.[1]  Congress enacted the CRA in 1977 as a community development initiative that sought to leverage the financial resources of private sector institutions.  Senator […]

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Notice of proposed rulemaking, HMDA reporting thresholds

(Download) June 12, 2019 Docket No. CFPB-2019-0021 or RIN 3170-AA76 Notice of Proposed Rulemaking, HMDA Reporting Thresholds To Whom it May Concern: The undersigned organizations (158 national and local organizations) oppose the proposal of the Consumer Financial Protection Bureau (CFPB) to exempt thousands of lending institutions from reporting the Home Mortgage Disclosure Act (HMDA) data. […]

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NCRC comment letter on Robinhood’s charter application

May 29 2019 RE: NCRC Comment Letter on Robinhood’s Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that Robinhood’s charter application has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served as required by the Community Reinvestment Act (CRA) and the […]

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NCRC CEO testifies on BB&T/SunTrust merger

Testimony of Jesse Van Tol, CEO, National Community Reinvestment Coalition, April 25, 2019, in Charlotte, North Carolina, at a hearing on the proposed BB&T/SunTrust bank merger with the Federal Reserve Board and Federal Deposit Insurance Corporation. Thank you for the opportunity to testify here today. My name is Jesse Van Tol, and I am the […]

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A review of the state of barriers to minority homeownership

(Download) Statement of the National Community Reinvestment Coalition U.S. House Committee on Financial Services Subcommittee on Housing, Community Development and Insurance May 8, 2019 Chairman Clay, Ranking member Duffy and members of the Subcommittee on Housing, Community Development and Insurance: The National Community Reinvestment Coalition (NCRC) commends you for holding this review on the state of and barriers […]

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Testimony of Jesse Van Tol, CEO, National Community Reinvestment Coalition, April 9, 2019 – Consumer Protection and Financial Institutions Subcommittee

The Community Reinvestment Act: Assessing the Law’s Impact on Discrimination and Redlining   Introduction: Public input and accountability are the keys to CRA’s success I thank Chairman Meeks and the members of this subcommittee for providing me the honor of testifying this morning regarding the Community Reinvestment Act’s (CRA) impact in combating discrimination and redlining. […]

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Request for information on FDIC’s deposit insurance application process

RIN 3064-ZA03 March 29, 2019 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to respond to the FDIC’s request for information regarding the application process for deposit insurance. As a coalition of 600 community-based organizations, NCRC believes that a clear and transparent process for deposit insurance applications is critical […]

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NCRC sign-on letter regarding the FHFA’s notice of proposed rulemaking on the FHLB’s housing goals amendments

Alfred M. Pollard, General Counsel Federal Housing Finance Agency, Eighth Floor 400 7th Street SW Washington, DC 20219 Attention:  Federal Home Loan Bank Housing Goals Amendments, RIN 2590–AA82 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposal to change the housing goals […]

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Sign-on letter regarding small dollar lending request for information, RIN 3064-ZA04

January 20, 2019 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation 550 Seventeenth Street NW Washington, D.C. 20429 Re:      Small Dollar Lending Request for Information, RIN 3064-ZA04 Dear Executive Secretary Feldman: On behalf of the National Community Reinvestment Coalition (NCRC) and our more than 600 community-based organizations, thank you for the […]

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Comment on CFPB RFI on data collection

December 21, 2018 Consumer Financial Protection Bureau 1700 G Street NW, Washington, DC 20552 Request for Information Regarding Bureau Data Collections Docket ID CFPB-2018-0031 To whom it may concern: This letter is in response to the request issued by the Consumer Financial Protection Bureau (“the CFPB”) and listed as Docket No. CFPB-2018-0031 in the Federal […]

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NCRC comments regarding Advance Notice of Proposed Rulemaking (Docket ID OCC–2018-0008) reforming the Community Reinvestment Act regulatory framework

November 8, 2018 Reforming the Community Reinvestment Act Regulatory Framework Docket ID OCC-2018-0008 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that the Community Reinvestment Act (CRA or Act) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. NCRC […]

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NCRC comment letter defending HUD’s Affirmatively Furthering Fair Housing Rule

October 15, 2018 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0500 Re:      Docket No. FR-6123-A-01 Advanced Notice of Proposed Rulemaking Affirmatively Furthering Fair Housing: Streamlining and Enhancements   Dear Assistant Secretary Farias: On behalf of the National Community […]

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Resolution to protect the Community Reinvestment Act – To ensure that efforts to modernize regulations do not undermine the intent of the law

The following sample resolution provides the history, purpose, and some of the basic functions of CRA and includes the key principles that are critical to preserve in the on-going regulatory reform effort by the nation’s bank regulators. This template is a start and can be adapted by non-profits, localities, state legislatures and other governing bodies moved for immediate adoption. It should […]

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Disparate impact reconsideration comments

August 20, 2018 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0001 Re: Docket No. FR-6111-A-01 Advanced Notice of Proposed Rulemaking Reconsideration of HUD’s Implementation of Fair Housing Act’s Disparate Impact Standard   Dear Assistant Secretary Farias: On behalf of […]

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NCRC analysis of OCC bulletin 2018-17

Supervisory Policy and Processes for Community Reinvestment Act Performance Evaluations OCC bulletin 2018-7 describes a number of technical and methodological issues concerning designation of assessment areas, data used on Community Reinvestment Act (CRA) exams, and scheduling of exams.[1] While this may seem technical in nature, the examination procedures outlined in the bulletin can have a […]

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