Dear Chairman Powell, Comptroller Otting and Chairman McWilliams:
We write to reiterate our grave concern about the impact of potential reforms to the Community Reinvestment Act (CRA). Any updates to this vital rule must be consistent with its original purpose of bringing financial services and credit access to low- and moderate-income (LMI) and underserved communities that continue to bear the legacy of redlining and blatant discrimination.
We urge the three banking agencies to jointly issue a CRA proposed rule. Moreover, as is outlined in further detail below, we strongly oppose any new evaluative metrics based on the aggregate dollar volume of a bank’s CRA activity, which would weaken CRA and hurt the LMI people and places it is intended to help. The agencies should not proceed until they are able to agree on a more constructive approach that strengthens the CRA.