Reforming the Community Reinvestment Act regulatory framework

  November 19, 2018 Reforming the Community Reinvestment Act Regulatory Framework Docket ID OCC-2018-0008   To Whom it May Concern: The undersigned groups maintain that the Community Reinvestment Act (CRA) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. Any CRA reform effort […]

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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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10 bad ideas for CRA (regulatory) reform

10 bad ideas & bank-centric proposals for CRA regulatory reform An OCC-only approach to CRA reform On August 28, 2018, the OCC released an advance notice of proposed rulemaking (ANPR) that asks 31 questions on how to reform CRA regulations.  The public comment period closes November 19th.  NCRC research has found that a significant weakening […]

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NCRC analysis of the advanced notice of proposed rulemaking (ANPR)

On August 28, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) concerning the Community Reinvestment Act (CRA). The ANPR does not propose specific changes to the regulation implementing CRA. Instead, the OCC describes concepts or frameworks for changing CRA and poses several questions regarding the effectiveness […]

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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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2018 Policy Agenda: Investing in a just economy

Investing in a Just Economy For over 27 years, NCRC has worked to create a just economy. We believe private capital of various forms – including a wide variety of financial institutions – must be engaged in building an equitable and fair economy. There is both a legal and a moral obligation for banks and […]

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Letter to the House of Representatives: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

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Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

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Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

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