Policy Archives

March 25, 2019March 26, 2019 by Josh Silver

Increasing community development financing data a necessary component for CRA reform

Data on community development lending and investing is lacking on a census tract level, making the information incomplete and difficult to assess. However, this is not the case for home mortgage lending data and small business loan data. If the federal regulatory agencies truly want to reform CRA, the first place to start is with better data. It would be a win-win for both banks and community organizations by facilitating identification of underserved areas. It would also further CRA’s objectives of directing access to credit and capital where it is needed most.

in Policy / Views

March 21, 2019 by NCRC

2019 Policy Agenda for the 116th session of Congress

Download the full Policy Agenda (PDF) Executive Summary For over 25 years, NCRC has worked to create a just economy. We believe private capital of various forms must be engaged in building an equitable and fair economy. There is both a legal and a moral obligation for banks and other financial institutions to invest and […]

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November 19, 2018 by NCRC

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 […]

in Policy

November 14, 2018January 11, 2019 by NCRC

Sign on letter for CRA ANPR

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 needs […]

in Policy

November 8, 2018February 11, 2019 by NCRC

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 […]

in Policy / Testimony & Regulatory Comments

October 15, 2018February 11, 2019 by NCRC

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 […]

in Policy / Testimony & Regulatory Comments

October 8, 2018October 22, 2018 by NCRC

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 […]

in Policy

September 6, 2018 by Josh Silver

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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August 21, 2018September 12, 2018 by NCRC

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 […]

in Policy / Testimony & Regulatory Comments

May 18, 2018 by NCRC

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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