Policy

Articles about NCRC policy issues.

Letter to the White House on affordable housing

(Download) July 30, 2019 President Donald J. Trump The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Dear President Trump: There have been a number of recent actions by the White House signaling the first real semblance of an Administration policy on affordable housing and homeownership. At the outset, we want to thank your …

Letter to the White House on affordable housing Read More »

data-scrabble-image

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.

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 …

Reforming the Community Reinvestment Act regulatory framework Read More »

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 …

Sign on letter for CRA ANPR Read More »

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 …

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

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 …

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

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 …

NCRC analysis of the advanced notice of proposed rulemaking (ANPR) Read More »

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 …

Disparate impact reconsideration comments Read More »

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).