Testimony & Regulatory Comments

Testimony and comments from NCRC about pending legislation and regulatory issues.

Joint Trades and Consumer organization request for Comment Period Extensions

The undersigned trade associations and organizations representing banks, credit unions and consumer interests write to share our concern with the brevity of the public comment period provided for recent novel national bank and national trust charter applications. The charters are not new, but the utilization of those existing charters by non-traditional applicants is significant.

NCRC Comment Letter on the FHFA’s 2021 Affordable Housing Goals Proposed Rule

(Download) October 13, 2020 Alfred M. Pollard, General Counsel, Attention: Comments/ RIN 2590–AB04 Federal Housing Finance Agency, Eighth Floor 400 Seventh Street, S.W. Washington, D.C. 20219 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) thanks you for the opportunity to publicly comment on the Federal Housing Finance Agency’s (FHFA) proposal to extend the 2018-2020 …

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NCRC comments on DOJ merger review guidelines

(Download) October 16, 2020 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Department of Justice’s (DOJ’s) merger review analysis. NCRC is an association of community-based organizations whose mission is to increase access to credit and capital in traditionally underserved communities. Our members are actively involved …

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NCRC Comment Letter on HUD’s Proposed Rulemaking on the Equal Access Rule

September 22, 2020 Regulations Division, Office of General Counsel, Department of Housing and Urban Development, 451 7th Street SW, Washington, DC 20410-0500. Re: HUD Docket No. FR-6152-P-01 Making Admission or Placement Determinations Based on Sex in Facilities Under Community Planning and Development Housing Programs Dear Secretary Carson: The National Community Reinvestment Coalition is vehemently opposed …

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NCRC Comment on Formative Application to OCC

(Download) September 23rd, 2020 John O’Brien Licensing Manager Office of the Comptroller of the Currency Central District 425 S. Financial Place, Suite 1700 Chicago, IL 60605 CE.Licensing@occ.treas.gov RE: Formative Bank, N.A. Interagency Charter and Federal Deposit Insurance Application Dear Mr. O’Brien: The National Community Reinvestment Coalition, joined by the National Consumer Law Center (on behalf …

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Joint Comment: Final Qualified Mortgage (QM) Rule Must Effectively Protect Consumers and Promote Access to Responsible Mortgage Credit

(Download) Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule …

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National Banks and Federal Savings Associations as Lenders Comment Sign-On Letter

September 3rd, 2020 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005  Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Honorable Acting Comptroller Brooks: The undersigned respectfully submit this comment …

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NCRC Opposes National Banks and Federal Savings Associations as Lenders

September 3rd, 2020 The National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Dear Mr. Brooks: We strongly oppose the Office of …

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GSE Capital Rule Comment Sign-on Letter

Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework Thank you for the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) re-proposed rule on capital requirements for Fannie Mae and Freddie Mac (the governmentsponsored enterprises, or GSEs). In our view, the proposed rule erroneously treats the GSEs as banks and …

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NCRC Comment on SoFi’s Charter Application

August 12, 2020 RE: NCRC Comment Letter on SoFi Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and 41 community organizations co-signing this letter maintain that Social Finance, Inc.’s (SoFi’s) application for a bank charter has not demonstrated a significant commitment to meeting the convenience and needs of the community …

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FHFA Re-Proposed Capital Rule for the Enterprises Sign-on Letter

August 10, 2020 The Honorable Mark Calabria Director Federal Housing Finance Agency 400 7th Street, SW Washington, D.C. 20219 Hugh Frater CEO Fannie Mae Midtown Center 1100 15th Street, NW Washington, DC 20005 David Brickman CEO Freddie Mac 1551 Park Run Drive Mclean, VA 22102 Dear Director Calabria, Executives Frater and Brickman: We are writing …

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NCRC joins with over 50 groups in support of mortgage relief in next covid-19 relief package

July 28, 2020  Majority Leader Mitch McConnell United States Senate Washington, DC 20510  Minority Leader Chuck Schumer United States Senate Washington, DC 20510  Chairman Mike Crapo Senate Committee on Banking, Housing and Urban Development Washington, DC 20510  Ranking Member Sherrod Brown Senate Committee on Banking, Housing and Urban Development Washington, DC 20510  Re: Support for …

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FHA and FHFA Forbearance Letter

The Honorable Ben Carson Secretary U.S. Department of Housing and Urban Development 451 7th Street, SW Washington, D.C. 20210 The Honorable Mark Calabria Director Federal Housing Finance Agency 400 7th Street, SW Washington, D.C. 20219 Dear Secretary Carson and Director Calabria: We are writing to express our deep concern over recent policy changes regarding the …

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Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule

Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule U.S. House of Representatives U.S. Capitol Washington, DC 20515 Dear Representative: On behalf of the undersigned organizations, we are writing to urge you to cosponsor and support H.J.Res. 90, a disapproval resolution that would overturn a poorly constructed rule change on …

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