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Testimony & Regulatory Comments

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

NCRC Comment on Responsible Development of Digital Assets

(Download) August 8, 2022 Natalia Li Deputy Director Office of Financial Institutions Policy Department of the Treasury 1500 Pennsylvania Ave. NW Washington, DC 20220 RE: Docket 2022-14588 Ensuring Responsible Development of Digital Assets Dear Ms. Li: Thank you for the opportunity to comment on these questions. The National Community Reinvestment Coalition (NCRC) is an association …

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NCRC’s Full Public Comment Letter On Community Reinvestment Act Interagency Rulemaking

(Download) Chief Counsel’s Office Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219 Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 James P. Sheesley Assistant Executive Secretary Federal Deposit Insurance Corporation 550 17th Street NW …

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Testimony of Catherine Crosby, Town Manager, Town of Apex; Board Chairperson, National Community Reinvestment Coalition

(Download) “Better, Together: Examining the Unified Proposed Rule to Modernize the Community Reinvestment Act” House Financial Services Subcommittee on Consumer Protection and Financial Institutions, July 13, 2022 I am honored to testify before you today on the proposed regulatory reform of the Community Reinvestment Act. I am the board chairperson of the National Community Reinvestment …

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40 Groups Urge FDIC To Downgrade TAB Bank

(Download) June 30, 2022 Janet R. Kincaid Deputy Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square, Suite 2300 San Francisco, CA 94105 RE: Community Reinvestment Exam for TAB Bank Honorable Deputy Regional Director Kincaid: The National Community Reinvestment Coalition and the undersigned groups believe that the practices discussed in this comment …

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Resolution To Protect The Community Reinvestment Act – To Ensure That Efforts To Modernize Regulations Do Not Undermine The Intent Of The Law

The following sample resolution provides the history, purpose, and some of the basic functions of CRA and includes the key principles that are critical to preserve in the on-going regulatory reform effort by the nation’s bank regulators. This template is a start and can be adapted by non-profits, localities, state legislatures and other governing bodies moved for immediate adoption. It should …

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Statement on the Need for An Interpretive Rule Concerning the Solicitation of Demographic Data for the Purposes of Fair Lending Self-Testing

(Download) June 22, 2022 We are a group of fintechs and consumer advocates who share a common interest in making the credit system fairer for historically underserved consumers. On June 29, 2021, the National Community Reinvestment Coalition and Affirm, Lending Club, Oportun, PayPal, Square (now “Block”), and Varo provided a joint statement to the Consumer …

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Regarding: Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (RIN 3064-ZA31)

(Download) May 30th, 2022 James P. Sheesley Assistant Executive Secretary Federal Deposit Insurance Corporation 550 17th St. NW Washington, DC 20429 Regarding: Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (RIN 3064-ZA31) Sent by electronic mail to comments@fdic.gov Dear Mr. Sheesley: The National Community Reinvestment Coalition (NCRC) appreciates that the …

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NCRC Calls on Federal Reserve to Refrain from Issuing CBDC

Ann E. Misback Secretary Board of Governors of the Federal Reserve 230 S LaSalle Street Chicago, IL 60604 RE: CBDC Benefits, Risks, and Policy Considerations Sent via electronic mail to digital-innovations@frb.gov Dear Secretary Misback: We appreciate the opportunity to provide our comments on the subject of a Federal Reserve central bank digital currency (CBDC). The National …

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NCRC, Partner Groups Submit Letter to Federal Reserve on Requiring Deposit Insurance and Supervision For All Financial Institutions That Receive Master Accounts

(Download) April 22, 2022 Ms. Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 Submitted electronically to regs.comments@federalreserve.gov Re:       Docket No. OP-1765: Supplemental Notice and Request on Guidelines for Evaluating Account and Services Requests. Dear Secretary Misback: The Center for Responsible Lending, National Community Reinvestment …

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CFPB Should Encourage Lenders to Look for Less Discriminatory Models

(Download) March 11, 2022 The Honorable Rohit Chopra Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Via email  RE:     CFPB Tools for Ensuring That Creditors Do Not Rely on Discriminatory Models Dear Director Chopra: On behalf of the National Community Reinvestment Coalition, Upturn, and Zest AI, we write to urge the Consumer …

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Letter In Support Of Bipartisan Close the ILC Loophole Act

April 5, 2022 The Honorable Maxine Waters Chairwoman Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 Re: Support for H.R. 5912, The Close the ILC Loophole Act Dear Chairwoman Waters and Ranking Member McHenry, The …

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NCRC Comment Letter On “Buy Now Pay Later” Consumer Finance Products

(Download) March 25th, 2022 Director Rohit Chopra Consumer Financial Protection Bureau 1700 “G” St. NW Washington, DC 20552 Regarding Docket CFPB-2022-0002: Notice and Request for Comment Regarding the CFPB’s Inquiry into Buy-Now-Pay-Later Honorable Director Chopra: Thank you for the opportunity to respond to the Bureau’s request for comments on buy-now-pay-later (BNPL) products. NCRC is a …

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NCRC Letter Urging Senate To Vote On Delayed David Uejio Nomination

(Download) March 24, 2022 The Honorable Charles Schumer Majority Leader United States Senate 322 Hart Senate Office Building Washington, D.C. 20510 Re: Confirmation of Dave Uejio as Assistant Secretary for Fair Housing and Equal Opportunity, Department of Housing and Urban Development Dear Senator Schumer: On behalf of the undersigned organizations, we write to express our …

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NCRC Remarks To Federal Regulators On US Bank Merger

Jesse Van Tol, President and CEO of the National Community Reinvestment Coalition, provided the following testimony on March 8, 2022, to regulators reviewing the proposed merger of U.S. Bancorp and MUFG Union Bank.  Good morning. I’m Jesse Van Tol and I’m the President and CEO of the National Community Reinvestment Coalition (NCRC). I will detail …

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