Testimony & Regulatory Comments

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

NCRC, consumer and community groups urge FDIC to deny insurance application for Rakuten ILC

February 19th, 2021 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Kathy L. Moe Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square Suite 2300 San Francisco, CA 94105-2780 RE: Comment Letter Regarding Deposit Insurance Application from Rakuten Bank America Dear Director Moe: The National Community Reinvestment Coalition (NCRC) …

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NCRC comment on Federal Reserve Board’s Advance Notice of Proposed Rulemaking regarding the Community Reinvestment Act – February 2021

DOWNLOAD FULL COMMENT Overview and introduction Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the thoughtfulness of the Federal Reserve Board’s (Board) approach to modernizing the regulations implementing the Community Reinvestment Act (CRA). NCRC is an association of community-based organizations whose mission is to …

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Over 100 groups call on Federal Reserve to Strengthen CRA

(Download) Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The Federal Reserve Board (Fed) must strengthen the rigor of CRA exams to promote recovery from the COVID-19 pandemic. The Fed has described approaches in its Advance Notice of Proposed Rulemaking (ANPR) on CRA that will make CRA exams more objective and …

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Civil Rights, Fair Lending And Consumer Rights Organizations Urge A More Race-Conscious CRA

(Download) February 16, 2021 Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Ave. NW Washington, DC 20551 RE:  Docket Number R-1723 and RIN Number 7100-AF94 Dear Ms. Misback: In its October 2020 Advance Notice of Proposed Rulemaking (ANPR), the Federal Reserve Board (FRB) invited public comment on …

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NCRC comment on OCC scoring methodology

(Download) February 2, 2021 RE: NCRC Comments on Docket ID OCC 2020–0025, Community Reinvestment Act regulations, methodology for determining thresholds on general performance standards To Whom it May Concern: The National Community Reinvestment Coalition, an association of community-based organizations dedicated to increasing lending and investing in underserved communities, opposes the Office of the Comptroller of …

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Joint letter urging the incoming Biden Administration to include homeowner assistance in the proposed American Rescue Plan

(Download) January 16, 2021 Joe Biden President-Elect Wilmington, DE Dear President-Elect Biden, We appreciate your leadership on COVID relief and Thursday’s announcement of a comprehensive effort to provide an emergency legislative package. The proposal includes many crucial priorities to heal our nation from the COVID-19 pandemic, both medical and economic, including additional rental assistance. We …

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Joint Consumer-Industry Comments to Veterans Administrations Partial Claims Proposal

(Download) January 8, 2021 Stephanie Li Chief of Regulations Loan Guaranty Service, Veterans Benefits Administration, Department of Veterans Affairs 810 Vermont Avenue NW Washington, DC 20420 RE:      RIN 2900-AR05—Loan Guaranty: COVID-19 Veterans Assistance Partial Claim Payment Program To whom it may concern: On behalf of the clients, communities, and industries that we represent, we write …

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NCRC Files Comment Opposing Charter Application from GM Financial

(Download) January 13, 2021 John Conneely Regional Director Federal Deposit Insurance Corporation 300 South Riverside Plaza, Suite 1700 Chicago, IL 60606-3447 RE: NCRC Comment Letter on GM Financial Bank Application Dear Director Conneelly: The National Community Reinvestment Coalition (NCRC) maintains that GM Financial Bank’s application for an Industrial Loan Charter (ILC) has not demonstrated a …

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NCRC Submits Comment on Oportun’s Application for a National Charter

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on Oportun’s application for a national bank charter. We request that the OCC extend the comment period for this application by 30 days to address numerous Community Reinvestment plan, loan pricing and debt collection practices raised by this application. Until these outstanding issues are addressed, we believe that the OCC does not have sufficient information to approve this application.

NCRC Comment Letter on the CFPB’s Outline of Proposals Under Consideration to Implement Small Business Lending Data Collection Requirements

(Download) December 14, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) outline of proposals under consideration …

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Joint Comment Letter From NCRC And 49 Organizations On The CFPB’s Proposal To Implement Small Business Lending Data Collection Requirements

(Download) Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (the Bureau) outline of proposals under consideration and alternatives …

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CRA & Race: The Federal Reserve’s Proposal on the Community Reinvestment Act (CRA)

The board’s question invites a dialogue about whether and where the Federal Reserve’s framework might affirmatively consider race more explicitly. While we are not yet committing to support various aspects of the Federal Reserve’s proposed framework for CRA examinations, this paper is designed to explore where and whether regulators could insert race in a framework like this from a statutory and constitutional perspective.

NCRC, CRL, and NCLC Send Comment Letter Opposing Figure’s Application for a National Bank Charter

(Download) December 7th, 2020 Mr. Louis Gittleman Director for District Licensing Western District Office 1225 17th Street, Suite 300 Denver, CO 80202 RE: Figure Bank, National Association: Charter application Dear Director Gittleman: Please accept this comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the …

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NCRC Comment on the CFPBs RFI on the Equal Credit Opportunity Act

(Download) December 1, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information on the Equal Credit Opportunity Act; Docket No. CFPB-2020-0026 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request For Information (RFI) on the Equal Credit …

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