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Testimony & Regulatory Comments

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

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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Position Paper on CRA Reform

(Download) The 123 undersigned organizations are pleased that the federal bank agencies will be proposing an interagency rule implementing the Community Reinvestment Act (CRA) in the near future. CRA has been instrumental in leveraging bank financing for retail lending and community development in low- and moderate-income (LMI) communities since its passage in 1977. A critical …

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NCRC Comment Letter on Figure Bank’s Charter Application

(Download) February 4, 2022 RE: NCRC Comment Letter on Figure Bank’s Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and 36 community organizations co-signing this letter maintain that Figure Bank’s application for a charter has not demonstrated a significant commitment to meeting the convenience and needs of the community to …

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Advocates Submit Letter to FDIC To Stop Banks From Fronting For Predatory Lenders

(Download) February 4, 2022 The Honorable Martin Gruenberg Acting Chairman Federal Deposit Insurance Corporation 1776 F Street, NW Washington, DC 20006 Rohit Chopra, Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20220 Michael Hsu, Acting Comptroller Office of the Comptroller of the Currency 400 7th Street, SW Washington, DC Dear Acting Chairman …

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NCRC Letter in Support Of Federal Reserve Nominees

(Download) Senator Sherrod Brown Chairman U.S. Senate Committee on Banking, Housing, and Urban Affairs 534 Dirksen Senate Office Building Washington, D.C. 20510 Dear Chairman Brown, The National Community Reinvestment Coalition (NCRC) and the undersigned organizations would like to express strong support for the nomination of Sarah Bloom Raskin to serve as Vice-Chair of Supervision for …

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Group letter on CFPB’s RFI on HMDA

(Download) January 21, 2022 RE: Request for Public Comment, HMDA Assessment, Docket No. CFPB-2021-0018 To Whom It May Concern: The 54 undersigned organizations extol the value of the new and enhanced Home Mortgage Disclosure Act (HMDA) variables added by the 2015 final rule issued by the Consumer Financial Protection Bureau (CFPB). The Dodd-Frank Wall Street …

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NCRC Expresses its Support for Greater Scrutiny of Bank Merger Applications; All Mergers Must Lead to Clear and Verifiable Benefits to the Public

(Download) January 20, 2022 Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation 1776 “F” Street, NW Washington, DC 20006 Dear Members of the Board of Directors of the Federal Deposit Insurance Corporation: The National Community Reinvestment Coalition (NCRC) and its undersigned member organizations express their support for the Federal Deposit Insurance Corporation’s (FDIC) action to …

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NCRC Comment on Proposed Section 1071 Small Business Lending Data Collection

(Download full comment) Introduction January 4, 2022 RE: Docket No. CFPB-2021-0015, Section 1071 Small Business Lending Data Collection To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to comment on the proposed rule for reporting and disseminating small business loan data required by Section 1071 of the Dodd Frank Wall …

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