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 […]

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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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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 […]

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NCRC analysis of OCC bulletin 2018-17

Supervisory Policy and Processes for Community Reinvestment Act Performance Evaluations OCC bulletin 2018-7 describes a number of technical and methodological issues concerning designation of assessment areas, data used on Community Reinvestment Act (CRA) exams, and scheduling of exams.[1] While this may seem technical in nature, the examination procedures outlined in the bulletin can have a […]

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Testimony of Stella Adams before the New York State Senate Democratic Conference

June 8, 2018 Senator Sanders, members of the Committee,  my name is Stella Adams, and I serve as the Chief of Equity and Inclusion for the National Community Reinvestment Coalition, more commonly known as NCRC. NCRC creates, implements, and supports long-term solutions and strategies that build community and promote individual economic well-being. The programs of […]

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Sign-on letter regarding CRA regulatory reform

(Download PDF) June 13, 2018 Dear Chairman McWilliams, Comptroller Otting, and Chairman Powell: Since 1977, the Community Reinvestment Act (CRA) has driven inclusion and equity in the financial markets. The act compels banks to serve the credit needs of their communities. It became an indispensable tool for historically marginalized communities excluded from the financial mainstream. […]

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NCRC comment on CFPB fair lending reviews and supervision

Docket No. CFPB-2018-0004 Effectiveness and Efficiency of Supervision Program To Whom it May Concern: The National Community Reinvestment Coalition (NCRC), a coalition of more than 600 community-based organizations, urges the CFPB to make the fair lending review process more transparent and to better facilitate community group input in the process. This letter represents the views […]

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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).

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Letter to the Senate: 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).

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