NCRC sign-on letter regarding the FHFA’s notice of proposed rulemaking on the FHLB’s housing goals amendments

Alfred M. Pollard, General Counsel Federal Housing Finance Agency, Eighth Floor 400 7th Street SW Washington, DC 20219 Attention:  Federal Home Loan Bank Housing Goals Amendments, RIN 2590–AA82 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposal to change the housing goals […]

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Sign-on letter regarding small dollar lending request for information, RIN 3064-ZA04

January 20, 2019 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation 550 Seventeenth Street NW Washington, D.C. 20429 Re:      Small Dollar Lending Request for Information, RIN 3064-ZA04 Dear Executive Secretary Feldman: On behalf of the National Community Reinvestment Coalition (NCRC) and our more than 600 community-based organizations, thank you for the […]

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Comment on CFPB RFI on data collection

December 21, 2018 Consumer Financial Protection Bureau 1700 G Street NW, Washington, DC 20552 Request for Information Regarding Bureau Data Collections Docket ID CFPB-2018-0031 To whom it may concern: This letter is in response to the request issued by the Consumer Financial Protection Bureau (“the CFPB”) and listed as Docket No. CFPB-2018-0031 in the Federal […]

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NCRC comments regarding Advance Notice of Proposed Rulemaking (Docket ID OCC–2018-0008) reforming the Community Reinvestment Act regulatory framework

November 8, 2018 Reforming the Community Reinvestment Act Regulatory Framework Docket ID OCC-2018-0008 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that the Community Reinvestment Act (CRA or Act) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. NCRC […]

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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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