Testimony & Regulatory Comments

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

Joint Comment on Application of First Mid Bancshares to acquire Delta Bancshares Company and Jefferson Bank and Trust

October 18, 2021 Colette A. FriedAssistant Vice PresidentFederal Reserve Bank of Chicago230 South LaSalle StreetChicago, IL 60604 Via comments.applications@chi.frb.org RE: Comment on Application of First Mid Bancshares to acquire Delta Bancshares Company and Jefferson Bank and Trust Dear Ms. Fried: The St. Louis Equal Housing and Community Reinvestment Alliance (SLEHCRA) and the National Community Reinvestment …

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NCRC Submits Comment on Interagency Proposal for the Regulation of Partnerships between Banks and Fintechs

October 18, 2021 Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue, NW Washington, DC 20551. Federal Reserve Docket OP-1752 James P. Sheesley, Assistant Executive Secretary Attention: Comments-RIN 3064-ZA26, Legal ESS Federal Deposit Insurance Corporation 550 17th Street NW Washington, DC 20429. Chief Counsel’s Office Attention: Comment …

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Social Determinants of Health Caucus – Request for Information Letter

(Download) Attn SDOH Caucus Co-Chairs: Congresswoman Cheri Bustos Congressman G.K. Butterfield Congressman Tom Cole Congressman Markwayne Mullin RE: Social Determinants of Health Caucus – Request for Information Dear Members of Congress: Please accept this response to the Request for Information from the Congressional Caucus on Social Determinants of Health, on behalf of the National Community …

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NCRC, CRL, and NCLC File Joint Letter Opposing Acquisition of Liberty Bank

(Download) August 24, 2021 Janet Kincaid Deputy Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square Suite 2300 San Francisco, CA 94105 RE: Change in Control, KMD Partners, LLC to acquire Liberty Bank, Inc. Dear Ms. Kincaid: We ask the FDIC not to approve the application from KMD Partners, LLC to acquire …

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NCRC Comment on HUD’s Proposed Disparate Impact Rule

(Download) August 24, 2021 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. HUD-2021-0033 FR-6251-P-01 Reinstatement of Discriminatory Effects Standard Dear Assistant Secretary Worden: The National Community Reinvestment Coalition (NCRC) and the undersigned organizations would like to applaud the …

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Letter of support for Dave Uejio as Assistant Secretary for Fair Housing and Equal Opportunity, Department of Housing and Urban Development

August 4, 2021 The Honorable Sherrod Brown Chair, U.S. Senate Committee on Banking, Housing, and Urban Affairs 534 Dirksen Senate Office Building Washington, DC 20510 The Honorable Pat Toomey Ranking Member, U.S. Senate Committee on Banking, Housing, and Urban Affairs 534 Dirksen Senate Office Building Washington, DC 20510 Re: Letter of support for Dave Uejio as Assistant …

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Comment to FHFA on the Fannie Mae and Freddie Mac 2022-2024 Underserved Market Plans

(Download) July 16, 2021 Marcea Barringer, Senior Policy Analyst Federal Housing Finance Agency, Eighth Floor 400 Seventh Street, S.W. Washington, D.C. 20219 Attention: Duty to Serve 2022-2024 RFI Dear Ms. Barringer, The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to publicly comment on the Federal Housing Finance Agency’s (FHFA) request for input on the Fannie Mae …

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Consumer and community groups urge Federal Reserve Board to ensure that financial institutions benefiting from the payments system serve the public interest

(Download) National Community Reinvestment Coalition (NCRC) National Consumer Law Center (NCLC) (on behalf of its low income clients) Center for Responsible Lending (CRL) Comment to Board of Governors of the Federal Reserve System on the Proposed Guidelines for Evaluating Account and Service Requests July 12, 2021 Submitted electronically to regs.comments@federalreserve.gov Ann E Misback Secretary Board of Governors of …

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NCRC comment on HUD’s AFFH interim final rule

(Download) Sasha Samberg-Champion Deputy General Counsel for Enforcement and Fair Housing Regulations Division, Office of General Counsel Department of Housing and Urban Development 451 7th Street SW, Room 10276 Washington, DC 20410-0500 July 12, 2021 Dear Mr. Samberg-Champion, Thank you for the opportunity to submit comments regarding the Department of Housing and Urban Development (HUD)’s interim …

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Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning

(Download) July 1, 2021  Office of the Comptroller of the Currency: Docket ID OCC-2020-0049Board of Governors of the Federal Reserve System: Docket No. OP- 1743Federal Deposit Insurance Corporation: RIN 3064-ZA24Consumer Financial Protection Bureau: Docket No. CFPB-2021-0004National Credit Union Administration: Docket No. NCUA-2021-0023 RE: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, …

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Statement on Request for Guidance on Implementation of Disparate Impact Rules under ECOA

A proposal by National Community Reinvestment Coalition’s Innovation Council for Financial Inclusion. Preventing discrimination in the use of algorithms and predictive models is crucial for a fair financial system in the digital age. As a group of both consumer advocates and financial services companies, we have found a shared interest in encouraging a fair lending …

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Support for the Greater Supervision in Banking Act (H.R. 3948)

June 22, 2021 The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for …

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Support the Fair Lending for All Act (H.R. 166)

(Download) The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for H.R. 166, …

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NCRC Summary of the Section 203, Strengthening the Community Reinvestment Act of 1977, of the American Housing and Economic Mobility Act of 2021 (S. 1368, H.R. 2768)

Although the Community Reinvestment Act (CRA) and other fair lending laws have increased lending and investment in traditionally underserved communities, stubborn and persistent lending disparities by race and income remain. CRA needs an update and its coverage of the financial industry must be expanded. The overall objective of Section 203 is to increase lending, investments …

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Ncrc opposes the deposit insurance application of Payservices, Inc. for failing to include a CRA plan

April 8th, 2021 John Henrie Regional Director Federal Deposit Insurance Corporation 10 10th Street, NE Suite 800 Atlanta, GA 30309-3849 RE: Application for Deposit Insurance (New Bank) from PayServices, Inc. Dear Mr. Henrie: Please kindly accept our comment on the application from PayServices, Inc. (Delray Beach, Florida) for deposit insurance. PayServices failed to include a …

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