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Testimony & Regulatory Comments

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

Letter to regulators on CRA regulatory actions

September 9, 2019 The Honorable Jerome H. Powell Chairman, Federal Reserve Board of Governors 20th Street and Constitution Avenue NW Washington, DC 20551 The Honorable Joseph Otting Comptroller of the Currency 400 7th St SW Washington, DC 20219 The Honorable Jelena McWilliams Chairman, Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Dear […]

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National Community Reinvestment Coalition’s written testimony for the U.S House committee on financial services field hearing in Houston, Texas, September 4, 2019

Our results show a pattern of disinvestment and discouragement that contributes to the wide disparities in small business ownership for blacks and Hispanics in the U.S.

National Community Reinvestment Coalition’s written testimony for the U.S House committee on financial services field hearing in Houston, Texas, September 4, 2019 Read More »

NCRC Comment letter on Rakuten Charter application

  (Download) August 27, 2019 RE: NCRC Comment Letter on Rakuten Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that Rakuten’s application for an Industrial Loan Charter (ILC) has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served as required per

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Letter to the White House on affordable housing

(Download) July 30, 2019 President Donald J. Trump The White House 1600 Pennsylvania Avenue NW Washington, DC 20500 Dear President Trump: There have been a number of recent actions by the White House signaling the first real semblance of an Administration policy on affordable housing and homeownership. At the outset, we want to thank your

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Comment on HUD’s Opportunity Zone policy

(Download) June 17, 2019 Public Finance and Regulatory Analysis Division Office of Policy Development and Research Department of Housing and Urban Development 451 7th Street SW, Room 8216 Washington, DC 20410-0500 Via Federal eRulemaking Portal Re: Docket No. FR–6155–N–01 Request for Information Review of HUD Policy in Opportunity Zones  Dear Secretary Carson: On behalf of

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The purpose and design of the Community Reinvestment Act (CRA): An examination of the 1977 hearings and passage of the CRA

A version of this article appeared first in Conference of Consumer Finance Law, Quarterly Report, Vol. 72, No. 4 Introduction In 2019, the Community Reinvestment Act (CRA) will be forty-two years old.[1]  Congress enacted the CRA in 1977 as a community development initiative that sought to leverage the financial resources of private sector institutions.  Senator

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Notice of proposed rulemaking, HMDA reporting thresholds

(Download) June 12, 2019 Docket No. CFPB-2019-0021 or RIN 3170-AA76 Notice of Proposed Rulemaking, HMDA Reporting Thresholds To Whom it May Concern: The undersigned organizations (158 national and local organizations) oppose the proposal of the Consumer Financial Protection Bureau (CFPB) to exempt thousands of lending institutions from reporting the Home Mortgage Disclosure Act (HMDA) data.

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NCRC comment letter on Robinhood’s charter application

May 29 2019 RE: NCRC Comment Letter on Robinhood’s Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that Robinhood’s charter application has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served as required by the Community Reinvestment Act (CRA) and the

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NCRC CEO testifies on BB&T/SunTrust merger

Testimony of Jesse Van Tol, CEO, National Community Reinvestment Coalition, April 25, 2019, in Charlotte, North Carolina, at a hearing on the proposed BB&T/SunTrust bank merger with the Federal Reserve Board and Federal Deposit Insurance Corporation. Thank you for the opportunity to testify here today. My name is Jesse Van Tol, and I am the

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A review of the state of barriers to minority homeownership

(Download) Statement of the National Community Reinvestment Coalition U.S. House Committee on Financial Services Subcommittee on Housing, Community Development and Insurance May 8, 2019 Chairman Clay, Ranking member Duffy and members of the Subcommittee on Housing, Community Development and Insurance: The National Community Reinvestment Coalition (NCRC) commends you for holding this review on the state of and barriers

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Testimony of Jesse Van Tol, CEO, National Community Reinvestment Coalition, April 9, 2019 – Consumer Protection and Financial Institutions Subcommittee

The Community Reinvestment Act: Assessing the Law’s Impact on Discrimination and Redlining   Introduction: Public input and accountability are the keys to CRA’s success I thank Chairman Meeks and the members of this subcommittee for providing me the honor of testifying this morning regarding the Community Reinvestment Act’s (CRA) impact in combating discrimination and redlining.

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Request for information on FDIC’s deposit insurance application process

RIN 3064-ZA03 March 29, 2019 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to respond to the FDIC’s request for information regarding the application process for deposit insurance. As a coalition of 600 community-based organizations, NCRC believes that a clear and transparent process for deposit insurance applications is critical

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NCRC’s Comment on FHFA’s Proposal on Credit Score Models

(Download) March 21, 2019 Alfred M. Pollard General Counsel Federal Housing Finance Agency, Eighth Floor 400 7th Street, SW Washington, D.C. 20219 Attention: Comments/RIN 2590–AA98) Dear Mr. Pollard: We appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) notice of proposed rulemaking on credit score models.  For more than 25 years, the

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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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