Testimony & Regulatory Comments

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

Joint letter on the product and program limits imposed on Fannie Mae and Freddie Mac

(Download) April 6, 2021 The Honorable Janet Yellen Secretary Department of the Treasury 1500 Pennsylvania Ave, NW Washington, DC 20220 The Honorable Mark A. Calabria Director Federal Housing Finance Agency 400 7th St, SW Washington, DC 20024 Dear Secretary Yellen and Director Calabria, We are writing to express concerns about the various product and program …

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Joint industry-advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule

(Download) April 5, 2020 Mr. Dave Uejio Acting Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 RE:        Docket No. CFPB-2021-0003; RIN 3170-AA98; Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): General QM Loan Definition; Delay of Mandatory Compliance Date Dear Acting Director Uejio, The undersigned organizations write to …

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Joint advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule

(Download) April 5, 2021 Mr. Dave Uejio Acting Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Docket No. CFPB-2021-0003, Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): General QM Loan Definition; Delay of Mandatory Compliance Date Dear Acting Director Uejio: We the undersigned civil rights organizations are …

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NCRC comment on OMB Standards For Delineating The Metropolitan And Micropolitan Statistical Area, OMB-2021-0001

(Download) March 19, 2021 RE: OMB Standards for Delineating the Metropolitan and Micropolitan Statistical Area, OMB-2021-0001 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and the undersigned organizations oppose the Office of Management of Budget’s (OMB’s) proposed re-definition of metropolitan and micropolitan areas. Under the proposal, a metropolitan statistical area would be …

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Letter of support for Don Graves to be next Deputy Commerce Secretary

(Download) The Honorable Maria Cantwell Chair Committee on Commerce, Science and Transportation United States Senate Washington, DC 20510 The Honorable Roger Wicker Ranking Member Committee on Commerce, Science and Transportation United States Senate Washington, DC 20510 March 17, 2021 Re: Consumer, community and civil rights groups urge confirmation of Don Graves for Deputy Secretary, Department …

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Joint Letter urging inclusion of the Neighborhood Homes Investment Act in the Administration’s infrastructure proposal

(Download) March 17, 2021 The Honorable Joseph R. Biden, Jr. The White House 1600 Pennsylvania Avenue, N.W. Washington DC 20500 Dear President Biden: We are a diverse and broad coalition of nonprofits, real estate trade groups, lenders, and civil rights advocates, brought together by a shared belief that we need a policy solution that expands …

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NCRC’s comment on Brex’s charter application

(Download) March 15, 2021 RE: Comment on Brex’s charter application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that Brex’s application for deposit insurance for an Industrial Loan Charter (ILC) would not accord with safety and soundness standards for banks and has not demonstrated a significant commitment to meeting the convenience …

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NCRC Urges Robust Affordable Housing Goals & FHFA Policies To Support Them

(Download) February 28, 2021 Alfred M. Pollard, General Counsel Federal Housing Finance Agency, Eighth Floor 400 Seventh Street SW Washington, DC Attention: Comments/RIN 2590–AB12 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to publicly comment on the Federal Housing Finance Agency’s (FHFA) advance notice of proposed rulemaking on the Enterprise Housing …

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NCRC urges support for the Fair Lending for All Act (HR166), recommends strengthening enforcement to prevent lending discrimination

(Download) February 26, 2021 The Honorable Al Green Chair Committee on Financial Services Subcommittee on Oversight and Investigations United States House of Representatives Washington, DC 20515 The Honorable Andy Barr Ranking Member Committee on Financial Services Subcommittee on Oversight and Investigations United States House of Representatives Washington, DC 20515 Dear Chairman Green, Ranking Member Barr …

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NCRC, consumer and community groups urge FDIC to deny insurance application for Rakuten ILC

February 19th, 2021 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Kathy L. Moe Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square Suite 2300 San Francisco, CA 94105-2780 RE: Comment Letter Regarding Deposit Insurance Application from Rakuten Bank America Dear Director Moe: The National Community Reinvestment Coalition (NCRC) …

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NCRC comment on Federal Reserve Board’s Advance Notice of Proposed Rulemaking regarding the Community Reinvestment Act – February 2021

DOWNLOAD FULL COMMENT Overview and introduction Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the thoughtfulness of the Federal Reserve Board’s (Board) approach to modernizing the regulations implementing the Community Reinvestment Act (CRA). NCRC is an association of community-based organizations whose mission is to …

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Over 100 groups call on Federal Reserve to Strengthen CRA

(Download) Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The Federal Reserve Board (Fed) must strengthen the rigor of CRA exams to promote recovery from the COVID-19 pandemic. The Fed has described approaches in its Advance Notice of Proposed Rulemaking (ANPR) on CRA that will make CRA exams more objective and …

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Civil Rights, Fair Lending And Consumer Rights Organizations Urge A More Race-Conscious CRA

(Download) February 16, 2021 Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Ave. NW Washington, DC 20551 RE:  Docket Number R-1723 and RIN Number 7100-AF94 Dear Ms. Misback: In its October 2020 Advance Notice of Proposed Rulemaking (ANPR), the Federal Reserve Board (FRB) invited public comment on …

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NCRC comment on OCC scoring methodology

(Download) February 2, 2021 RE: NCRC Comments on Docket ID OCC 2020–0025, Community Reinvestment Act regulations, methodology for determining thresholds on general performance standards To Whom it May Concern: The National Community Reinvestment Coalition, an association of community-based organizations dedicated to increasing lending and investing in underserved communities, opposes the Office of the Comptroller of …

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