Testimony & Regulatory Comments

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

Comment Period for CRA notice of proposed rulemaking now open

Today is the day, the clock is ticking, and we’ve got to mobilize everyone we know who cares about the economic health, wealth and justice in America’s communities. The government published today and opened up for public comments a plan to radically change and diminish the impact of the Community Reinvestment Act (CRA). Let’s make no …

Comment Period for CRA notice of proposed rulemaking now open Read More »

NCRC’s Letter to House and Senate Appropriations Committees on Housing Counseling Budget Needs

(Download) December 13, 2019 The Honarable Nita Lowey 2365 Rayburn House Office Building Washington, DC 20005 The Honorable Kay Granger 1026 Longworth House Office Building Washington, DC 20005 The Honorable Richard Shelby 304 Russell Senate Office Building Washington, DC 20005 The Honorable Patrick Leahy 437 Russell Senate Office Building Washington DC 20005 Dear Chairs and Ranking …

NCRC’s Letter to House and Senate Appropriations Committees on Housing Counseling Budget Needs Read More »

Initial NCRC Analysis of the FDIC and OCC Notice of Proposed Rulemaking Concerning the Community Reinvestment Act

In December 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking (NPRM) that would considerably weaken the regulations implementing the Community Reinvestment Act (CRA), a law designed to combat redlining by requiring banks to affirmatively and continually meet community needs for …

Initial NCRC Analysis of the FDIC and OCC Notice of Proposed Rulemaking Concerning the Community Reinvestment Act Read More »

Summary Fact Sheet on the OCC and FDIC CRA Proposed Rule

In the words of dissenting Federal Deposit Insurance Corporation (FDIC) Board member Martin Gruenberg, the FDIC and the Office of the Comptroller of the Currency’s (OCC) Notice of Proposed Rulemaking (NPRM) on the Community Reinvestment Act (CRA) “is a deeply misconceived proposal that would fundamentally undermine and weaken the Community Reinvestment Act.” The agencies would …

Summary Fact Sheet on the OCC and FDIC CRA Proposed Rule Read More »

NCRC Letter to CFPB Director Requesting Significant Improvement in the Public Dissemination of HMDA Data

December 9, 2019 Ms. Kathy Kraninger Director Consumer Financial Protection Bureau 1700 G. St. NW Washington DC, 20552 Dear Director Kraninger: Widely available and accessible Home Mortgage Disclosure Act (HMDA) data has been instrumental to achieving the statutory purpose of HMDA of assessing whether lending institutions are serving the housing and credit needs of communities. …

NCRC Letter to CFPB Director Requesting Significant Improvement in the Public Dissemination of HMDA Data Read More »

NCRC’s comment on reporting of data on loans to small businesses and farms

(Download) December 9, 2019 RE: Docket ID OCC-2019-0021, Loans to Small Businesses and Small Farms To Whom it May Concern: The National Community Reinvestment Coalition (NCRC), an association of more than 600 community-based organizations that promote access to basic banking services, affordable housing, entrepreneurship, job creation and vibrant communities for America’s working families, suggests that …

NCRC’s comment on reporting of data on loans to small businesses and farms Read More »

NCRC President and Founder John Taylor’s Oral Testimony at the CFPB Symposium: Section 1071 of the Dodd-Frank Act, November 6, 2019

I’ve been asked to talk about the importance of small business data. I want to begin by sounding a warning we should all head. The income inequality in our country, the highest of any industrialized nation and the highest it has been in 50 years, is a festering calamity building towards an explosion of American …

NCRC President and Founder John Taylor’s Oral Testimony at the CFPB Symposium: Section 1071 of the Dodd-Frank Act, November 6, 2019 Read More »

Statement of the National Community Reinvestment Coalition: Data Drives Access to Credit and Capital for Small Business

CFPB Symposium on Section 1071 Introduction – Importance of Small Business Loan Data The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to comment on the importance of data in understanding and monitoring the small business lending market. NCRC is an association of 600 community-based nonprofit organizations dedicated to increasing access to credit and capital …

Statement of the National Community Reinvestment Coalition: Data Drives Access to Credit and Capital for Small Business Read More »

NCRC’s Disparate Impact Letter to HUD

(Download) October 18, 2019 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-2019-0067 FR-6111-P-02 HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard Dear Assistant Secretary Farias: The National Community Reinvestment Coalition (NCRC) is committed to …

NCRC’s Disparate Impact Letter to HUD Read More »

Comment Letter on Advanced Notice of Proposed Rulemaking on HMDA Data Points

October 15, 2019 Comment on Advance Notice of Proposed Rulemaking (ANPR) Concerning HMDA Data Points Docket No. CFPB-2019-0020 To Whom It May Concern: The undersigned organizations (55 national and local organizations) oppose any dilution or diminishment of the new and enhanced Home Mortgage Disclosure Act (HMDA) variables added by the 2015 final rule issued by …

Comment Letter on Advanced Notice of Proposed Rulemaking on HMDA Data Points Read More »

Comment Letter on Notice of Proposed Rulemaking Concerning Which Lenders Report Data

October 15, 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 (214 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. As …

Comment Letter on Notice of Proposed Rulemaking Concerning Which Lenders Report Data Read More »

National Community Reinvestment Coalition’s Written Testimony for the U.S. House Financial Services Committee’s Diversity and Inclusion Subcommittee Hearing, ‘Examining the Racial and Gender Wealth Gap in America,’ Washington, DC, September 24, 2019

Good afternoon, thank you for inviting me here as Chief of Race, Wealth and Community of the National Community Reinvestment Coalition (NCRC) to speak about the racial wealth divide and what must be done to address this critical issue. NCRC was formed in 1990 and has grown into an association of more than 600 community-based …

National Community Reinvestment Coalition’s Written Testimony for the U.S. House Financial Services Committee’s Diversity and Inclusion Subcommittee Hearing, ‘Examining the Racial and Gender Wealth Gap in America,’ Washington, DC, September 24, 2019 Read More »

Letter to Regulators on Proposed CRA One-Ratio Reform

September 17, 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 Street, SW Washington, DC 20219 The Honorable Jelena McWilliams Chairman, Federal Deposit Insurance Corporation 550 17th Street, NW Washington, DC 20429 Dear …

Letter to Regulators on Proposed CRA One-Ratio Reform Read More »

NCRC comment letter on AmeriNat charter application

September 12, 2019 RE: NCRC Comment Letter on AmeriNat Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that AmeriNat’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 the Federal …

NCRC comment letter on AmeriNat charter application Read More »

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 …

Letter to regulators on CRA regulatory actions Read More »