Testimony & Regulatory Comments

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

NCRC Comment Letter on HUD’s Proposed Rulemaking on the Equal Access Rule

By / September 25, 2020 / Testimony & Regulatory Comments

September 22, 2020 Regulations Division, Office of General Counsel, Department of Housing and Urban Development, 451 7th Street SW, Washington, DC 20410-0500. Re: HUD Docket No. FR-6152-P-01 Making Admission or Placement Determinations Based on Sex in Facilities Under Community Planning and Development Housing Programs Dear Secretary Carson: The National Community Reinvestment Coalition is vehemently opposed …

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NCRC Comment on Formative Application to OCC

By / September 24, 2020 / Testimony & Regulatory Comments

(Download) September 23rd, 2020 John O’Brien Licensing Manager Office of the Comptroller of the Currency Central District 425 S. Financial Place, Suite 1700 Chicago, IL 60605 CE.Licensing@occ.treas.gov RE: Formative Bank, N.A. Interagency Charter and Federal Deposit Insurance Application Dear Mr. O’Brien: The National Community Reinvestment Coalition, joined by the National Consumer Law Center (on behalf …

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Joint Comment: Final Qualified Mortgage (QM) Rule Must Effectively Protect Consumers and Promote Access to Responsible Mortgage Credit

By / September 11, 2020 / Testimony & Regulatory Comments

(Download) Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB’s) qualified mortgage (QM) proposed rule. Given CFPB’s decision to end the GSE patch, we believe that a price-based approach is an appropriate and effective method to determine QM status. However, additional safeguards are necessary to ensure that the final rule …

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The OCC “True Lender” rule will allow lenders to evade state consumer protections

By / January 5, 2021 / Testimony & Regulatory Comments

September 3rd, 2020 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005  Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Honorable Acting Comptroller Brooks: The undersigned respectfully submit this comment …

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NCRC Opposes National Banks and Federal Savings Associations as Lenders

By / September 4, 2020 / Testimony & Regulatory Comments

September 3rd, 2020 The National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Dear Mr. Brooks: We strongly oppose the Office of …

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GSE Capital Rule Comment Sign-on Letter

By / September 3, 2020 / Testimony & Regulatory Comments

Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework Thank you for the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) re-proposed rule on capital requirements for Fannie Mae and Freddie Mac (the governmentsponsored enterprises, or GSEs). In our view, the proposed rule erroneously treats the GSEs as banks and …

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NCRC Comment on SoFi’s Charter Application

By / August 13, 2020 / Testimony & Regulatory Comments

August 12, 2020 RE: NCRC Comment Letter on SoFi Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and 41 community organizations co-signing this letter maintain that Social Finance, Inc.’s (SoFi’s) application for a bank charter has not demonstrated a significant commitment to meeting the convenience and needs of the community …

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FHFA Re-Proposed Capital Rule for the Enterprises Sign-on Letter

By / August 13, 2020 / Testimony & Regulatory Comments

August 10, 2020 The Honorable Mark Calabria Director Federal Housing Finance Agency 400 7th Street, SW Washington, D.C. 20219 Hugh Frater CEO Fannie Mae Midtown Center 1100 15th Street, NW Washington, DC 20005 David Brickman CEO Freddie Mac 1551 Park Run Drive Mclean, VA 22102 Dear Director Calabria, Executives Frater and Brickman: We are writing …

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NCRC joins with over 50 groups in support of mortgage relief in next covid-19 relief package

By / August 11, 2020 / Testimony & Regulatory Comments

July 28, 2020  Majority Leader Mitch McConnell United States Senate Washington, DC 20510  Minority Leader Chuck Schumer United States Senate Washington, DC 20510  Chairman Mike Crapo Senate Committee on Banking, Housing and Urban Development Washington, DC 20510  Ranking Member Sherrod Brown Senate Committee on Banking, Housing and Urban Development Washington, DC 20510  Re: Support for …

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FHA and FHFA Forbearance Letter

By / June 25, 2020 / Testimony & Regulatory Comments

The Honorable Ben Carson Secretary U.S. Department of Housing and Urban Development 451 7th Street, SW Washington, D.C. 20210 The Honorable Mark Calabria Director Federal Housing Finance Agency 400 7th Street, SW Washington, D.C. 20219 Dear Secretary Carson and Director Calabria: We are writing to express our deep concern over recent policy changes regarding the …

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Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule

By / June 29, 2020 / Testimony & Regulatory Comments

Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule U.S. House of Representatives U.S. Capitol Washington, DC 20515 Dear Representative: On behalf of the undersigned organizations, we are writing to urge you to cosponsor and support H.J.Res. 90, a disapproval resolution that would overturn a poorly constructed rule change on …

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Analysis of the OCC’s Final CRA Rule

By / October 28, 2020 / Testimony & Regulatory Comments

The Office of the Comptroller of the Currency (OCC) released their Community Reinvestment Act (CRA) final rule on May 20. It will lessen the public accountability of banks to their communities by enacting performance measures on CRA exams that will be complex and opaque, while at the same time over-simplifying how to measure a bank’s …

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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

By / June 10, 2020 / Testimony & Regulatory Comments

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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NCRC Comment on the CFPB’s Request for Information to Assist the Taskforce on Federal Consumer Financial Law

By / June 3, 2020 / Testimony & Regulatory Comments

(Download) June 1, 2020 Comment Intake Bureau of Consumer Financial Protection 1700 G Street NW Washington, D.C. 20552 Re:       Docket No. CFPB-2020-0013 85 FR 18214 Request for Information to Assist the Taskforce on Federal Consumer Financial Law Dear Chief of Staff Weber: The National Community Reinvestment Coalition (NCRC) would like to respond to the …

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