Testimony & Regulatory Comments

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

NCRC comments regarding Advance Notice of Proposed Rulemaking (Docket ID OCC–2018-0008) reforming the Community Reinvestment Act regulatory framework

By / February 11, 2019 / Policy, Testimony & Regulatory Comments

November 8, 2018 Reforming the Community Reinvestment Act Regulatory Framework Docket ID OCC-2018-0008 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that the Community Reinvestment Act (CRA or Act) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. NCRC …

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NCRC comment letter defending HUD’s Affirmatively Furthering Fair Housing Rule

By / February 11, 2019 / Testimony & Regulatory Comments, Policy

October 15, 2018 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0500 Re:      Docket No. FR-6123-A-01 Advanced Notice of Proposed Rulemaking Affirmatively Furthering Fair Housing: Streamlining and Enhancements   Dear Assistant Secretary Farias: On behalf of the National Community …

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Disparate impact reconsideration comments

By / September 12, 2018 / Testimony & Regulatory Comments, Policy

August 20, 2018 Regulations Division, 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. FR-6111-A-01 Advanced Notice of Proposed Rulemaking Reconsideration of HUD’s Implementation of Fair Housing Act’s Disparate Impact Standard   Dear Assistant Secretary Farias: On behalf of …

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NCRC analysis of OCC bulletin 2018-17

By / July 19, 2018 / Testimony & Regulatory Comments

Supervisory Policy and Processes for Community Reinvestment Act Performance Evaluations OCC bulletin 2018-7 describes a number of technical and methodological issues concerning designation of assessment areas, data used on Community Reinvestment Act (CRA) exams, and scheduling of exams.[1] While this may seem technical in nature, the examination procedures outlined in the bulletin can have a …

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Testimony of Stella Adams before the New York State Senate Democratic Conference

By / June 12, 2018 / Testimony & Regulatory Comments

June 8, 2018 Senator Sanders, members of the Committee,  my name is Stella Adams, and I serve as the Chief of Equity and Inclusion for the National Community Reinvestment Coalition, more commonly known as NCRC. NCRC creates, implements, and supports long-term solutions and strategies that build community and promote individual economic well-being. The programs of …

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Sign-on letter regarding CRA regulatory reform

By / July 25, 2018 / Testimony & Regulatory Comments

(Download PDF) June 13, 2018 Dear Chairman McWilliams, Comptroller Otting, and Chairman Powell: Since 1977, the Community Reinvestment Act (CRA) has driven inclusion and equity in the financial markets. The act compels banks to serve the credit needs of their communities. It became an indispensable tool for historically marginalized communities excluded from the financial mainstream. …

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NCRC comment on CFPB fair lending reviews and supervision

By / May 22, 2018 / Testimony & Regulatory Comments

Docket No. CFPB-2018-0004 Effectiveness and Efficiency of Supervision Program To Whom it May Concern: The National Community Reinvestment Coalition (NCRC), a coalition of more than 600 community-based organizations, urges the CFPB to make the fair lending review process more transparent and to better facilitate community group input in the process. This letter represents the views …

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Letter to the House of Representatives: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

By / May 2, 2018 / Testimony & Regulatory Comments, Policy

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

By / May 2, 2018 / Testimony & Regulatory Comments, Policy

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

NCRC analysis of CRA Treasury report

By / April 18, 2018 / Testimony & Regulatory Comments

The Department of Treasury released its long anticipated memorandum recommending changes and updates to the Community Reinvestment Act (CRA) in early April. Spring is a season of renewal and CRA is a law that indeed needs refreshing and updating. Passed in 1977, it imposes an affirmative obligation on banks to serve the needs of local communities. The statute directs federal bank agencies to examine and rate banks on their lending and service in low- and moderate-income communities.

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

By / March 13, 2018 / Testimony & Regulatory Comments, Policy

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

NCRC’s congressional testimony on fintech oversight

By / February 12, 2018 / Uncategorized, Testimony & Regulatory Comments

Statement for the record from John Taylor, president and CEO, of the National Community Reinvestment Coalition to the House Financial Services Subcommittee on House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit   January 30, 2018 Chairman Luetkemeyer, Ranking Member Clay, and Distinguished members of the Subcommittee: The National Community Reinvestment Coalition (NCRC) appreciates …

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Letter to Treasury: Strengthening the Community Reinvestment Act

By / March 26, 2018 / Testimony & Regulatory Comments

The Honorable Steven T. Mnuchin Secretary of the Treasury Department of the Treasury 1500 Pennsylvania Ave NW Washington DC, 20220 Click here for a summary of the letter.   Dear Secretary Mnuchin, In February of 2017, President Trump issued an executive order mandating that federal agencies regulate the financial industry consistent with core principles including …

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Don’t blame the affordable housing goals for the financial crisis 

By / February 11, 2019 / Testimony & Regulatory Comments

Federal Research Financial Crisis Inquiry Report (2010)[1] “Conclusions of the Financial Crisis Inquiry Commission” “We also studied at length how the Department of Housing and Urban Development’s (HUD’s) affordable housing goals for the GSEs affected their investment in risky mortgages. Based on the evidence and interviews with dozens of individuals involved in this subject area, …

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