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Testimony & Regulatory Comments

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

Resolution To Protect The Community Reinvestment Act – To Ensure That Efforts To Modernize Regulations Do Not Undermine The Intent Of The Law

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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Statement on the Need for An Interpretive Rule Concerning the Solicitation of Demographic Data for the Purposes of Fair Lending Self-Testing

(Download) June 22, 2022 We are a group of fintechs and consumer advocates who share a common interest in making the credit system fairer for historically underserved consumers. On June 29, 2021, the National Community Reinvestment Coalition and Affirm, Lending Club, Oportun, PayPal, Square (now “Block”), and Varo provided a joint statement to the Consumer

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Regarding: Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (RIN 3064-ZA31)

(Download) May 30th, 2022 James P. Sheesley Assistant Executive Secretary Federal Deposit Insurance Corporation 550 17th St. NW Washington, DC 20429 Regarding: Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (RIN 3064-ZA31) Sent by electronic mail to comments@fdic.gov Dear Mr. Sheesley: The National Community Reinvestment Coalition (NCRC) appreciates that the

Regarding: Request for Comment on Rules, Regulations, Guidance, and Statement of Policy on Bank Merger Transactions (RIN 3064-ZA31) Read More »

NCRC Calls on Federal Reserve to Refrain from Issuing CBDC

Ann E. Misback Secretary Board of Governors of the Federal Reserve 230 S LaSalle Street Chicago, IL 60604 RE: CBDC Benefits, Risks, and Policy Considerations Sent via electronic mail to digital-innovations@frb.gov Dear Secretary Misback: We appreciate the opportunity to provide our comments on the subject of a Federal Reserve central bank digital currency (CBDC). The National

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NCRC, Partner Groups Submit Letter to Federal Reserve on Requiring Deposit Insurance and Supervision For All Financial Institutions That Receive Master Accounts

(Download) April 22, 2022 Ms. Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 Submitted electronically to regs.comments@federalreserve.gov Re:       Docket No. OP-1765: Supplemental Notice and Request on Guidelines for Evaluating Account and Services Requests. Dear Secretary Misback: The Center for Responsible Lending, National Community Reinvestment

NCRC, Partner Groups Submit Letter to Federal Reserve on Requiring Deposit Insurance and Supervision For All Financial Institutions That Receive Master Accounts Read More »

CFPB Should Encourage Lenders to Look for Less Discriminatory Models

(Download) March 11, 2022 The Honorable Rohit Chopra Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Via email  RE:     CFPB Tools for Ensuring That Creditors Do Not Rely on Discriminatory Models Dear Director Chopra: On behalf of the National Community Reinvestment Coalition, Upturn, and Zest AI, we write to urge the Consumer

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Letter In Support Of Bipartisan Close the ILC Loophole Act

April 5, 2022 The Honorable Maxine Waters Chairwoman Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 Re: Support for H.R. 5912, The Close the ILC Loophole Act Dear Chairwoman Waters and Ranking Member McHenry, The

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OFN, NCRC Letter to SBA to Support proposed reforms to the Community Advantage Pilot Program

The Opportunity Finance Network (OFN) and the National Community Reinvestment Coalition (NCRC), along with the undersigned, are writing to express our strong support for the Small Business Administration’s (SBA) proposed reforms to the Community Advantage Pilot Program.

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NCRC Comment Letter On “Buy Now Pay Later” Consumer Finance Products

(Download) March 25th, 2022 Director Rohit Chopra Consumer Financial Protection Bureau 1700 “G” St. NW Washington, DC 20552 Regarding Docket CFPB-2022-0002: Notice and Request for Comment Regarding the CFPB’s Inquiry into Buy-Now-Pay-Later Honorable Director Chopra: Thank you for the opportunity to respond to the Bureau’s request for comments on buy-now-pay-later (BNPL) products. NCRC is a

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NCRC Letter Urging Senate To Vote On Delayed David Uejio Nomination

(Download) March 24, 2022 The Honorable Charles Schumer Majority Leader United States Senate 322 Hart Senate Office Building Washington, D.C. 20510 Re: Confirmation of Dave Uejio as Assistant Secretary for Fair Housing and Equal Opportunity, Department of Housing and Urban Development Dear Senator Schumer: On behalf of the undersigned organizations, we write to express our

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NCRC Remarks To Federal Regulators On US Bank Merger

Jesse Van Tol, President and CEO of the National Community Reinvestment Coalition, provided the following testimony on March 8, 2022, to regulators reviewing the proposed merger of U.S. Bancorp and MUFG Union Bank.  Good morning. I’m Jesse Van Tol and I’m the President and CEO of the National Community Reinvestment Coalition (NCRC). I will detail

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Position Paper on CRA Reform

(Download) The 123 undersigned organizations are pleased that the federal bank agencies will be proposing an interagency rule implementing the Community Reinvestment Act (CRA) in the near future. CRA has been instrumental in leveraging bank financing for retail lending and community development in low- and moderate-income (LMI) communities since its passage in 1977. A critical

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NCRC Comment Letter on Figure Bank’s Charter Application

(Download) February 4, 2022 RE: NCRC Comment Letter on Figure Bank’s Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and 36 community organizations co-signing this letter maintain that Figure Bank’s application for a charter has not demonstrated a significant commitment to meeting the convenience and needs of the community to

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Advocates Submit Letter to FDIC To Stop Banks From Fronting For Predatory Lenders

(Download) February 4, 2022 The Honorable Martin Gruenberg Acting Chairman Federal Deposit Insurance Corporation 1776 F Street, NW Washington, DC 20006 Rohit Chopra, Director Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20220 Michael Hsu, Acting Comptroller Office of the Comptroller of the Currency 400 7th Street, SW Washington, DC Dear Acting Chairman

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