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Testimony & Regulatory Comments

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

NCRC comment on HUD’s AFFH interim final rule

(Download) Sasha Samberg-Champion Deputy General Counsel for Enforcement and Fair Housing Regulations Division, Office of General Counsel Department of Housing and Urban Development 451 7th Street SW, Room 10276 Washington, DC 20410-0500 July 12, 2021 Dear Mr. Samberg-Champion, Thank you for the opportunity to submit comments regarding the Department of Housing and Urban Development (HUD)’s interim […]

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Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning

(Download) July 1, 2021  Office of the Comptroller of the Currency: Docket ID OCC-2020-0049Board of Governors of the Federal Reserve System: Docket No. OP- 1743Federal Deposit Insurance Corporation: RIN 3064-ZA24Consumer Financial Protection Bureau: Docket No. CFPB-2021-0004National Credit Union Administration: Docket No. NCUA-2021-0023 RE: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence,

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Statement on Request for Guidance on Implementation of Disparate Impact Rules under ECOA

A proposal by National Community Reinvestment Coalition’s Innovation Council for Financial Inclusion. Preventing discrimination in the use of algorithms and predictive models is crucial for a fair financial system in the digital age. As a group of both consumer advocates and financial services companies, we have found a shared interest in encouraging a fair lending

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Support for the Greater Supervision in Banking Act (H.R. 3948)

June 22, 2021 The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for

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Support the Fair Lending for All Act (H.R. 166)

(Download) The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for H.R. 166,

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NCRC Summary of the Section 203, Strengthening the Community Reinvestment Act of 1977, of the American Housing and Economic Mobility Act of 2021 (S. 1368, H.R. 2768)

Although the Community Reinvestment Act (CRA) and other fair lending laws have increased lending and investment in traditionally underserved communities, stubborn and persistent lending disparities by race and income remain. CRA needs an update and its coverage of the financial industry must be expanded. The overall objective of Section 203 is to increase lending, investments

NCRC Summary of the Section 203, Strengthening the Community Reinvestment Act of 1977, of the American Housing and Economic Mobility Act of 2021 (S. 1368, H.R. 2768) Read More »

Ncrc opposes the deposit insurance application of Payservices, Inc. for failing to include a CRA plan

April 8th, 2021 John Henrie Regional Director Federal Deposit Insurance Corporation 10 10th Street, NE Suite 800 Atlanta, GA 30309-3849 RE: Application for Deposit Insurance (New Bank) from PayServices, Inc. Dear Mr. Henrie: Please kindly accept our comment on the application from PayServices, Inc. (Delray Beach, Florida) for deposit insurance. PayServices failed to include a

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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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