Testimony & Regulatory Comments

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

NCRC urges support for the Fair Lending for All Act (HR166), recommends strengthening enforcement to prevent lending discrimination

(Download) February 26, 2021 The Honorable Al Green Chair Committee on Financial Services Subcommittee on Oversight and Investigations United States House of Representatives Washington, DC 20515 The Honorable Andy Barr Ranking Member Committee on Financial Services Subcommittee on Oversight and Investigations United States House of Representatives Washington, DC 20515 Dear Chairman Green, Ranking Member Barr […]

NCRC urges support for the Fair Lending for All Act (HR166), recommends strengthening enforcement to prevent lending discrimination Read More »

NCRC, consumer and community groups urge FDIC to deny insurance application for Rakuten ILC

February 19th, 2021 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Kathy L. Moe Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square Suite 2300 San Francisco, CA 94105-2780 RE: Comment Letter Regarding Deposit Insurance Application from Rakuten Bank America Dear Director Moe: The National Community Reinvestment Coalition (NCRC)

NCRC, consumer and community groups urge FDIC to deny insurance application for Rakuten ILC Read More »

NCRC comment on Federal Reserve Board’s Advance Notice of Proposed Rulemaking regarding the Community Reinvestment Act – February 2021

DOWNLOAD FULL COMMENT Overview and introduction Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the thoughtfulness of the Federal Reserve Board’s (Board) approach to modernizing the regulations implementing the Community Reinvestment Act (CRA). NCRC is an association of community-based organizations whose mission is to

NCRC comment on Federal Reserve Board’s Advance Notice of Proposed Rulemaking regarding the Community Reinvestment Act – February 2021 Read More »

Over 100 groups call on Federal Reserve to Strengthen CRA

(Download) Docket Number R-1723 and RIN Number 7100-AF94 To Whom it May Concern: The Federal Reserve Board (Fed) must strengthen the rigor of CRA exams to promote recovery from the COVID-19 pandemic. The Fed has described approaches in its Advance Notice of Proposed Rulemaking (ANPR) on CRA that will make CRA exams more objective and

Over 100 groups call on Federal Reserve to Strengthen CRA Read More »

Civil Rights, Fair Lending And Consumer Rights Organizations Urge A More Race-Conscious CRA

(Download) February 16, 2021 Ann E. Misback, Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Ave. NW Washington, DC 20551 RE:  Docket Number R-1723 and RIN Number 7100-AF94 Dear Ms. Misback: In its October 2020 Advance Notice of Proposed Rulemaking (ANPR), the Federal Reserve Board (FRB) invited public comment on

Civil Rights, Fair Lending And Consumer Rights Organizations Urge A More Race-Conscious CRA Read More »

NCRC comment on OCC scoring methodology

(Download) February 2, 2021 RE: NCRC Comments on Docket ID OCC 2020–0025, Community Reinvestment Act regulations, methodology for determining thresholds on general performance standards To Whom it May Concern: The National Community Reinvestment Coalition, an association of community-based organizations dedicated to increasing lending and investing in underserved communities, opposes the Office of the Comptroller of

NCRC comment on OCC scoring methodology Read More »

CRA’s First Aid Kit: Tools and Resources for Hospitals, Health Systems and Medical Professionals to Support CRA Modernization

Access to housing, jobs, transportation, education, healthy food and recreation are the building blocks for a healthy community, outside of clinical care. Working with banks to support those building blocks is supported by a robust CRA.

CRA’s First Aid Kit: Tools and Resources for Hospitals, Health Systems and Medical Professionals to Support CRA Modernization Read More »

Joint letter urging the incoming Biden Administration to include homeowner assistance in the proposed American Rescue Plan

(Download) January 16, 2021 Joe Biden President-Elect Wilmington, DE Dear President-Elect Biden, We appreciate your leadership on COVID relief and Thursday’s announcement of a comprehensive effort to provide an emergency legislative package. The proposal includes many crucial priorities to heal our nation from the COVID-19 pandemic, both medical and economic, including additional rental assistance. We

Joint letter urging the incoming Biden Administration to include homeowner assistance in the proposed American Rescue Plan Read More »

Joint Consumer-Industry Comments to Veterans Administrations Partial Claims Proposal

(Download) January 8, 2021 Stephanie Li Chief of Regulations Loan Guaranty Service, Veterans Benefits Administration, Department of Veterans Affairs 810 Vermont Avenue NW Washington, DC 20420 RE:      RIN 2900-AR05—Loan Guaranty: COVID-19 Veterans Assistance Partial Claim Payment Program To whom it may concern: On behalf of the clients, communities, and industries that we represent, we write

Joint Consumer-Industry Comments to Veterans Administrations Partial Claims Proposal Read More »

NCRC Files Comment Opposing Charter Application from GM Financial

(Download) online pharmacy buy zoloft no prescription pharmacy January 13, 2021 John Conneely Regional Director Federal Deposit Insurance Corporation 300 South Riverside Plaza, Suite 1700 Chicago, IL 60606-3447 RE: NCRC Comment Letter on GM Financial Bank Application Dear Director Conneelly: The National Community Reinvestment Coalition (NCRC) maintains that GM Financial Bank’s application for an Industrial

NCRC Files Comment Opposing Charter Application from GM Financial Read More »

NCRC Submits Comment on Oportun’s Application for a National Charter

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on Oportun’s application for a national bank charter. We request that the OCC extend the comment period for this application by 30 days to address numerous Community Reinvestment plan, loan pricing and debt collection practices raised by this application. Until these outstanding issues are addressed, we believe that the OCC does not have sufficient information to approve this application.

NCRC Submits Comment on Oportun’s Application for a National Charter Read More »

NCRC Comment Letter on the CFPB’s Outline of Proposals Under Consideration to Implement Small Business Lending Data Collection Requirements

(Download) December 14, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) outline of proposals under consideration

NCRC Comment Letter on the CFPB’s Outline of Proposals Under Consideration to Implement Small Business Lending Data Collection Requirements Read More »

Joint Comment Letter From NCRC And 49 Organizations On The CFPB’s Proposal To Implement Small Business Lending Data Collection Requirements

(Download) Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Comments on the CFPB Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (the Bureau) outline of proposals under consideration and alternatives

Joint Comment Letter From NCRC And 49 Organizations On The CFPB’s Proposal To Implement Small Business Lending Data Collection Requirements Read More »

CRA & Race: The Federal Reserve’s Proposal on the Community Reinvestment Act (CRA)

The board’s question invites a dialogue about whether and where the Federal Reserve’s framework might affirmatively consider race more explicitly. While we are not yet committing to support various aspects of the Federal Reserve’s proposed framework for CRA examinations, this paper is designed to explore where and whether regulators could insert race in a framework like this from a statutory and constitutional perspective.

CRA & Race: The Federal Reserve’s Proposal on the Community Reinvestment Act (CRA) Read More »

NCRC, CRL, and NCLC Send Comment Letter Opposing Figure’s Application for a National Bank Charter

(Download) December 7th, 2020 Mr. Louis Gittleman Director for District Licensing Western District Office 1225 17th Street, Suite 300 Denver, CO 80202 RE: Figure Bank, National Association: Charter application Dear Director Gittleman: Please accept this comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the

NCRC, CRL, and NCLC Send Comment Letter Opposing Figure’s Application for a National Bank Charter Read More »