Today, a coalition of housing, consumer protection and community development organizations called on the three federal bank regulatory agencies that govern the Community Reinvestment Act (CRA) to issue uniform CRA regulations in an anticipated Notice of Proposed Rulemaking (NPR) — and ensure any metrics for CRA activities are focused on addressing community needs, not simply the dollar volume of bank activities.
In a letter from the National Community Reinvestment Coalition and 27 other organizations, the coalition urged the Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation to not twist a desire for greater clarity and consistency into a dollar volume metric that would not be meaningful for local communities.
“There is broad agreement that well-designed metrics can provide greater clarity, consistency and transparency for banks and be impactful for LMI borrowers and communities,” the letter said. “Enhancing benchmarks within component tests can provide greater clarity for banks in a way that is also meaningful for communities.”
“However, we would have serious concerns about a metrics framework based primarily on a ratio of the aggregate dollar volume of a bank’s CRA balance sheet to the bank’s deposit or asset base, whether at the assessment area level or institution-wide, that would drive a presumptive CRA rating.”
Read the full letter: