LexBlog: The OCC’s CRA Final Rule Under a New Comptroller and the Biden Administration: What Now?

LexBlog, January 28, 2021, The OCC’s CRA Final Rule Under a New Comptroller and the Biden Administration: What Now?

The fate of the OCC’s Community Reinvestment Act (CRA) final rule, issued on May 20, 2020, hangs in the balance following the inauguration of President Biden on January 20 and the resignation of former Acting Comptroller Brian Brooks, who was a major proponent of the rule, on January 14.

Consumer advocates have uniformly and vigorously opposed the OCC’s CRA final rule, accusing the agency of acting hastily to “unlawfully gut[]” the CRA. On June 25, 2020, the National Community Reinvestment Coalition (“NCRC”) and California Reinvestment Coalition filed a lawsuit against the OCC, asking a federal district court to declare the OCC’s CRA final rule unlawful and set it aside. That lawsuit remains pending as of this writing.


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Redlining and Neighborhood Health

Before the pandemic devastated minority communities, banks and government officials starved them of capital.

Lower-income and minority neighborhoods that were intentionally cut off from lending and investment decades ago today suffer not only from reduced wealth and greater poverty, but from lower life expectancy and higher prevalence of chronic diseases that are risk factors for poor outcomes from COVID-19, a new study shows.

The new study, from the National Community Reinvestment Coalition (NCRC) with researchers from the University of Wisconsin–Milwaukee Joseph J. Zilber School of Public Health and the University of Richmond’s Digital Scholarship Lab, compared 1930’s maps of government-sanctioned lending discrimination zones with current census and public health data.

Table of Content

  • Executive Summary
  • Introduction
  • Redlining, the HOLC Maps and Segregation
  • Segregation, Public Health and COVID-19
  • Methods
  • Results
  • Discussion
  • Conclusion and Policy Recommendations
  • Citations
  • Appendix

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