More than 500 community-based groups send CRA reform letter to regulators

Today, 520 state and national community-based groups called on the three federal bank regulatory agencies that implement the Community Reinvestment Act (CRA) to not include a one-ratio metric in the upcoming proposed CRA rule change. 

In a letter written and submitted by the National Community Reinvestment Coalition (NCRC), the coalition of housing, consumer protection and community development organizations urged the Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation to drop the idea of a “one-ratio” metric from new CRA rules expected to be proposed by the agencies this fall.

“As we have stated in our comment letters regarding the Advance Notice of Proposed Rulemaking (ANPR), if a metric of this nature is determinative of the CRA rating either at the assessment area or overall, it will likely distort CRA activity in a way that is not responsive to local needs,” the letter said. “In order to boost the numerator of the ratio, banks will likely favor large dollar community development activity or purchases of mortgage-backed securities (MBS).”

“The one ratio also has the potential to interfere with sound business practices. If empirical benchmarks for passing ratings are set too high during economic downturns, banks could feel pressured to seek large deals when smaller loans or other financial assistance could better support communities and avoid over-leveraging banks. Different agency heads under various administrations could also adjust ratios that promote particular policies but do not take local credit needs into account.”

“A one ratio approach will make CRA exams less transparent and will deter public input. If the one ratio replaces existing metrics such as percent of loans to low- and moderate-income borrowers or communities, it will be harder for community organizations and members of the public to understand which needs banks are responding to and which ones they are neglecting.”

View the list of signers, read the full letter:


To request an interview with NCRC CEO Jesse Van Tol, contact:

Alyssa Wiltse-Ahmad

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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

Complete the form to download the full report: