More Than 500 Community Organizations Urge FDIC To Not Join Flawed Notice of Proposed Rulemaking for Community Reinvestment Act

Today, 516 state and national community-based organizations urged the Federal Deposit Insurance Corporation’s (FDIC) Board of Directors to not join the Office of the Comptroller of the Currency’s (OCC) notice of proposed rulemaking (NPR) for the Community Reinvestment Act (CRA).

In a letter written and submitted by the National Community Reinvestment Coalition (NCRC), the coalition of housing, consumer protection and community development organizations referred to the OCC’s approach as “flawed” and asked the FDIC to be more involved in bringing all three CRA regulatory agencies together for a unified approach. The Federal Reserve has made it clear that it will not be involved in this NPR.

“For almost its entire 40-year history, the Community Reinvestment Act (CRA) has resulted in interagency consensus among the prudential regulators.  We are very concerned that OCC’s regulatory framework, and specifically its’ insistence on a dollar volume metric, expanding what is CRA qualifying and other changes that could dilute the power of the law for low- and moderate-income (LMI) communities, has fractured the consensus among prudential regulators on how best to implement a law so vital to lending, investments and financial services, including bank branches, in LMI communities.”

“At this stage in the rulemaking process, we would urge the FDIC Board to play a more constructive and instrumental role in bringing the regulators together around a unified approach…The FDIC should not join a flawed OCC-led approach that will weaken CRA obligations for the nation’s largest financial institutions.  We urge the FDIC Board not to join the notice of proposed rulemaking at this time, and wait until the public has an opportunity to fully vet the OCC’s framework.”

The groups are also calling on the OCC to elongate the comment period from 60 days to at least 120 days due to the complexity of the regulatory changes as well as having much of the comment period fall during the holiday season.


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: