NCRC statement on OCC’s Proposed CRA Thresholds

Yesterday, the Office of the Comptroller of the Currency (OCC) released a proposed rule for establishing the Community Reinvestment Act (CRA) evaluation measure thresholds, retail lending distribution test thresholds, and community development minimums under the general performance standards set forth in the agency’s 2020 final rule. Rather than proposing the promised thresholds, the OCC is instead launching a data collection effort to obtain the very data that should have been the basis of its final rule.

Jesse Van Tol, CEO of the National Community Reinvestment Coalition, made the following statement:

“When the OCC pushed through its final CRA rule back in May, it did so during a pandemic and economic downturn with little to no community and bank support. At that time, the OCC promised additional data and analysis would be coming in the form of another proposed rule for CRA benchmarks and thresholds. But what it released yesterday contained neither of those things. 

“Once again the OCC has shown that it lacks the data and factual basis for making its CRA final rule revisions. We have sought this data numerous times through FOIA requests, but the OCC has not produced adequate data to be able to properly evaluate the impact of its final rule. From our review, the final rule will decrease retail lending, investing and bank services in underserved communities – the exact opposite of what we need right now to rebuild and recover from the pandemic. It will make it easier for banks to pass, while actually doing less for their communities.

“Continuing to push through its disastrous and unsubstantiated rule changes is irresponsible. With a 60-day comment period, this is a lame duck proposed rule. We will call on the incoming Biden Administration to withdraw this proposed rule, rescind the 2020 CRA final rule and commit to an interagency rulemaking using the Federal Reserve Board proposal released earlier this year as a starting point.”

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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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