NCRC submits comment supporting OCC’s full rescission of disastrous 2020 CRA rule

The National Community Reinvestment Coalition (NCRC) today submitted a comment letter to the Office of the Comptroller of the Currency (OCC) strongly supporting the OCC’s proposed rescission of its disastrous 2020 Community Reinvestment Act (CRA) rule. In the comment letter, NCRC also urged the OCC to quickly join with the Federal Reserve and the Federal Insurance Deposit Corporation (FDIC) to embark on a genuine interagency rule.

108 state and local groups signed on to NCRC’s comment.

The comment provided a detailed summary of the main reasons why the OCC’s 2020 CRA rule must be fully rescinded. For example, NCRC determined that the 2020 rule would violate the statutory purpose of CRA by diverting banks from lending and investing in formerly redlined communities. It did this by diluting CRA’s focus on low- and moderate-income (LMI) communities and expanding what activities, such as large infrastructure with partial benefits for LMI communities, qualified for CRA credit. 

The 2020 rule also would have minimized the value of public participation, eliminated the service test for large banks and substantially diminished the incentives of banks to respond to the needs of their assessment areas.

“While we appreciate the OCC providing an opportunity to submit comments, it is now the time to fully rescind the 2020 CRA rule, and to start over with the FDIC and the Fed to establish a true interagency rule that modernizes and strengthens CRA for today and the future,” said Jesse Van Tol, President and CEO of NCRC. 

Quickly repealing the 2020 rule would allow the agencies to embark on a genuine interagency process which would tackle critical issues such as improving the availability of data on CRA performance, reforming assessment areas to consider lending beyond bank branches, bolstering the rigor of CRA evaluations and ratings, and explicitly considering race in CRA exams along the lines suggested in a recent NCRC white paper.

The comment also addresses transition rules for when the 2020 rule is fully rescinded and before a joint interagency rule has been developed. The OCC should apply the same rules to the banks that it regulates that FDIC- and Fed-regulated banks are currently following. 

To read NCRC’s full comment letter, visit: https://ncrc.org/ncrc-comment-letter-on-occ-proposal-to-rescind-its-harmful-cra-final-2020-rule/

Organizations In Support



Americans for Financial Reform Education Fund

Center for Responsible Lending

Consumer Action

National Association for Latino Community Asset Builders

National CAPACD- National Coalition for Asian Pacific American Community Development

National Consumer Law Center (on behalf of its low-income clients)

National Fair Housing Alliance

National NeighborWorks Association

Prosperity Now

Public Citizen

U.S. Conference of Mayors


Birmingham Business Resource Center

Building Alabama Reinvestment


Arizona Partnership for Healthy Communities

Chicanos Por La Causa

Local First Arizona


Pima County Community Land Trust


Wildfire: Igniting Community Action to End Poverty in Arizona


Black Cultural Zone Community Development Corporation

California Coalition for Rural Housing

California Reinvestment Coalition

Ephesians Community Development Center

Housing on Merit

Peoples Opportunity Fund

Rural Community Assistance Corporation

District Of Columbia

Autistic Self Advocacy Network

Better Markets

Coalition for Non Profit Housing and Economic Development

Committee for Better Banks

Latino Economic Development Center

Poverty and Race Research Action Council


Affordable Homeownership Foundation

African American Alliance of CDFI CEOs Inc.

Catalyst Miami

Community Reinvestment Alliance of South Florida

Florida Housing Coalition

Metro North Community Development Corp


Beyond $avvy Corporation

Georgia Advancing Communities Together, Inc.

Neighborhood Improvement Association


Hawai’i Alliance for Community-Based Economic Development


Chicago Community Loan Fund

Housing Action Illinois

Illinois People’s Action

Universal Housing Solutions CDC

Woodstock Institute


Fair Housing Center of Central Indiana


Northwest Indiana Reinvestment Alliance

Prosperity Indiana

South Bend Heritage Foundation


River Cities Development Services



River City Housing, Inc.




Jane Place Neighborhood Sustainability Initiative

Multi-Cultural Development Center

NewCorp, Inc



Massachusetts Affordable Housing Alliance



Maryland Consumer Rights Coalition

Project  PLASE, Inc.


New Hope Community Development

Southwest Economic Solutions


Community Reinvestment Fund, USA


Metropolitan St. Louis Equal Housing and Opportunity Council



MS Communities United for Prosperity (MCUP)


Montana Fair Housing

New Jersey

New Jersey Citizen Action

New York

Association for Neighborhood and Housing Development (ANHD)

Devotion USA

Empire Justice Center

Fair Finance Watch

Long Island Housing Services, Inc.

North Carolina

NC Housing Coalition, Inc.

Reinvestment Partners

Welfare Reform Liaison Project, Inc.


Friends of the African Union


Mustard Seed Development Center

Ohio CDC Association

Working In Neighborhoods


CASA of Oregon

Housing Oregon



Chester Community Improvement Project

National Housing Resource Center

Pittsburgh Community Reinvestment Group

Rhode Island

HousingWorks RI


Southern Dallas Progress Community Development Corporation

TCH Development, Inc


Clarke Square Neighborhood Initiative Inc.

CR-Social Development Commission

Housing Resources, Inc.

Inner City Redevelopment Corp

Metropolitan Milwaukee Fair Housing Council

Milwaukee Christian Center

Milwaukee Community Land Trust


Prism Economic Development Corporation

Southside Organizing Committee

Urban Economic Development Association of Wisconsin, Inc.

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