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The comment provided a detailed summary of the main reasons why the OCC’s 2020 CRA rule must be fully rescinded.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The comment also addresses transition rules for when the 2020 rule is fully rescinded and before a joint interagency rule has been developed.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
National
AFL-CIO
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
Alabama
Birmingham Business Resource Center
Building Alabama Reinvestment
Arizona
Arizona Partnership for Healthy Communities
Chicanos Por La Causa
Local First Arizona
LULAC
Pima County Community Land Trust
Trellis
Wildfire: Igniting Community Action to End Poverty in Arizona
California
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
Florida
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
Georgia
Beyond $avvy Corporation
Georgia Advancing Communities Together, Inc.
Neighborhood Improvement Association
Hawaii
Hawai’i Alliance for Community-Based Economic Development
Illinois
Chicago Community Loan Fund
Housing Action Illinois
Illinois People’s Action
Universal Housing Solutions CDC
Woodstock Institute
Indiana
Fair Housing Center of Central Indiana
HomesteadCS
Northwest Indiana Reinvestment Alliance
Prosperity Indiana
South Bend Heritage Foundation
Iowa
River Cities Development Services
Kentucky
REBOUND, Inc.
River City Housing, Inc.
Louisiana
HousingLOUISIANA
HousingNOLA
Jane Place Neighborhood Sustainability Initiative
Multi-Cultural Development Center
NewCorp, Inc
Massachusetts
Ceres
Massachusetts Affordable Housing Alliance
Maryland
CCCSMD
Maryland Consumer Rights Coalition
Project PLASE, Inc.
Michigan
New Hope Community Development
Southwest Economic Solutions
Minnesota
Community Reinvestment Fund, USA
Missouri
Metropolitan St. Louis Equal Housing and Opportunity Council
Mississippi
HEED
MS Communities United for Prosperity (MCUP)
Montana
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.
Ohio
Friends of the African Union
JOVIS
Mustard Seed Development Center
Ohio CDC Association
Working In Neighborhoods
Oregon
CASA of Oregon
Housing Oregon
Pennsylvania
Ceiba
Chester Community Improvement Project
National Housing Resource Center
Pittsburgh Community Reinvestment Group
Rhode Island
HousingWorks RI
Texas
Southern Dallas Progress Community Development Corporation
TCH Development, Inc
Wisconsin
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
NAACP
Prism Economic Development Corporation
Southside Organizing Committee
Urban Economic Development Association of Wisconsin, Inc.
