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The comment provided a detailed summary of the main reasons why the OCC’s 2020 CRA rule must be fully rescinded.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The comment also addresses transition rules for when the 2020 rule is fully rescinded and before a joint interagency rule has been developed.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

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.

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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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