NCRC Submits FOIA Request for Missing Data in CRA Proposed Rule

Today, the National Community Reinvestment Coalition (NCRC) submitted a Freedom of Information Act (FOIA) request to the Office of the Comptroller of the Currency (OCC) for records related to the agency’s plan to revise Community Reinvestment Act (CRA) rules.

The agency’s notice of proposed rulemaking (NPRM) was announced in December and published on January 9 by the OCC and the Federal Insurance Deposit Corporation (FDIC). The NCRC FOIA request seeks the public release of data referenced but not provided in the NPRM, including undisclosed data from a sample of over 200 exams for banks from which the agencies extrapolated critical thresholds on which CRA performance evaluations are proposed to be made. That includes all records containing an analysis or explanation for the selection of the sample of performance evaluations completed and all records and reports containing information about benchmarks used for the CRA performance measures. all records containing an analysis of or information about the threshold concept regarding a bank receiving a satisfactory or an outstanding presumptive bank-level rating if it receives that rating in “just more than 50 percent of its assessment areas, and in those areas where it holds a significant amount of deposits.” NCRC is also seeking records containing an analysis of or information about the proposal that affordable housing can be defined as housing for middle-income households.

“This data should have been included in the proposal to back up the claims being made by the federal regulators about the anticipated impact of the rule changes,” said Alice Bodley, NCRC’s Chief Operating Officer and General Counsel. “We can not fully analyze the proposal and what effects it will have on low- and moderate-income communities without this data. We don’t know why the foundational information was kept out of the proposal, but the public should be able to review it before the agencies move ahead with major changes to the law.”

NCRC’s Director of Policy and Government Affairs, Gerron Levi, is scheduled to testify today at a hearing on the proposed rule changes with the House Financial Services’ Subcommittee on Consumer Protection and Financial Institutions. Her testimony will note the missing data and urge the OCC and FDIC to extend the 60-day public comment period on the proposal.

“The public needs adequate time to analyze the data once the FOIA request has been fulfilled,” Bodley said.

To request an interview with NCRC COO Alice Bodley, 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

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