NCRC Submits Letter to FDIC, OCC, Federal Reserve Supporting FDIC’s action to review bank merger approval framework

The National Community Reinvestment Coalition (NCRC) today submitted a letter to the Federal Deposit Insurance Corporation (FDIC) to express support from its members to introduce a Request for Comments to review the agency’s bank merger approval framework, and called on the Office of the Comptroller of the Currency and the Federal Reserve Board to do the same.

102 state and local NCRC member groups signed on to NCRC’s letter.

Banking mergers are happening at a rapid pace. In 1984, there were 18,000 insured depository institutions. By 2021, there were slightly fewer than 5,000 independent banks. Regulators have not formally denied a merger application since 2003

Under the Bank Merger Act, Congress required the federal banking regulators to consider public interest when approving mergers. However, the evidence would suggest that most mergers result in net losses for communities, higher interest rates for borrowers, less retail lending, and reduced rates of interest paid on savings accounts. Research suggests that when a bank is acquired, its existing customers have a more difficult time to qualify for a loan.   

Local branches are also often closed after a merger, taking with them the relationship-based lending that they often do. And banking deserts are on the rise too.

“The request for public comments on bank mergers is a great first step, and the FDIC should now move forward and publish the request to ensure that NCRC, its members and the communities we serve have the opportunity to comment on the effects of bank mergers,” said NCRC President and CEO Jesse Van Tol. “The OCC and the Federal Reserve should also implement similar merger review actions right away.”

To read NCRC’s full letter, visit: 


Members who signed on

Access Plus Capital (Fresno, California)

Affordable Homeownership Foundation, Inc. (Fort Myers, Florida)

African American Trade Association (Denver, Colorado)

American GI Forum (San Antonio, Texas)

Atlanta Neighborhood Development Partnership, Inc. (Atlanta, Georgia)

Asian Business Association (Los Angeles, California)

Asian Business Association of Silicon Valley (Fremont, California)

Association for Neighborhood and Housing Development (New York, New York)

Beyond $avvy Consumers (Douglassville, Georgia)

Birmingham Business Resource Center (Birmingham, Alabama)

Black Cultural Zone Community Development Corporation (Oakland, California)

BLDG Memphis (Memphis, Tennessee)

Building Alabama Reinvestment (Birmingham, Alabama)

Consumer Advocates Against Reverse Mortgage Abuse (CAARMA)

California Coalition for Rural Housing (Sacramento, California)

California Reinvestment Coalition (San Francisco, California)
CAMEO: The California Microenterprise Network (San Francisco, California)

CASA of Oregon (Sherwood, Oregon)

Ceiba (Philadelphia, Pennsylvania)

Center for LGBTQ Economic Advancement & Research (San Francisco, California)

Central Islip Civic Council, Inc. (Central Islip, New York)

CHES, Inc. (Kansas City, Missouri)

Chicago Community Loan Fund (Chicago, Illinois)

Chicago Rehab Network (Chicago, Illinois)

Chicanos Por La Causa (Phoenix, Arizona)

Chicanos Por La Causa Texas (Houston, Texas)

City of Jackson (Jackson, Mississippi)

Coalition for Non-Profit Housing and Economic Development (Washington, DC)

Community Link (Charlotte, North Carolina)

Community Reinvestment Alliance of South Florida (Miami, Florida)

Community Service Network (Stoneham, Massachusetts) 

Community Service Programs of West Alabama, Inc. (Tuscaloosa, Alabama)

Consumers Council of Missouri (St. Louis, Missouri)

Cornerstone West CDC (Wilmington, Delaware)

Corporation for Supportive Housing (New York, New York)

Delaware Community Reinvestment Action Council, Inc. (Wilmington, Delaware)

EAH Housing (California and Hawai’i)

Fair Finance Watch (Bronx, New York)

Fair Housing Center of Central Indiana, Inc. (Indianapolis, Indiana)

Fair Housing Contact Service Inc. (Akron, Ohio)

Florida Housing Counselor Network (Tallahassee, Florida)

Georgia Advancing Communities Together, Inc. (Atlanta, Georgia)

Greater Cincinnati Microenterprise Initiative (Cincinnati, Ohio)

Greater New Orleans Housing Alliance (New Orleans, Louisiana)

Hawai’i Alliance for Community-Based Economic Development (Honolulu, Hawai’i)

Homes on the Hill Community Development Corporation (Columbus, Ohio) 

HomesteadCS (Lafayette, Indiana)

Housing Action Illinois (Chicago, Illinois)

Housing Education and Economic Development (Jackson, Mississippi)

Housing Justice Center (St. Paul, Minnesota) 

Housing Options & Planning Enterprises, Inc. (Ox Hill, Maryland)

Housing Louisiana (New Orleans, Louisiana)

HousingNOLA (New Orleans, Louisiana)

Jewish Community Action (St. Paul, Minnesota)


Legacy Foundation (Crown Point, Indiana)

Lewis Associates (Lansing, Michigan)

Long Island Housing Services, Inc. (Bohemia, New York)

Manna, Inc. (Washington, DC)

Maryland Consumer Rights Coalition (Baltimore, Maryland)

Massachusetts Affordable Housing Alliance (Boston, Massachusetts) 

Metropolitan Consortium of Community Developers (Minneapolis, Minnesota)

Metropolitan Milwaukee Fair Housing Council (Milwaukee, Wisconsin)

Metropolitan St. Louis Equal Housing and Opportunity Council (St. Louis, Missouri)

Michigan Oncology Quality Consortium (Ann Arbor, Michigan)

Montana Fair Housing (Butte, Montana)

Multicultural Development Center (Bossier City, Louisiana)

Mustard Seed Development (Cleveland, Ohio)

MY Project USA (Columbus, Ohio)

National Association of American Veterans, Inc. (Washington, DC)

National NeighborWorks Association (Washington, DC)

Neighborhood Improvement Association (Savannah, Georgia)

New Jersey Citizen Action (Newark, New Jersey)

Northwest Indiana Reinvestment Alliance (Hammond, Indiana)

Ohio CDC Association (Columbus, Ohio)

Olive Hill Community Economic Development Corporation, Inc. (Morganton, North Carolina)

People’s Self-Help Housing (San Luis Obispo, California)

Philadelphia Association of Community Development Corporations (Philadelphia, Pennsylvania)

Piedmont Business Capital (Greensboro, North Carolina)

Piedmont Housing Alliance (Charlottesville, Virginia)

Pima County Community Land Trust (Tucson, Arizona)

Pittsburgh Community Reinvestment Group (Pittsburgh, Pennsylvania)

Prosperity Indiana (Indianapolis, Indiana)

Proud Ground (Portland, Oregon)

R.A.A. – Ready, Aim, Advocate (St. Louis, Missouri)

River Cities Development Services (Davenport, Iowa)

River City Housing, Inc. (Louisville, Kentucky)

Roosevelt Southwest Community Dev Corp (Birmingham, Alabama)

Sandhills Community Action Program, Inc. (Southern Pines, North Carolina)

South Bend Heritage Foundation (South Bend, Indiana)

Southern California Black Chamber of Commerce (Palm Springs, California)

Southern Dallas Progress Community Development Corporation (Dallas, Texas)

Southwest Community Development Corporation (Philadelphia, Pennsylvania)

Springfield NHS (Springfield, Massachusetts) 

TCH Development, Inc (Houston, Texas)

The Greenlining Institute (Oakland, California)

Titusville Development Corporation (Birmingham, Alabama)

U SNAP BAC INC (Detroit, Michigan)

Urban Coalition of Appraisal Professionals

Woodstock Institute (Chicago, Illinois)

Working In Neighborhoods (Cincinnati, Ohio)

You Always COUNT Ministries (Cincinnati, Ohio)

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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

Complete the form to download the full report: