NCRC’s Policy Director Testifies Before House on Disastrous CRA Reform Proposal

The Trump Administration’s banking regulators released a plan in December to upend the Community Reinvestment Act (CRA). Although released under the guise of being a modernization of the monumental civil rights legislation, Comptroller of the Currency Joseph Otting’s plan is a complete rewrite of the law.

The National Community Reinvestment Coalition (NCRC) is not the only one deeply concerned about the proposed changes. House Financial Services Committee’s Subcommittee on Consumer Protection and Financial Institutions is hosting a hearing today on who will be the winners and losers under the proposed changes.

NCRC’s Director of Policy and Government Affairs, Gerron Levi, was one of the witnesses testifying against the notice of proposed rulemaking. Levi focused her testimony on NCRC’s biggest concerns: the 60-day comment period is too short to properly assess and analyze all the changes; the proposal lacks data and impact analysis making a complete analysis of changes within the short comment period even more difficult; and that the proposed changes are substantial, dilutive and would weaken the effectiveness of the law.

“At the outset, we believe there have been critical missteps in the rulemaking process, including the 60-day length of the public comment period. The agencies must extend it. The OCC and FDIC should heed Chairwoman Maxine Waters and Ranking Member Sherrod Brown and the Members of this Committee and Senate Banking calling for and extension of the comment period,” Levi said. “The 240-page proposal is dense, complex and has many interlocking pieces – in terms of how all the new benchmarks, thresholds and definitions fit together. Neither the 60-day timeframe nor the information provided in the notice of proposed rulemaking (NPRM) offer a meaningful opportunity to comment.” 

To read NCRC’s full written testimony, visit:


To learn more about the proposed CRA changes and submit a comment to the OCC and the FDIC, visit:


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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: