Opportunity Finance Network, February 10, 2020: Weigh in on the future of the Community Reinvestment Act
OFN has concluded that the performance evaluation framework outlined in the NPRM would weaken the banking industry’s requirements to serve low-wealth markets in significant ways. By relying heavily on a dollar-volume ratio to determine a bank’s CRA rating, the proposed changes could result in banks making fewer mortgage and small business loans in low- and moderate-income (LMI) communities, as well as less financing for critical community development activities. This flaw in the performance evaluation design is so fundamental that it outweighs any other positive changes included in the NPRM.
OFN has not arrived at this conclusion without careful study and extensive consultation with CDFI leaders, allies and bank partners. Whether you incorporate OFN’s recommendations into your comment letter or submit different views, please make your voice heard by the March 9 deadline.