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CRA & Race: The Federal Reserve’s Proposal on the Community Reinvestment Act (CRA)

The board’s question invites a dialogue about whether and where the Federal Reserve’s framework might affirmatively consider race more explicitly. While we are not yet committing to support various aspects of the Federal Reserve’s proposed framework for CRA examinations, this paper is designed to explore where and whether regulators could insert race in a framework like this from a statutory and constitutional perspective.

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NCRC, CRL, and NCLC Send Comment Letter Opposing Figure’s Application for a National Bank Charter

(Download) December 7th, 2020 Mr. Louis Gittleman Director for District Licensing Western District Office 1225 17th Street, Suite 300 Denver, CO 80202 RE: Figure Bank, National Association: Charter application Dear Director Gittleman: Please accept this comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the

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Natasha Sim

Compliance and Regulatory Counsel nsim@ncrc.org 202-792-1282 Natasha Sim is Compliance and Regulatory Counsel at the National Community Reinvestment Coalition (NCRC). Since joining NCRC in late 2020, Natasha has led the implementation of a multi-million-dollar lending program and managed the development of an affordable housing initiative aiming to produce 20 million homes by 2030. Natasha has

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Soraya Otero

Special Assistant to the COO and Community Liaison sotero@ncrc.org 202-792-1283 Soraya Otero will be supporting NCRC’s COO Gregory Dyson as a Special Assistant, and support our Just Economy club as Community Liaison. Soraya brings outstanding organizational competencies, capacity building knowledge and practice, and great interpersonal skills backed by a robust career in operations and finance. She is focused towards institutional strategic goals.

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NCRC Comment on the CFPBs RFI on the Equal Credit Opportunity Act

(Download) December 1, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information on the Equal Credit Opportunity Act; Docket No. CFPB-2020-0026 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request For Information (RFI) on the Equal Credit

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Group sign-on letter on the CFPBs RFI on the Equal Credit Opportunity Act

(Download) Kathy Kraninger Director Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Dear Director Kraninger: The undersigned civil rights, community, and consumer organizations appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request for Information (RFI) on the Equal Credit Opportunity Act (ECOA), which “seeks comments and information

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NCRC statement on OCC’s Proposed CRA Thresholds

Yesterday, the Office of the Comptroller of the Currency (OCC) released a proposed rule for establishing the Community Reinvestment Act (CRA) evaluation measure thresholds, retail lending distribution test thresholds, and community development minimums under the general performance standards set forth in the agency’s 2020 final rule.

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Initial NCRC Analysis of OCC Proposal to Establish Thresholds for its New CRA Measures

The OCC has proposed yet another data collection effort to develop thresholds for its flawed 2020 Community Reinvestment Act final rule. This is another tacit admission by the OCC that  all along it has lacked the data and factual basis for developing its flawed revisions to CRA examination performance measures. Instead of creating more consistency

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