“The OCC’s approach to this has been to barrel in without building consensus first on how to proceed,” said Jesse Van Tol, CEO of the National Community Reinvestment Coalition. He raised the possibility that the FDIC’s support could be contingent on some kind of carve-out for smaller banks. “It will be telling if the FDIC signs on with a clause to let their banks opt out. Talk about a vote of confidence.”

Last year, the National Community Reinvestment Coalition released a report showing that neighborhoods singled out as hazardous by redlining are much more likely to struggle today than those that were not on the list.