U.S. House of Representatives
Washington, DC 20515
On behalf of the undersigned organizations, we are writing to urge you to cosponsor and support H.J.Res. 90, a disapproval resolution that would overturn a poorly constructed rule change on the Community Reinvestment Act (CRA) hastily finalized in May, days before Comptroller Otting’s resignation from the agency, and published this month.
At the outset, it is critical to note that the Trump Administration is split on the CRA final rule. With a lack of interagency coordination among the nation’s bank regulators, different banks will be held to different reinvestment standards depending on their regulator – an outcome that both banks and advocates have cautioned against. Federal Reserve Chairman Jerome Powell testified just last week that he expects the agency to move forward with CRA updates intended to garner “broad support among the community of intended beneficiaries” something he considers to be “one non-negotiable condition for it.” The OCC’s final rule achieved no such support or consensus. The vast majority of public comments – about 90 percent – opposed the CRA evaluation measure and presumptive ratings framework that remains at the heart of the final rule, but the OCC adopted it anyway.
The OCC’s final rule makes a series of changes to the CRA regulatory framework that reduce incentives for banks to lend to low-and-moderate income(LMI) families and invest and serve LMI communities: home buyers and homeowners, small businesses, community development projects that primarily benefit and serve LMI people. It also expands the number of banks that will have no review of how they open and close bank branches and provide key bank services in LMI and underserved neighborhoods.
These harmful changes could not come at a worse time. The ongoing COVID-19 pandemic and widespread social unrest that is gripping the nation has hit LMI and communities of color the hardest and brought gapping disparities to the forefront. The changes to the CRA being pushed through by the OCC would do little to address the pressing national priorities of reducing the racial wealth gap, of better serving those traditionally underserved by the nation’s financial system or stimulating an economic recovery from COVID-19 that is equitable. While the OCC claims its aim is to increase CRA activity, the lack of interagency agreement among this Administration’s regulators should serve as a dire warning about that claim. We do not yet know the full impact of COVID-19 on local mortgage markets, small business resiliency, or how LMI households, neighborhoods, local jobs, and key sectors will recover. Weakening CRA at this moment is a blueprint for a crisis after the crisis.
For all these reasons and more, we urge you to cosponsor H.J.Res. 90 and support it when it is considered on the House floor.
National Community Reinvestment Coalition (NCRC)
Americans for Financial Reform
Center for Community Progress
Local Initiatives Support Corporation (LISC)
National Association for Latino Community Asset Builders (NALCAB)
National Housing Resource Center
National Housing Trust
National NeighborWorks Association
National Urban League
The Leadership Conference on Civil and Human Rights
Titusville Development Corporation
Arizona Housing Coalition
Local First Arizona
Local First Arizona Foundation
California Coalition for Rural Housing
California Reinvestment Coalition
California Resources and Training
CDC Small Business Finance
Grounded Solutions Network
High Impact Financial Analysis, LLC
Peoples’ Self-Help Housing
The Greenlining Institute
Urban Land Conservancy
Neighborhood Housing Services of Waterbury
District of Columbia
Africa Diaspora Directorate
Delaware Community Reinvestment Action Council, Inc.
Edgemoor Revitalization Cooperative, Inc.
The Ministry of Caring Inc.
Affordable Homeownership Foundation, Inc.
Community Reinvestment Alliance of South Florida
Goldenrule Housing & Community Development Corp Inc
Metro North Community Development Corp.
Hawai’i Alliance for Community-Based Economic Development
Accion Serving Illinois & Indiana
Chicago Community Loan Fund
Chicago Rehab Network
Housing Action Illinois
NW HomeStart, Inc
Continuum of Care Network NWI, Inc.
River City Housing
Multi-Cultural Development Center
Greater Boston Legal Services
Massachusetts Affordable Housing Alliance
African American Chamber of Commerce of Montgomery County
Maryland Consumer Rights Coalition
Maryland Consumer Rights Coalition
Residential Housing Counseling Agency
Coastal Enterprises, Inc.
Fair Housing Center of Metropolitan Detroit
Habitat for Humanity of Michigan
Southwest Economic Solutions
Metropolitan St. Louis Equal Housing and Opportunity Council
Hope Enterprise Corporation
Montgomery Citizens United for Prosperity (MCUP)
Montana Fair Housing, Inc.
NCRC Housing Rehab Fund, LLC
New Jersey Association on Correction
New Jersey Citizen Action
New Jersey Community Capital
Southwest Neighborhood Housing Services
Association for Neighborhood and Housing Development (ANHD)
Banana Kelly Community Improvement Association
Beaulac Associates LLC
BOC Capital Corp. CDFI
Business Outreach Center Network
Center for NYC Neighborhoods
Chhaya Community Development Corporation
Community Capital New York
Community Development Venture Capital Alliance
CNY Fair Housing, Inc.
Community Loan Fund of the Capital Region, Inc.
Cypress Hills Local Development Corporation
Fair Finance Watch
Fidelis Federal Credit Union
Fifth Avenue Committee
Genesee Co-op FCU
Greater Jamaica Development Corporation
Habitat for Humanity New York City
Habitat NYC Community Fund
La Fuerza CDC
Neighbors Helping Neighbors
NYS CDFI Coalition
Oswego County Federal Credit Union
PathStone Enterprise Center, Inc.
Renaissance Economic Development Corp.
The Knowledge House
Three Jewels Outreach Center
University Neighborhood Housing Program
Cleveland Neighborhood Progress
Columbus Compact dba Columbus Empowerment Corp.
Homes on the Hill, CDC
Ohio CDC Association
The Fair Housing Center for Rights & Research
Working In Neighborhoods
Amani Christian Community Development
Beltzhoover Consensus Group
Berks Latino Workforce Development Corporation (BLWDC)
Chester Community Improvement Project
Fair Housing Rights Center in Southeastern Pennsylvania
Good Bricks Ventures LLC
Jave Jive Coffee LLC
Mount Washington Community Development Corporation
Northside Leadership Conference
PHDA Pittsburgh Housing Development Association, Inc
Philadelphia Association of Community Development Corporations
Pittsburgh Community Reinvestment Group
Rising Tide Partners
The Enterprise Center
Tube City Renaissance
Wilkinsburg Community Development Corporation
Our Casas Resident Council INC.
Southern Dallas Progress Community Development Corporation
Rocky Mountain Community Reinvestment Corporation
Low Income Housing Institute
Citizen Action of Wisconsin
Metropolitan Milwaukee Fair Housing Council
Movin’ Out, Inc.
United Community Center
Urban Economic Development Association of Wisconsin (UEDA)
Washington Park Housing Comm
YWCA Southeast Wisconsin
“Although commenters disagreed with the approach outlined in the proposal, the agency ultimately agreed with the minority of commenters who expressed support for the proposed framework. OCC Final Rule, p. 18 or p. 34738. See also, Statement by FDIC Chairman Jelena McWilliams on the CRA Joint Proposed Rulemaking, May 20, 2020.