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Submit a CRA comment to the Federal Reserve

The deadline to submit comments to the Federal Reserve Board’s (Fed) Advance Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA) is fast approaching — Tuesday, February 16, at 11:59 pm

For instructions and NCRC’s sample comment letters, please visit:

www.ncrc.org/TreasureCRA 

Unlike the Office of the Comptroller of the Currency’s (OCC) CRA approach, NCRC believes the Fed’s approach is a good first step. However, especially now with the Biden Administration at the helm, we will be seeking more rigor in some of the performance measures to ensure that CRA ratings will not be as inflated as they are today. These changes are essential in ensuring that CRA exams leverage more lending, investing and services for communities of color and low- and moderate-income communities.

If you would like to comment, NCRC’s sample comment letters are on its #TreasureCRA page. On the page, under the “take action” tab, you will find both a long and a short version of the comment letter, which you can copy and edit as you see fit to submit to the Fed. You can find instructions on how to submit comments on the page as well. Please feel free to forward our sample comment letters and the link to our #TreasureCRA page to everyone in your network and encourage them to submit comments. 

If you have any questions about the comment letter or submitting a comment, feel free to contact Joe Reed at jreed@ncrc.org. 

If you are a hospital or health system interested in submitting a comment on CRA, learn more here: CRA’s First Aid Kit: Tools And Resources For Hospitals, Health Systems And Medical Professionals To Support CRA Modernization

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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: