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CRA reform

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

By / November 30, 2020 / Testimony & Regulatory Comments

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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How to Evaluate Community Development Financing and Services Under CRA

By / December 10, 2019 / Views

In anticipation of the reform proposals to the Community Reinvestment Act (CRA) expected this week, I am continuing the review of performance measures on CRA exams. The most recent blog looked at performance measures on the lending test. This one will scrutinize performance measures on the investment and service test. 

The importance of CRA assessment areas and bank branches

By / July 19, 2018 / Research

In 1977, Congress enacted the Community Reinvestment Act (CRA) and required federal bank agencies to assess the record of banks in meeting needs for credit and banking services in communities in which banks are chartered. The federal bank agencies responded by creating CRA examinations that assessed banks’ performance in geographical areas containing bank branches and …

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CityLab: How the Fair Housing Act failed black homeowners

By / April 13, 2018 / In the News

Fair-lending enforcement would not happen in earnest until years after the Fair Housing Act, not until the Community Reinvestment Act of 1977 required financial institutions go on record about what they considered their market area. The law intentionally created a conundrum for any institution that was redlining: How could it accept deposits from customers to whom it was unwilling to lend?

American Banker: 5 takeaways from Treasury’s call to action on CRA

By / April 4, 2018 / In the News

The report “addressed what we have for a long time talked about with assessment areas. We think that is a step in the right direction,” said John Taylor, President and CEO of NCRC. But Taylor wanted to make sure that regulators do not lose sight of the importance of branch locations if they expand the assessments to other areas.