The Regulatory Review, May 31, 2022, Increasing Access to Credit in Communities of Color
Research from the National Community Reinvestment Coalition and Relman Colfax PLLC provides an in-depth analysis of the constitutional authorities allowing federal regulators to embed race-conscious evaluations in CRA regulations. There are numerous ways in which the CRA can and should be updated to address racial discrimination in access to credit. For example, the CRA can incorporate an analysis by race when designating assessment areas and evaluating a bank’s responsiveness to local needs, just as it already requires an analysis by income.
