| Document Title | Submitted ANPR Comment? | Submitted NPRM Comment? | Passed Resolution? | Signed USCM ANPR Letter? | Signed USCM NPRM Letter? | ANPR Statement? | NPRM Statement? | Final Rule Statement? |
|---|---|---|---|---|---|---|---|---|
| City and County of San Francisco, CA | None | Yes | No | No | No | No | No | No |
| City Milwaukee ,WI | Yes | None | Yes | No | No | No | No | No |
| City of Akron, OH | None | Yes | No | No | No | No | No | No |
| City of Albuquerque, NM | None | None | No | No | Yes | No | No | No |
| City of Alexandria, VA | None | None | No | Yes | Yes | No | No | No |
| City of Allentown PA | None | Yes | No | No | No | No | No | No |
| City of Atlanta, GA | None | None | No | No | Yes | No | No | No |
| City of Augusta, GA | None | None | No | Yes | No | No | No | No |
| City of Austin, Texas | Yes | Yes | No | Yes | Yes | No | No | No |
| City of Baltimore, MD | None | None | Yes | No | Yes | No | No | No |
| City of Baton Rouge, LA | None | None | No | Yes | No | No | No | No |
| City of Beaverton, OR | None | None | No | No | Yes | No | No | No |
| City of Berkeley, CA | None | None | No | No | Yes | No | No | No |
| City of Bethlehem | Yes | Yes | No | Yes | Yes | No | No | No |
| City of Binghamton, NY | None | None | No | No | Yes | No | No | No |
| City of Boston, MA | None | None | Yes | No | Yes | No | No | No |
| City of Boulder, CO | None | None | No | No | Yes | No | No | No |
| City of Brownsville, TX | None | None | No | Yes | Yes | No | No | No |
| City of Burnsville, MN | None | None | No | Yes | No | No | No | No |
| City of Cape Coral, FL | None | None | No | No | Yes | No | No | No |
| City of Central Falls, RI | None | None | No | Yes | No | No | No | No |
| City of Charlotte, NC | None | None | No | Yes | No | No | No | No |
| City of Chattanooga, TN | None | None | No | No | Yes | No | No | No |
| City of Chicago,IL | None | Yes | No | No | Yes | No | Yes | Yes |
| City of Chula Vista, CA | None | None | No | Yes | Yes | No | No | No |
| City of Cincinnati,OH | None | Yes | No | No | Yes | No | No | No |
| City of Clarksville, TN | None | None | No | Yes | No | No | No | No |
| City of Cleveland Heights, OH | Yes | None | No | No | No | No | No | No |
| City of Cleveland, OH | Yes | Yes | No | No | No | No | No | No |
| City of College Park, MD | None | None | No | Yes | Yes | No | No | No |
| City of College Station, TX | None | None | No | Yes | No | No | No | No |
| City of Columbia, SC | None | None | No | Yes | Yes | No | No | No |
| City of Columbus, OH | None | None | No | No | Yes | No | No | No |
| City of Corvallis, OR | None | None | No | Yes | No | No | No | No |
| City of Costa Mesa, CA | None | None | No | No | Yes | No | No | No |
| City of Dallas, TX | Yes | Yes | No | Yes | Yes | No | No | No |
| City of Dayton, OH | None | None | Yes | Yes | Yes | No | Yes | No |
| City of Denver, CO | None | None | No | Yes | Yes | No | No | No |
| City of Des Moines, IA | None | None | No | Yes | No | No | No | No |
| City of Detroit, MI | None | None | No | Yes | Yes | No | No | No |
| City of Doral, FL | None | None | No | No | Yes | No | No | No |
| City of Durham, NC | None | None | No | Yes | Yes | No | No | No |
| City of East Hartford, CT | None | None | No | No | Yes | No | No | No |
| City of Edina, MN | None | None | No | No | Yes | No | No | No |
| City of Erie, PA | None | None | No | Yes | No | No | No | No |
| City of Euclid, OH | Yes | None | No | No | No | No | No | No |
| City of Eugene, OR | None | None | No | No | Yes | No | No | No |
| City of Everett, MA | None | None | No | Yes | Yes | No | No | No |
| City of Fayetteville, AR | None | None | No | No | Yes | No | No | No |
| City of Findlay, OH | None | None | No | No | Yes | No | No | No |
| City of Fontana, CA | None | None | No | No | Yes | No | No | No |
| City of Fort Wayne, IN |
It's our money. Keep it in our neighborhoods.
We need a strong Community Reinvestment Act.
#TreasureCRA
CRA will be essential for COVID-19 economic recovery in the communities hardest hit by the pandemic.
The Community Reinvestment Act was passed in 1977 to end discrimination known as redlining.
It required banks to meet the credit needs of the communities where they do business. Discrimination in lending is still a problem. Yet some want to substantially weaken the law. We can’t allow that to happen.
LATEST
Current Situation
The Office of the Comptroller of the Currency finalized new, weakened CRA rules in May 2020. NCRC has sued to stop enforcement. The Federal Reserve announced in September 2020 its own CRA rulemaking effort. See NCRC’s initial analysis. The other agency that enforces CRA, the FDIC, hasn’t updated rules for the banks it supervises.
Help us spread the word in your community.
Use the tools on this page to reach your friends and local leaders.
See what is at risk in your community with this tool. Include these findings in a comment letter about the proposed rules.
WE NEED TO MODERNIZE CRA, NOT RELAX IT.
Take Action
TELL REGULATORS
Submit A Comment
The Federal Reserve Board (Fed) has issued an Advance Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA). The ANPR’s proposals improve upon the current CRA exam structure in contrast to the Office of the Comptroller’s final rule, which dramatically weakens CRA.
Overall, the Fed’s approach is a good first step but NCRC will be seeking more rigor in some of the performance measures in order to ensure that CRA ratings will not be as inflated as they are today. More rigor is key to ensuring that CRA exams leverage more lending, investing and services for communities of color and low- and moderate-income communities.
How to Comment
Members of the public can comment to the Federal Reserve Board via email: regs.comments@federalreserve.gov. The Fed asks that the subject line of the comment and email include the Docket Number R-1723 and RIN Number 7100-AF94.
It is also possible to submit letters via the Fed website by going to this link. It should be noted that submissions to the Fed website can be NOT attachments, only text. If you want to submit a PDF or a Word document, it would be best to email your comment to the above email address.
If you would like read ALL comments submitted to the Fed ANPR, or check to see if your comment has posted, go to this link.
The comment period ends on February 16th at 11:59 pm.
Short Comment letter
Docket Number R-1723 and RIN Number 7100-AF94
To Whom it May Concern:
The Federal Reserve Board (Fed) must strengthen CRA exams in order to promote recovery from the COVID-19 pandemic. The Fed has described approaches in its Advance Notice of Proposed Rulemaking (ANPR) on CRA that will make CRA exams more objective. Yet, questions remain about whether the Fed’s approach will make grading tougher. If nearly every bank continues to pass their CRA exams, banks will not engage in serious efforts to help communities of color and low- and moderate-income (LMI) neighborhoods recover from the pandemic.
(Provide sentences here about how your organization engages in neighborhood development and is fighting COVID-19).
NCRC recently released a report finding a strong relationship between redlining and susceptibility to COVID. Redlined neighborhoods have the highest levels of health conditions such as asthma, diabetes and kidney disease, which make residents more susceptible to COVID-19. Life expectancy is almost four years lower in the redlined communities.
Since the start of the pandemic, about 41% of African American businesses have been closed compared to just 17% of White-owned small businesses. Discrimination in lending contributes to these differences in survival rates. A NCRC investigation found that African Americans applying for Paycheck Protection Program (PPP) loans for their small businesses during the pandemic were likely to receive less information than Whites.
CRA must be strengthened in order to combat discrimination. The Fed emphasizes improving the performance measures on CRA exams including those used on the lending test that compare a bank’s percent of loans to LMI borrowers to other lenders. The Fed does not describe in detail the impact of its reforms on CRA ratings except to hint that banks may continue to receive the same grades.
Moreover, the Fed is proposing to reduce the number of ratings on a state level and on subtests from five to four. This proposal would result in fewer distinctions in performance whereas new CRA exams must reveal more distinctions in order to motivate banks to be more responsive to COVID-19 recovery needs. Five ratings must be retained on the state level and on subtests.
The Fed asks whether underserved areas should be designated based on high levels of poverty or low levels of retail lending. NCRC advocated an approach based on low levels of lending which would effectively target redlined neighborhoods and communities of color.
We also ask the Fed to consider explicitly including race on CRA exams. The agencies have hesitated to do so but we believe that the CRA statute allows this since the law emphasizes banks meeting credit needs in all communities, but particularly underserved ones. CRA exams could include performance measures assessing lending, investing, branching and services to people of color and communities of color. The Fed could also provide CRA consideration for lending and investing in majority minority census tracts outside of assessment areas just as the Fed is considering for Indian reservations and other underserved areas.
In the interest of reaching underserved areas, we strongly support the Fed’s proposals to improve data collection including community development financing data, which would better enable stakeholders to determine communities most in need.
We support the Fed’s proposals to expand assessment areas, which are geographical areas on CRA exams. In addition to areas around branches, assessment areas must also include areas outside of branches with significant amounts of bank lending or deposit taking.
We do not support expanding financial education to any income since LMI consumers and people of color are most likely to be unbanked as revealed by surveys of the Federal Deposit Insurance Corporation (FDIC). Likewise, the Fed should further develop its procedures for awarding CRA credit for financing affordable housing that is unsubsidized so that such financing actually serves LMI residents.
Finally, we applaud the Fed proposal to eliminate distinctions in the rigor of examination among assessment areas that have resulted in banks neglecting smaller cities, rural counties and Native American reservations.
We appreciate the direction the Fed has embarked upon but caution that it must not end up with proposals that replicate existing CRA ratings inflation as this will not help our communities devastated by COVID-19.
Long Comment letter
Docket Number R-1723 and RIN Number 7100-AF94
To Whom it May Concern:
The Federal Reserve Board (Fed) must strengthen the rigor of CRA exams in order to promote recovery from the COVID-19 pandemic. The Fed has described approaches in its Advance Notice of Proposed Rulemaking (ANPR) on CRA that will make CRA exams more objective and transparent. Yet, questions remain about whether the Fed’s approach will reduce the high rate of CRA inflation. If nearly every bank continues to pass their CRA exams, banks will not engage in strenuous efforts to help communities of color and low- and moderate-income (LMI) neighborhoods recover from the pandemic’s devastation.
(Provide sentences here about your organization and how your organization engages in neighborhood revitalization and is fighting COVID-19).
Strengthening CRA is a critical component of a just recovery
The National Community Reinvestment Coalition (NCRC) recently released a major report finding significant correlations between redlining and susceptibility to COVID. In the 1930s, the Home Owners Loan Corporation (HOLC) commissioned the production of maps that rated neighborhoods based on the risk of lending in them. Working class and minority neighborhoods usually received the riskiest designation of hazardous. The designations subsequently facilitated redlining and discrimination against these neighborhoods, which remain starved of credit and are predominantly lower-income and minority. These neighborhoods also have the highest incidence of health conditions such as asthma, diabetes, kidney disease and stroke, which make residents more susceptible to COVID-19. Life expectancy is almost four years lower in the redlined communities than the neighborhoods not designated as hazardous by HOLC.
Since the start of the pandemic, more than 440,000 African American businesses have been closed or 41% compared to just 17% of White-owned small businesses. Discrimination in lending contributes significantly to racial disparities in small business survival rates. A NCRC investigation found that African American testers applying for Paycheck Protection Program (PPP) loans for their small businesses during the pandemic were likely to receive less information or encouragement to apply than White testers. CRA must be strengthened considerably in order to combat discrimination and help our communities recover from the pandemic.
The Federal Reserve proposal must be strengthened to prevent grade inflation
However, it is unclear if the Fed’s ANPR proposals will address CRA ratings inflation. The Fed emphasizes improving the performance measures on CRA exams including those used on the lending test that compare a bank’s percent of loans to LMI borrowers and communities to other lenders. However, the Fed proposes thresholds that appear to replicate the high ratings on CRA exams. The Fed does not describe in any detail the impact of its initial thresholds on CRA ratings and hints the thresholds replicate the current CRA ratings distribution.
Moreover, the Fed is proposing to reduce the number of ratings on a state level and on subtests from five to four. This proposal would result in fewer distinctions in performance whereas a new CRA exam system must reveal more distinctions in performance in order to motivate banks to be more responsive to COVID-19 recovery needs. Five ratings must be retained on the state level and on subtests.
The Federal Reserve proposal should be strengthened to increase lending to people of color
The Fed recognizes the importance of addressing racial inequities. It asks the public whether underserved areas should be designated based on high levels of poverty or low levels of retail lending. We support NCRC’s designation of underserved census tracts based on low levels of lending which would effectively target neighborhoods redlined because of the HOLC classifications.
We also ask the Fed to consider explicitly including race on CRA exams. The agencies have hesitated to do so but we believe that the CRA statute allows this since the law emphasizes banks meeting credit needs in all communities, but particularly underserved ones. CRA exams could include performance measures assessing lending, investing, branching and services to people of color and communities of color. In addition, CRA exams can include racial and ethnic demographic data in performance context analysis and require banks to affirmatively include communities of color in their assessment areas (geographical areas on CRA exams). The Fed could also provide CRA consideration for lending and investing in majority minority census tracts outside of assessment areas just as the Fed is considering for Indian reservations and other underserved areas.
Assessment areas must support and reflect a commitment to local lending, investments and services
We support the Fed’s proposals to expand assessment areas on CRA exams. In addition to areas around branches, assessment areas must also include areas outside of branches with significant amounts of bank lending or deposit-taking. We do not support the idea of a national assessment area for internet banks that the Fed discusses. Instead, we believe that data analysis can designate areas where high numbers of retail loans or deposits are located.
We applaud the Fed proposal to eliminate distinctions between full-scope and limited-scope assessment areas. Full-scope assessment areas, which are usually the largest cities, count more on current CRA exams than limited-scope areas that generally are smaller cities and rural counties. Often, communities of color, Native American reservations and other underserved communities continue to receive less CRA-related loans and investments because they are in limited-scope areas.
CRA modernization must maintain its focus on lower-income communities and communities of color
Unlike the Office of the Comptroller (OCC), the Fed generally does not stray away from the focus on LMI communities in its ANPR proposals. However, we do not support expanding financial education to any income since LMI consumers and people of color are most likely to be unbanked or underbanked as revealed by surveys conducted by the Federal Deposit Insurance Corporation (FDIC). The Fed can designate additional subgroups in the population such as people of color, people with disabilities or older adults for whom CRA credit for financial education or other community development activity can be earned instead of opening it up to everyone regardless of need. Likewise, the Fed should further develop its procedures for awarding CRA credit for financing affordable housing that is not subsidized so that such financing actually serves LMI tenants.
Collecting improved community development and deposit data
Finally, the Fed should pursue its proposals to collect improved community development and deposit data. Community development and deposit data should be collected on a census tract level or at least on a county level so that CRA exams can better target community development financing to areas of need.
Conclusion
We appreciate the direction the Fed has embarked in its ANPR but caution that it must not end up with a set of proposals that replicate existing CRA ratings inflation as this will not help our communities devastated by COVID-19. We believe that this proposal serves as an important starting point for an interagency rulemaking that will strengthen CRA and take a critical step towards more financially resilient communities and an equitable recovery.
View more tools and resources for hospitals, health systems and medical professionals.
Use this sample comment letter as a guide for yours.
Hospitals and Health Care
To: regs.comments@federalreserve.gov
Subject: RE: Notice of Proposed Rulemaking, Community Reinvestment Act Regulations, Docket Number R-1723, RIN Number 7100-AF94
To Whom It May Concern:
On behalf of the Sample Hospital System, a non-for-profit health system in Sample City, USA, I would like to convey my support of the Federal Reserve’s Advanced Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA). We believe that the proposed changes to the Community Reinvestment Act regulations outlined in the ANPR by the Federal Reserve Board will build upon and enhance the current CRA regulations, not tear them down as the final rule of the Office of the Comptroller of the Currency does.
Sample Hospital System is the largest hospital system in the Sample Region. We have grown significantly over the past 15 years, employing more than 8,000 individuals and operating 55 speciality acute care facilities. Our health system has more than 3,000 beds in 22 states. We serve more than 5 million patients annually.
The Federal Reserve Board ANPR proposes to build upon the existing CRA exam structure of separate tests for retail and community development activity. Separate tests are needed in order to ensure banks are responding adequately to the variety of local needs. The board is exploring how to create assessment areas, geographical areas on CRA exams that receive ratings, that will capture lending and deposit-taking activity outside of branch networks.
The board’s ANPR follows a final CRA rule issued in May 2020 by the Office of the Comptroller of the Currency (OCC). The OCC’s rule would decrease lending, investment and services in low- and moderate-income (LMI) communities by over-simplifying performance measures on CRA exams and broadening what counts on CRA to include activities that either partially or tangentially benefit LMI communities, including infrastructure like major bridges that may not be in or near LMI communities.
As a leader in patient care for the Sample Region, we know (and much research supports) that health outcomes are only a small part due to clinical care and personal behavior, while 60% can be attributed to social and environmental conditions, such as affordable and stable housing, income, job opportunity, proximity to healthy food options and education. Stable housing, in particular, is a cornerstone of optimal health outcomes.
In order to best promote health, we need healthy housing, steady job growth, decent schools, and green spaces in our communities. A strengthened CRA is needed to encourage banks to make loans and investments for affordable housing, community facilities and local small businesses. While we appreciate the Federal Reserve’s overall approach, we are concerned that the board must ensure its tests and performance measures do not end up replicating the high pass rates and ratings that banks currently receive and that do not reveal much distinctions in performance. Banks will be encouraged to increase their loans and investments in neighborhoods only if the final regulation produces rigorous exams.
In addition, we applaud the board’s proposals to improve the publicly available CRA data. In particular, community development activities will be increased if banks are held accountable via publicly available data. This data would reveal how many loans and investments banks are making in the various categories of community development compared to their peers.
Sample Hospital has collaborated with several community-based organizations in our region to invest in upstream projects that enhance the social determinants of health for our most vulnerable community members. Banks that we partner with look to CRA credit as added incentive to collaboration. Strengthening CRA offers the potential for greater collaboration between hospitals and banks to invest in and create healthy communities.
Sample Hospital urges the Federal Reserve to consider the health of underserved communities as part of a robust CRA.
We believe that this proposal serves as an important starting point for an interagency rulemaking that will strengthen CRA and take an important step towards more financially resilient communities and an equitable recovery. Thank you for providing this opportunity for Sample Hospital to comment on this critical rulemaking.
Sincerely,
Name
Title, Organization
TELL LOCAL LEADERS
The following sample resolution provides the history, purpose, and some of the basic functions of CRA and includes the key principles that are critical to preserve in the on-going regulatory reform effort by the nation’s bank regulators.
This template is a start and can be adapted by non-profits, localities, state legislatures and other governing bodies moved for immediate adoption. It should also include one or more clauses about the importance of CRA or the role it has played that is specific to the moving organizations or the local/state jurisdiction.
RESOLUTION TO PROTECT THE COMMUNITY REINVESTMENT ACT -TO ENSURE THAT EFFORTS TO MODERNIZE REGULATIONS DO NOT UNDERMINE THE INTENT OF THE LAW
WHEREAS, the Community Reinvestment Act (CRA) was enacted on October 12, 1977 to end the practice of “redlining” by financial institutions where they would draw a red line on a map around the neighborhoods they did not want to offer financial services; before the enactment of the CRA, redlining made it near impossible for low- and moderate-income Americans, racial and ethnic minorities, and their neighborhoods to access credit services, such as mortgages and business loans, regardless of their qualifications or creditworthiness; and
WHEREAS, CRA was a landmark civil rights law passed in 1977 to end discrimination that was once common in America’s banking and housing markets; and
WHEREAS, discrimination in lending is still a problem; and
WHEREAS, the CRA states that “regulated financial institutions have continuing and affirmative obligations to help meet the credit needs of the local communities in which they are chartered”; and
WHEREAS, the CRA establishes a regulatory regime for monitoring the level of lending, investments, and services in low- and moderate-income neighborhoods traditionally underserved by lending institutions; examiners from three federal agencies assess and “grade” a lending institution’s activities in low- and moderate-income neighborhoods; and
WHEREAS, the federal agencies conducting CRA examinations are: the Office of the Comptroller of the Currency (OCC), which examines nationally chartered banks and the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board – both of whom examine state-chartered banks; and
WHEREAS, if a regulatory agency finds a financial institution not serving these neighborhoods, it can delay or deny that institution’s request to merge with another lender or to open a branch or expand any of its other services; the financial institution regulatory agency can also approve the merger application subject to specific improvements in a bank’s lending or investment record in low- and moderate-income neighborhoods; and
WHEREAS, a financial institution’s CRA grade can be downgraded if a federal agency uncovers evidence of illegal, abusive or discriminatory lending on their fair lending exams that occur at about the same time as CRA exams; and
WHEREAS, since 1996, according to analysis of bank lending data by the National Community Reinvestment Coalition (NCRC), CRA-covered banks issued almost 29 million small business loans in low- and moderate-income tracts, totaling $1.156 trillion, and $1.179 trillion in community development loans that support affordable housing and economic development projects benefiting low- and moderate-income communities; and
WHEREAS, a 2016 review of the CRA examinations of intermediate small banks(ISBs)/mid-sized banks (banks with asset sizes today between $313 million and $1.252 billion) found that ISBs produced over $9.3 billion of community development (CD) loans and grants; and
WHEREAS, studies have found that CRA-covered home lending is safer and sounder than non-CRA covered lending; when a larger share of lending is issued by CRA-covered banks than by independent mortgage companies, a neighborhood experiences lower delinquency rates and less risky lending; and
WHEREAS, despite the tremendous benefits of CRA to communities, the full potential of CRA has not been realized because it has not been updated to take into account changes in the banking industry and the economy; independent mortgage companies not covered by CRA now make more than 50 percent of the home mortgage loans in America and financial technology companies (“Fintech”) not covered by CRA operating via the internet are rapidly increasing their lending; and
WHEREAS, notwithstanding the need to modernize CRA, we are concerned about ideas from some federal regulators that would substantially weaken the law; and
WHEREAS, geographic assessment areas must remain the focus of CRA exams for all banks; banks should continue to be graded based on every geography where they lend or receive a significant percentage of their deposits; banks cannot be allowed to cherry-pick where they lend – and where they don’t lend at all or to ignore the credit needs of distressed and vulnerable communities; and
WHEREAS, regulators review of a bank’s CRA commitment should not be consumed by an approach that is primarily driven by dollar amount. In May of 2020, the OCC finalized changes to its CRA regulations and implemented a presumptive rating which would mainly consist of the dollar amount of a bank’s total CRA activities divided by the bank’s deposits. CRA was designed to encourage the financial system to meet the credit and capital needs of people with low and moderate incomes and small businesses who frequently have a need for relatively smaller sized loans. Moving to a dollar volume approach would encourage larger deals at the expense of underserved borrowers the law was designed to protect; and
WHEREAS, the new OCC rule will allow 89% of the banks they regulate to opt for easier exams that will start right away and will result in more banks not having a service test that looks at their branching in lower income neighborhoods and in more banks not being evaluated for their community development financing;
WHEREAS, the OCC’s rule of 2020 would also move CRA away from its focus on low- and moderate-income families and communities and count the financing of large infrastructure projects and financial education for middle- and upper-income consumers; and
WHEREAS, CRA should explicitly state the law’s obligation to fairly serve all races and ethnicities; banks that engage in large-scale illegal and harmful activities should fail their CRA exams.
WHEREAS, replacing a lending test for large banks that counted for 50% of the overall rating with a pass/fail lending test will encourage banks to decrease their home and small business lending in communities of color and modest income communities;
WHEREAS, the new scoring system will radically devalue the importance of maintaining branches in neighborhoods with low- and moderate-incomes, despite strong evidence that branches are still heavily used by households with lower incomes; and
WHEREAS, the rule allows examiners at their discretion to grant multipliers of up to four times for activities that they consider innovative will result in inconsistent exams, inflated ratings, and reductions in in actual community development financing; and
WHEREAS, basing new assessment areas off of physical addresses of depositors is problematic since this information is not currently collected, and if collected would likely not be shared with the public, leaving cities to guess whether a bank has an obligation to serve their community; and
THEREFORE BE IT RESOLVED, that the (organization’s name), will support efforts to modernize CRA, but not relax or undermine the law’s goal and intent; and
BE IT FURTHER RESOLVED, that the (organization’s name), opposes the OCC’s changes to CRA and urges the Federal Reserve Board and FDIC to refrain from these harmful changes that will thwart the economic recovery from COVOID and will divert resources from recovery efforts in low- and moderate-income neighborhoods and communities of color that have been disproportionately harmed by COVID;
BE IT FURTHER RESOLVED, that the (organization’s name), will support modernizing CRA to apply it to non-bank institutions including mortgage companies, financial technology companies, and credit unions; and
BE IT FURTHER RESOLVED, that the (organization’s name), will opposes the OCC’s changes that also efforts to watered down the penalties under CRA for discrimination, and urges the Federal Reserve Board and FDIC to increase penalties for discrimination; and
BE IT FURTHER RESOLVED, that the (organization’s name), believes that banks should also be examined for how they are lending, serving and investing in underserved neighborhoods that have high minority populations, low capital flows and have had a history of redlining. While the Administration’s new CRA rules may give credit for bank activities in these neighborhoods, the OCC’s changes will not actively hold banks accountable for expanding opportunities for wealth building in communities of color; and
BE IT FURTHER RESOLVED, that the (organization’s name), will support a CRA with a clearly-defined grading system that emphasizes lending, bank branches, fair lending performance, and responsible loan products for working class families; and
BE IT FINALLY RESOLVED, that the (organization’s name), will support efforts to hold a bank accountable if it fails its CRA exam, or wishes to acquire a bank with a better CRA grade, and urge agencies to recognize and encourage community benefit agreements and efforts that motivate banks to make more loans, investments, and services available to traditionally underserved communities.
Respectfully submitted on _____,
LOCAL ACTIONS
Read more about local resolutions.
NYC Community Board 12 Manhattan, NY
NGO RESOLUTIONS
POLICYMAKER ACTIVITY