The Problem

The Trump Administration has been systematically dismantling long-standing civil rights laws, and now they are focusing on weakening the Community Reinvestment Act (CRA). The CRA was originally passed as one of the civil rights laws of the 1960s and 70s in response to systemic redlining, discrimination, and disinvestment. The CRA requires banks to lend and provide services equitably, and support community development in the places where they do business.

Take Action

The OCC is proposing changes that threaten the very heart of the CRA and put at risk the work we all do to serve and empower lower-income communities of color. Right now, we need to make our voices heard, which means comments are critical. The OCC is accepting comments for the next 60 days on its proposed changes - until the deadline of April 8th. Write a comment, ask allies, members, friends, family to comment. Tell them what is wrong with the proposal and what we want.

Click here to learn how to submit comments.

We must fight for the right priorities. Click here to see our priorities and stay tuned for more information on how to submit comments. Comments are due April 8th!

Why the CRA Matters

ANHD CRA FACT SHEET

The CRA is the reason why banks make loans to lower-income homebuyers, open or maintain branches in lower-income neighborhoods, invest time, resources, and money into community-based organizations and local projects for affordable housing, economic development, and more. With changes in the banking industry, persistent discrimination and racial disparities, and threats of displacement, the CRA need updating. However, the proposed changes to the CRA are not coming from the people impacted by redlining and disinvestment. They are driven by former banker turned Comptroller Joseph Otting of the Office of the Comptroller of the Currency (OCC). Even worse, the FDIC is joining them, allowing up to 70% of their banks to opt out, and the Federal Reserve Board is not supporting this flawed plan. This creates a confusing, bifurcated system with two of the three federal bank regulators offering proposals for the largest banks that threaten the very heart of this important law, while doing little to nothing to address its shortcomings.

Now is the time to fight back! Comments matter. Read more to learn about how the CRA helps you and your community, ways it needs to be strengthened, and why the OCC’s approach is the wrong one. The comment period is just 60 days, which gives us very little time to respond.

 

How Do CRA-Regulated Banks Help You & Your Community?

  • Bank branches and affordable, accessible banking products
  • Affordable mortgages to buy a home or stay in a home
  • Loans to help small businesses operate and expand
  • Financing for affordable housing, economic development, and community services – the Low-Income Housing Tax Credit (LIHTC) is just one example
  • Investments in Community Development Financial Institutions (CDFIs) and credit unions that serve individuals, small businesses, and nonprofit developers
  • Philanthropic grants to nonprofits that develop, advocate for, and support affordable housing, economic development, financial empowerment, and community services

Why Do We Need to Preserve & Strengthen the CRA?

  • Discrimination in lending is still a problem for Black and Brown people.
  • Speculative multifamily lending and lending to bad acting landlords contributes to harassment and displacement.
  • Banks continue to close branches and charge high fees for banking.
  • CRA covered lending is safer and less likely to result in foreclosure than non-CRA covered lending.
  • Online bank lenders lend nationwide yet are only evaluated on their lending around their headquarters. Non-bank lenders are not covered by the CRA, meaning no regulator evaluates how equitably they are lending, nor do they have any obligation to reinvest in local communities.
  • Low-income communities of color have disproportionally fewer bank branches and do not have the banking products they need to conduct transactions and build wealth.

Related Resources

An updated State of Bank Reinvestment in New York City analyzing the OCC’s final Community Reinvestment Act rule and its local impact during a global health pandemic
ANHD Weighs in on Banking Policy in Response to COVID-19
The OCC and FDIC Need to Hear From Us! Tell Them Why the CRA Matters by April 8th
The Consumer Financial Protection Bureau (CFPB) is now looking to roll back Home Mortgage Disclosure Act (HMDA) data and limit the number of lenders who report to HMDA at all.
Trends in 1-4 family home lending in NYC based on newly released Home Mortgage Disclosure Act (HMDA) data from 2016
An annual analysis of local bank reinvestment activity and the impact of the Community Reinvestment Act
An annual analysis of local bank reinvestment activity and the impact of the Community Reinvestment Act
Recent trends in 1-4 family home lending in NYC based on newly released Home Mortgage Disclosure Act data from 2012 to 2014
An analysis of economic development-related bank reinvestment activity in NYC, how the Community Reinvestment Act support economic development activities, and the lost opportunities in NYC.

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