Josh Silver

NCRC Comments Regarding Notice of Proposed Rulemaking (Docket ID OCC–2018-0008 and RIN 3064-AF22)

By / / Testimony & Regulatory Comments / 182 minutes of reading

(Download) April 8, 2020 RE: Notice of Proposed Rulemaking, Community Reinvestment Act Regulations, Docket ID OCC-2018-0008 and RIN 3064-AF22 To Whom it May Concern: The National Community Reinvestment Coalition, an association of 600 community-based organizations that promote access to basic banking services, affordable housing, entrepreneurship, job creation and vibrant communities for America’s working families, believes […]

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Sign-On Letter asking OCC & FDIC to Suspend CRA Rulemaking during the COVID-19 Crisis

By / / Testimony & Regulatory Comments / 8 minutes of reading

(Download) March 24, 2019 The Honorable Joseph M. Otting Comptroller of the Currency The Honorable Jelena McWilliams Chairman, Federal Deposit Insurance Corporation Dear Comptroller Otting and Chairman McWilliams: On behalf of the undersigned organizations, the National Community Reinvestment Coalition (NCRC) requests an immediate suspension until the end of the health crisis of the comment period for the proposed changes to

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Proposed OCC and FDIC Geographic Analysis of Home Mortgage and Small Business Lending: Permission to Decrease Lending for the Largest Banks?

By / / Research / 20 minutes of reading

Executive Summary The proposed changes to the Community Reinvestment Act (CRA) released by the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) would radically reconfigure the testing criteria for banks.  A new testing regime would assess low- and moderate-income (LMI) home mortgage and small business lending with a demographic comparison

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NCRC’s Letter to Congress on COVID-19 Stimulus Provisions

By / / Testimony & Regulatory Comments / 6 minutes of reading

(Download) The Honorable Mitch McConnell Majority Leader U.S. Senate S-230, The Capitol Washington, DC 20515 The Honorable  Chuck Schumer Minority Leader United States Senate S-221, The Capitol Washington, DC 20510 The Honorable Nancy Pelosi Speaker U.S. House of Representatives H-232, The Capitol Washington, DC 20515 The Honorable Kevin McCarthy Minority Leader U.S. House of Representatives

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NCRC comment on Notice of Proposed Rulemaking, AFFH: Streamlining and Enhancements

By / / Testimony & Regulatory Comments / 9 minutes of reading

March 16, 2020 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0500 Re: Docket No. FR-6123-P-02 Notice of Proposed Rulemaking Affirmatively Furthering Fair Housing: Streamlining and Enhancements Dear Assistant Secretary Farias: On behalf of the National Community Reinvestment Coalition (NCRC),

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The CRA Evaluation Measures Would Allow Banks to Relax their Retail Lending to LMI Borrowers and Communities

By / / Research / 13 minutes of reading

The Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) have proposed changes that would dramatically alter the Community Reinvestment Act (CRA) examination of banks. Their proposal would create a metric, called the CRA evaluation measure, that would be the dominant measure for determining a bank’s rating. As long as a

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Racial Wealth Snapshot: African Americans and the Racial Wealth Divide

By / / Research / 4 minutes of reading

Download Infographic   Defining African American Though a term that has personal meanings and different connotations for many, “African American” is defined by the U.S. Census as “a person having origins in any of the Black racial groups of Africa,” and used synonymously with the simple term “Black.” These African roots can be found in an array

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