Policy

Articles about NCRC policy issues.

NCRC analysis of the advanced notice of proposed rulemaking (ANPR)

On August 28, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) concerning the Community Reinvestment Act (CRA). The ANPR does not propose specific changes to the regulation implementing CRA. Instead, the OCC describes concepts or frameworks for changing CRA and poses several questions regarding the effectiveness […]

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Disparate impact reconsideration comments

August 20, 2018 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0001 Re: Docket No. FR-6111-A-01 Advanced Notice of Proposed Rulemaking Reconsideration of HUD’s Implementation of Fair Housing Act’s Disparate Impact Standard   Dear Assistant Secretary Farias: On behalf of

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Letter to the House of Representatives: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

Letter to the House of Representatives: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities Read More »

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities Read More »

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities Read More »

HUD suspends AFFH, a key civil rights rule intended to fight housing discrimination 

The U.S. Department of Housing and Urban Development (HUD) announced this week it is suspending the Affirmatively Furthering Fair Housing (AFFH) rule until 2020. The AFFH rule was passed in 2015 to provide jurisdictions with a long overdue roadmap and measurement tools to comply with the landmark Fair Housing Act (FHA). 

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Preserving the GSEs is key to preserving affordability

Nearly nine years after the U.S. government seized both of them at the height of the Great Recession, Fannie and Freddie remain under the control of the federal government. The good news is they’re profitable again. The bad news is they no longer play a significant role helping the working class obtain affordable home loans. 

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Past Policy Campaigns

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HMDA Data Enhancements

Enacted by Congress in 1975, the Home Mortgage Disclosure Act (HMDA) requires banks, savings and loan associations and other financial institutions to publicly report detailed data on their home lending activity. Over the years, community organizations and concerned citizens have used HMDA data as a tool to determine which banks are lending in their community.

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Small Business Data

Data disclosures must be enhanced for small business lending so that the public can thoroughly assess financial institutions’ lending practices to women, minorities, and working-class Americans. With enhanced data disclosure, regulatory agencies can more effectively enforce fair lending laws and banks are generally more motivated to serve overlooked small businesses. NCRC applauds Congress for passing

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Anti-Predatory Lending and Sustainable Homeownership

Since the last review of the Home Ownership and Equity Protection Act (HOEPA) by the Federal Reserve Board, the home mortgage market has changed considerably. Subprime lending has become a dominant force, unregulated mortgage brokers now originate a large part of the mortgages, and exotic mortgages with exploding interest rates have become a common occurrence.

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