Testimony & Regulatory Comments

Testimony and comments from NCRC about pending legislation and regulatory issues.

NCRC’s Comment on New York’s Proposed State CRA Rules for Mortgage Companies

(Download) April 4th, 2025 VIA ELECTRONIC FILING Terry McMahon Via Email: terry.mcmahon@dfs.ny.gov RE: NCRC Comment on the New 3 NYCRR 120 – Compliance with Banking Law Section 28-bb Dear Mr. McMahon: The National Community Reinvestment Coalition (NCRC), a network of over 700 community organizations dedicated to creating a nation that not only promises but delivers opportunities […]

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NCRC Comment on FDIC Proposed Rescission of 2024 Merger Policy Statement

(Download) March 31, 2025 RE: Comment on RIN 3064–ZA45, Proposed Rescission of FDIC 2024 Statement of Policy on Bank Merger Transactions To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the proposed rescission of the 2024 FDIC Statement of Policy on Bank Merger Transactions. We strenuously oppose

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Industry members of the Innovation Council urge regulatory stabilization at the CFPB

(Download) March 19, 2025 Majority Leader John Thune United States Senate SD-511 Washington, D.C. 20510 Minority Leader Charles Schumer 322 Hart Senate Office Building Washington, D.C. 20510 Re: Industry Support for the Rapid Confirmation of a Permanent Director of the CFPB To the Honorable Majority Leader Thune and Honorable Minority Leader Schumer, As members of

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NCRC and CDFI Members Urge Congress to Protect the CDFI Fund From Elimination

(Download) March 21, 2025 Senator Mark Warner Senator Mike Crapo Senator Thom Tillis, Chairman, Financial Institutions and Consumer Protection Senator Catherine Cortez Masto, Ranking Member, Financial Institutions and Consumer Protection Rep. Andy Barr, Chairman, Subcommittee on Financial Institutions Rep. Bill Foster, Ranking Member, Subcommittee on Financial Institutions Dear Senator Warner and Senator Crapo; Chairman Tillis

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NCRC Comment Letter in Opposition to Stellantis Bank USA Application for Deposit Insurance

March 15, 2025 Paul Worthing Regional Director San Francisco FDIC 25 Jessie Street at Ecker Square, Suite 2300 San Francisco, CA, 94105-2780 CRACommentCollector@FDIC.GOV Re: National Community Reinvestment Coalition Opposition to Federal Deposit Insurance Application for Stellantis Bank USA Director Worthing: We appreciate the opportunity to comment on Stellantis’ application for deposit insurance as part of

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NCRC and Member Organizations Send Letter to Congress Opposing Cuts to HUD Funding

(Download) Congressman Steve Womack, Chair Congressman James E. Clyburn, Ranking Member Subcommittee on Transportation, Housing, and Urban Development and Related Agencies House Committee on Appropriations Senator Cindy Hyde-Smith, Chair Senator Kirsten Gillibrand, Ranking Member Subcommittee on Transportation, Housing, and Urban Development and Related Agencies Senate Committee on Appropriations VIA EMAIL March 10, 2025 Dear Chairs Womack,

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NCRC’s Sign-on Letter About Proposed Cuts to the US Department of Housing and Urban Development

(Download) Congressman Steve Womack, Chair Congressman James E. Clyburn, Ranking Member Subcommittee on Transportation, Housing, and Urban Development and Related Agencies House Committee on Appropriations Senator Cindy Hyde-Smith, Chair Senator Kirsten Gillibrand, Ranking Member Subcommittee on Transportation, Housing, and Urban Development and Related Agencies Senate Committee on Appropriations VIA EMAIL February 27, 2025 Dear Chairs Womack,

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Sign On Letter To Protect Annual Funding For The CDFI Fund

(Download) February 18, 2025 The Honorable Bill Hagerty Chair Appropriations Subcommittee on Financial Services & General Government US Senate 251 Russell Senate Office Building Washington, DC 20510 The Honorable David Joyce Chair Appropriations Subcommittee on Financial Services & General Government US House of Representatives 2065 Rayburn House Office Building Washington, DC 20515 The Honorable Jack

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NCRC Memo on Final FHFA Affordable Housing Goal Rule for 2025-2027

(Download) December 23, 2024 TO: NCRC members and allies FROM: Josh Silver, Senior Fellow RE: Final FHFA Affordable Housing Goals Rule for 2025-2027 Dear Colleagues: On December 19, the Federal Housing Finance Agency (FHFA) issued its final affordable housing goals for Fannie Mae and Freddie Mac, known as Government Sponsored Enterprises (GSEs) for the years 2025 –

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NCRC Memo on Fannie Mae’s and Freddie Mac’s 2025-2027 Equitable and Underserved Markets Plan

(Download) On November 25, the Federal Housing Finance Agency (FHFA) released Fannie Mae’s and Freddie Mac’s Equitable Housing Finance Plans and Underserved Markets Plans for 2025 through 2027.[1] These plans are similar to bank reinvestment requirements except that the FHFA does not evaluate and rate Fannie Mae’s and Freddie Mac’s performance. Instead, Fannie Mae and Freddie Mac submit

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NCRC Comment on Third Party Guidance for Bank-Fintech Arrangements

(Download) October 15, 2024 RE: Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the recent interagency guidance on third party relationships and the follow-up request for information (RFI) on bank partnerships with fintechs (non-bank financial

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NCRC’s Comment on Proposed Affordable Housing Goals for 2025-2027

(Download) October 21, 2024 RE: 2025–2027 Enterprise Housing Goals To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposed affordable housing goals for 2025 through 2027. NCRC applauds some of the goals as pushing the Government Sponsored Enterprises (GSEs) to consistently

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NCRC Comments on Charles Schwab CRA Strategic Plan

(Download) October 16, 2024 Federal Reserve Board CCA-CRA-Staff@frb.gov  Federal Reserve Bank of Dallas Dallas-CASup@dal.frb.org CRA Officer Charles Schwab Bank, SSB Charles Schwab Premier Bank, SSB CRAPlanComments@schwab.com  Re: Proposed 2025 Community Reinvestment Act Strategic Plan for Charles Schwab Bank, SSB (the CSB Plan) and Proposed 2025 Community Reinvestment Act Strategic Plan for Charles Schwab Premier Bank,

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NCRC Comments on Square’s Proposed CRA Strategic Plan Outline how Square Exploits the ILC Charter to Avoid Reinvestment Obligations

(Download) The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to provide comments on the CRA Strategic Plan (the Plan) proposed by Square Financial Services Inc. (SFS or Square). NCRC is a coalition of over 700 community organizations that work with policymakers and financial institutions to champion fairness in banking, housing, and business development. Overall,

NCRC Comments on Square’s Proposed CRA Strategic Plan Outline how Square Exploits the ILC Charter to Avoid Reinvestment Obligations Read More »

NCRC comment on proposed FDIC rule on industrial banks

(Download) October 4, 2024 RE: Parent Companies of Industrial Banks and Industrial Loan Companies, RIN 3064–AF88 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on proposed changes to the FDIC regulation of parent companies of industrial banks and the rigor of the application process for industrial banks.

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