Testimony & Regulatory Comments

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

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,

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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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NCRC and Fintechs – Joint Letter on Fair Lending and the Executive Order on AI

(Download) September 25, 2024 Dear Director Chopra and Director Thompson, As nonprofit consumer advocates and for-profit fintech companies, we have found common ground that artificial intelligence (AI) can, and in many cases should, be used to improve fair lending practices. We write today to encourage further action pursuant to the Administration’s Executive Order on the Safe,

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NCRC comment on FDIC Proposed Rule regarding Change in Control Applications

(Download) September 16, 2024 RE: Regulations Implementing the Change in Bank Control Act, RIN 3064–AG04 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the FDIC’s proposed changes to its regulation implementing the Change in Bank Control Act. The FDIC is motivated to make this change because

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NCRC Comment on the AHP Application Process.

(Download) August 19, 2024 RE: FHLBank Affordable Housing Program Competitive Application Process To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) request for information regarding the Affordable Housing Program (AHP) application process. NCRC engaged in dialogue with our member organizations including

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NCRC Comment on Duty to Serve Plans

(Download) August 9, 2024 Marcea Barringer Supervisory Policy Analyst Attention: Duty to Serve 2025-2027 RFI Federal Housing Finance Agency, Ninth Floor 400 Seventh Street, S.W. Washington, D.C. 20219 Dear Ms. Barringer: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on Fannie Mae’s and Freddie Mac’s proposed Underserved Markets Plans for 2025-2027 submitted

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NCRC’s Jesse Van Tol Provided Remarks At Capital One – Discover Hearing

NCRC President and CEO Jesse Van Tol testified Friday, July 19, at a public hearing on the proposed Capital One-Discover merger. Here are his prepared remarks: Good Morning, I’m Jesse Van Tol, President and CEO of NCRC. This merger is a terrible, horrible, no good, very bad idea. And I could just end my testimony

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NCRC’s Kevin Hill Provided Remarks At Capital One – Discover Merger Hearing

NCRC Senior Policy Advisor Kevin Hill testified Friday, July 19, at a public hearing on the proposed Capital One-Discover merger. Here are his prepared remarks: Hello, I’m Kevin Hill with NCRC. The OCC and the Federal Reserve must deny Capital One’s application to acquire Discover Bank. This merger would further consolidate the credit card industry,

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NCRC comment on FHLB Bank Mission

(Download) July 12, 2024 To Whom it May Concern: NCRC appreciates this opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) request for information (RFI) regarding the mission of the Federal Home Loan Banks (FHLB) and their support of affordable housing and community development. The FHFA must sharpen the FHLBank mission statement and performance

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NCRC comment on FDIC proposed statement of policy

(Download) June 18, 2024 RE: Statement of Policy (SOP) on Bank Merger Transactions, RIN 3064–ZA31 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on proposed changes to the FDIC’s statement of policy on bank merger transactions. Bank mergers profoundly impact banks’ capacities to serve the convenience and

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NCRC Testimony at FHFA Listening Session and Comments in Response to FHFA RFI on Equitable Housing Finance Plans

Josh Silver, Senior Advisor, NCRC, June 5, 2024 The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to comment on the equitable housing finance plan requirement for the Government Sponsored Enterprises (GSEs). The GSEs, Fannie Mae and Freddie Mac, are major entities in the secondary market providing liquidity for banks and other lenders when they

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Letter to OMB Re: Improving Civic Engagement to Increase Public Participation in Government

Download May 17, 2024 Loren Schulman Associate Director Office of Performance and Personnel Management Office of Management and Budget 725 17th St., NW Washington, DC 20503 Samuel Berger Associate Administrator Office of Information and Regulatory Affairs Office of Management and Budget 725 17th St., NW Washington, DC 20503  Re: Methods and Leading Practices for Advancing

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