Testimony and comments from NCRC about pending legislation and regulatory issues.
(Download) March 21, 2019 Alfred M. Pollard General Counsel Federal Housing Finance Agency, Eighth Floor 400 7th Street, SW Washington, D.C. 20219 Attention: Comments/RIN 2590–AA98) Dear Mr. Pollard: We appreciate the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) notice of proposed rulemaking on credit score models. For more than 25 years, the […]
NCRC’s Comment on FHFA’s Proposal on Credit Score Models Read More »
Alfred M. Pollard, General Counsel Federal Housing Finance Agency, Eighth Floor 400 7th Street SW Washington, DC 20219 Attention: Federal Home Loan Bank Housing Goals Amendments, RIN 2590–AA82 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Federal Housing Finance Agency’s (FHFA) proposal to change the housing goals
January 20, 2019 Robert E. Feldman, Executive Secretary Attention: Comments Federal Deposit Insurance Corporation 550 Seventeenth Street NW Washington, D.C. 20429 Re: Small Dollar Lending Request for Information, RIN 3064-ZA04 Dear Executive Secretary Feldman: On behalf of the National Community Reinvestment Coalition (NCRC) and our more than 600 community-based organizations, thank you for the
Sign-on letter regarding small dollar lending request for information, RIN 3064-ZA04 Read More »
December 21, 2018 Consumer Financial Protection Bureau 1700 G Street NW, Washington, DC 20552 Request for Information Regarding Bureau Data Collections Docket ID CFPB-2018-0031 To whom it may concern: This letter is in response to the request issued by the Consumer Financial Protection Bureau (“the CFPB”) and listed as Docket No. CFPB-2018-0031 in the Federal
Comment on CFPB RFI on data collection Read More »
November 8, 2018 Reforming the Community Reinvestment Act Regulatory Framework Docket ID OCC-2018-0008 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that the Community Reinvestment Act (CRA or Act) has been one of the most valuable laws for increasing access to capital and credit for low- and moderate-income (LMI) communities. NCRC
October 15, 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. 20410-0500 Re: Docket No. FR-6123-A-01 Advanced Notice of Proposed Rulemaking Affirmatively Furthering Fair Housing: Streamlining and Enhancements Dear Assistant Secretary Farias: On behalf of the National Community
NCRC comment letter defending HUD’s Affirmatively Furthering Fair Housing Rule Read More »
10 bad ideas & bank-centric proposals for CRA regulatory reform An OCC-only approach to CRA reform On August 28, 2018, the OCC released an advance notice of proposed rulemaking (ANPR) that asks 31 questions on how to reform CRA regulations. The public comment period closes November 19th. NCRC research has found that a significant weakening
10 bad ideas for CRA (regulatory) reform Read More »
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
Disparate impact reconsideration comments Read More »
Supervisory Policy and Processes for Community Reinvestment Act Performance Evaluations OCC bulletin 2018-7 describes a number of technical and methodological issues concerning designation of assessment areas, data used on Community Reinvestment Act (CRA) exams, and scheduling of exams.[1] While this may seem technical in nature, the examination procedures outlined in the bulletin can have a
NCRC analysis of OCC bulletin 2018-17 Read More »
June 8, 2018 Senator Sanders, members of the Committee, my name is Stella Adams, and I serve as the Chief of Equity and Inclusion for the National Community Reinvestment Coalition, more commonly known as NCRC. NCRC creates, implements, and supports long-term solutions and strategies that build community and promote individual economic well-being. The programs of
Testimony of Stella Adams before the New York State Senate Democratic Conference Read More »
(Download PDF) June 13, 2018 Dear Chairman McWilliams, Comptroller Otting, and Chairman Powell: Since 1977, the Community Reinvestment Act (CRA) has driven inclusion and equity in the financial markets. The act compels banks to serve the credit needs of their communities. It became an indispensable tool for historically marginalized communities excluded from the financial mainstream.
Sign-on letter regarding CRA regulatory reform Read More »
Docket No. CFPB-2018-0004 Effectiveness and Efficiency of Supervision Program To Whom it May Concern: The National Community Reinvestment Coalition (NCRC), a coalition of more than 600 community-based organizations, urges the CFPB to make the fair lending review process more transparent and to better facilitate community group input in the process. This letter represents the views
NCRC comment on CFPB fair lending reviews and supervision Read More »
Reforming CRA must not become a pretext for relaxing CRA. The focus of these principles are areas we expect the federal bank agencies to consider in reforming CRA.
Principles for CRA Regulatory Reform Read More »
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).
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).
