Testimony & Regulatory Comments

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

Comment to FHFA on the Fannie Mae and Freddie Mac 2022-2024 Underserved Market Plans

By / / Policy, Testimony & Regulatory Comments / 15 minutes of reading

(Download) July 16, 2021 Marcea Barringer, Senior Policy Analyst Federal Housing Finance Agency, Eighth Floor 400 Seventh Street, S.W. Washington, D.C. 20219 Attention: Duty to Serve 2022-2024 RFI Dear Ms. Barringer, The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to publicly comment on the Federal Housing Finance Agency’s (FHFA) request for input on the Fannie Mae […]

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Consumer and community groups urge Federal Reserve Board to ensure that financial institutions benefiting from the payments system serve the public interest

By / / Testimony & Regulatory Comments / 32 minutes of reading

(Download) National Community Reinvestment Coalition (NCRC) National Consumer Law Center (NCLC) (on behalf of its low income clients) Center for Responsible Lending (CRL) Comment to Board of Governors of the Federal Reserve System on the Proposed Guidelines for Evaluating Account and Service Requests July 12, 2021 Submitted electronically to regs.comments@federalreserve.gov Ann E Misback Secretary Board of Governors of

Consumer and community groups urge Federal Reserve Board to ensure that financial institutions benefiting from the payments system serve the public interest Read More »

NCRC comment on HUD’s AFFH interim final rule

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

(Download) Sasha Samberg-Champion Deputy General Counsel for Enforcement and Fair Housing Regulations Division, Office of General Counsel Department of Housing and Urban Development 451 7th Street SW, Room 10276 Washington, DC 20410-0500 July 12, 2021 Dear Mr. Samberg-Champion, Thank you for the opportunity to submit comments regarding the Department of Housing and Urban Development (HUD)’s interim

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Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, including Machine Learning

By / / Testimony & Regulatory Comments / 33 minutes of reading

(Download) July 1, 2021  Office of the Comptroller of the Currency: Docket ID OCC-2020-0049Board of Governors of the Federal Reserve System: Docket No. OP- 1743Federal Deposit Insurance Corporation: RIN 3064-ZA24Consumer Financial Protection Bureau: Docket No. CFPB-2021-0004National Credit Union Administration: Docket No. NCUA-2021-0023 RE: Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence,

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Statement on Request for Guidance on Implementation of Disparate Impact Rules under ECOA

By / / Testimony & Regulatory Comments / 3 minutes of reading

A proposal by National Community Reinvestment Coalition’s Innovation Council for Financial Inclusion. Preventing discrimination in the use of algorithms and predictive models is crucial for a fair financial system in the digital age. As a group of both consumer advocates and financial services companies, we have found a shared interest in encouraging a fair lending

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Support for the Greater Supervision in Banking Act (H.R. 3948)

By / / Testimony & Regulatory Comments / 2 minutes of reading

June 22, 2021 The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for

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Support the Fair Lending for All Act (H.R. 166)

By / / Testimony & Regulatory Comments / 5 minutes of reading

(Download) The Honorable Maxine Waters Chairwoman Committee on Financial Services United States House of Representatives Washington, DC 20515 The Honorable Patrick McHenry Ranking Member Committee on Financial Services United States House of Representatives Washington, DC 20515 Dear Chairwoman Waters, Ranking Member McHenry and Members of the Committee: We are writing to urge your support for H.R. 166,

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NCRC Summary of the Section 203, Strengthening the Community Reinvestment Act of 1977, of the American Housing and Economic Mobility Act of 2021 (S. 1368, H.R. 2768)

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

Although the Community Reinvestment Act (CRA) and other fair lending laws have increased lending and investment in traditionally underserved communities, stubborn and persistent lending disparities by race and income remain. CRA needs an update and its coverage of the financial industry must be expanded. The overall objective of Section 203 is to increase lending, investments

NCRC Summary of the Section 203, Strengthening the Community Reinvestment Act of 1977, of the American Housing and Economic Mobility Act of 2021 (S. 1368, H.R. 2768) Read More »

Ncrc opposes the deposit insurance application of Payservices, Inc. for failing to include a CRA plan

By / / Testimony & Regulatory Comments / 3 minutes of reading

April 8th, 2021 John Henrie Regional Director Federal Deposit Insurance Corporation 10 10th Street, NE Suite 800 Atlanta, GA 30309-3849 RE: Application for Deposit Insurance (New Bank) from PayServices, Inc. Dear Mr. Henrie: Please kindly accept our comment on the application from PayServices, Inc. (Delray Beach, Florida) for deposit insurance. PayServices failed to include a

Ncrc opposes the deposit insurance application of Payservices, Inc. for failing to include a CRA plan Read More »

Joint letter on the product and program limits imposed on Fannie Mae and Freddie Mac

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

(Download) April 6, 2021 The Honorable Janet Yellen Secretary Department of the Treasury 1500 Pennsylvania Ave, NW Washington, DC 20220 The Honorable Mark A. Calabria Director Federal Housing Finance Agency 400 7th St, SW Washington, DC 20024 Dear Secretary Yellen and Director Calabria, We are writing to express concerns about the various product and program

Joint letter on the product and program limits imposed on Fannie Mae and Freddie Mac Read More »

Joint industry-advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule

By / / Testimony & Regulatory Comments / 2 minutes of reading

(Download) April 5, 2020 Mr. Dave Uejio Acting Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 RE:        Docket No. CFPB-2021-0003; RIN 3170-AA98; Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): General QM Loan Definition; Delay of Mandatory Compliance Date Dear Acting Director Uejio, The undersigned organizations write to

Joint industry-advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule Read More »

Joint advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule

By / / Testimony & Regulatory Comments / 12 minutes of reading

(Download) April 5, 2021 Mr. Dave Uejio Acting Director Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 Re: Docket No. CFPB-2021-0003, Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): General QM Loan Definition; Delay of Mandatory Compliance Date Dear Acting Director Uejio: We the undersigned civil rights organizations are

Joint advocates letter on delaying compliance with the general loan definition under the CFPB’s Qualified Mortgage rule Read More »

NCRC comment on OMB Standards For Delineating The Metropolitan And Micropolitan Statistical Area, OMB-2021-0001

By / / Testimony & Regulatory Comments / 18 minutes of reading

(Download) March 19, 2021 RE: OMB Standards for Delineating the Metropolitan and Micropolitan Statistical Area, OMB-2021-0001 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) and the undersigned organizations oppose the Office of Management of Budget’s (OMB’s) proposed re-definition of metropolitan and micropolitan areas. Under the proposal, a metropolitan statistical area would be

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Letter of support for Don Graves to be next Deputy Commerce Secretary

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

(Download) The Honorable Maria Cantwell Chair Committee on Commerce, Science and Transportation United States Senate Washington, DC 20510 The Honorable Roger Wicker Ranking Member Committee on Commerce, Science and Transportation United States Senate Washington, DC 20510 March 17, 2021 Re: Consumer, community and civil rights groups urge confirmation of Don Graves for Deputy Secretary, Department

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Joint Letter urging inclusion of the Neighborhood Homes Investment Act in the Administration’s infrastructure proposal

By / / Testimony & Regulatory Comments / 4 minutes of reading

(Download) March 17, 2021 The Honorable Joseph R. Biden, Jr. The White House 1600 Pennsylvania Avenue, N.W. Washington DC 20500 Dear President Biden: We are a diverse and broad coalition of nonprofits, real estate trade groups, lenders, and civil rights advocates, brought together by a shared belief that we need a policy solution that expands

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