Testimony & Regulatory Comments

The board’s question invites a dialogue about whether and where the Federal Reserve’s framework might affirmatively consider race more explicitly. While we are not yet committing to support various aspects of the Federal Reserve’s proposed framework for CRA examinations, this paper is designed to explore where and whether regulators could insert race in a framework like this from a statutory and constitutional perspective.

(Download) December 7th, 2020 Mr. Louis Gittleman Director for District Licensing Western District Office 1225 17th Street, Suite 300 Denver, CO 80202 RE: Figure Bank, National Association: Charter application Dear Director Gittleman: Please accept this comment from the National Community Reinvestment Coalition, the National Consumer Law Center® and the Center for Responsible Lending opposing the

(Download) December 1, 2020 Comment Intake Consumer Financial Protection Bureau 1700 G Street, NW Washington, DC 20552 Re: Request for Information on the Equal Credit Opportunity Act; Docket No. CFPB-2020-0026 Dear Director Kraninger: Thank you for the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request For Information (RFI) on the Equal Credit

(Download) Kathy Kraninger Director Bureau of Consumer Financial Protection 1700 G Street, NW Washington, DC 20552 Dear Director Kraninger: The undersigned civil rights, community, and consumer organizations appreciate the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) Request for Information (RFI) on the Equal Credit Opportunity Act (ECOA), which “seeks comments and information

(Download) October 13, 2020 Alfred M. Pollard, General Counsel, Attention: Comments/ RIN 2590–AB04 Federal Housing Finance Agency, Eighth Floor 400 Seventh Street, S.W. Washington, D.C. 20219 Dear Mr. Pollard: The National Community Reinvestment Coalition (NCRC) thanks you for the opportunity to publicly comment on the Federal Housing Finance Agency’s (FHFA) proposal to extend the 2018-2020

(Download) October 16, 2020 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Department of Justice’s (DOJ’s) merger review analysis. NCRC is an association of community-based organizations whose mission is to increase access to credit and capital in traditionally underserved communities. Our members are actively involved

September 22, 2020 Regulations Division, Office of General Counsel, Department of Housing and Urban Development, 451 7th Street SW, Washington, DC 20410-0500. Re: HUD Docket No. FR-6152-P-01 Making Admission or Placement Determinations Based on Sex in Facilities Under Community Planning and Development Housing Programs Dear Secretary Carson: The National Community Reinvestment Coalition is vehemently opposed

(Download) September 23rd, 2020 John O’Brien Licensing Manager Office of the Comptroller of the Currency Central District 425 S. Financial Place, Suite 1700 Chicago, IL 60605 CE.Licensing@occ.treas.gov RE: Formative Bank, N.A. Interagency Charter and Federal Deposit Insurance Application Dear Mr. O’Brien: The National Community Reinvestment Coalition, joined by the National Consumer Law Center (on behalf

September 3rd, 2020 National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005  Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Honorable Acting Comptroller Brooks: The undersigned respectfully submit this comment

September 3rd, 2020 The National Community Reinvestment Coalition 740 15th St. NW Washington, DC 20005 Brian Brooks Acting Comptroller of the Currency 400 7th St SW Washington, DC 20219 Re: Comments on Proposal “National Banks and Federal Savings Associations as Lenders” Docket ID: OCC-2020-0026 RIN 1557-AE97 Dear Mr. Brooks: We strongly oppose the Office of

Comment to the Federal Housing Finance Agency on Enterprise Regulatory Capital Framework Thank you for the opportunity to comment on the Federal Housing Finance Agency’s (FHFA’s) re-proposed rule on capital requirements for Fannie Mae and Freddie Mac (the governmentsponsored enterprises, or GSEs). In our view, the proposed rule erroneously treats the GSEs as banks and

Instructions for use: This is an interactive report. Please use the tiles at the top to page forward.      Questions: Jason Richardson Director, Research & Evaluationjrichardson@ncrc.org 202-464-2722