Summary
CRA efforts have failed Indian Country for generations. Here's what NCRC is doing to amplify Native American voices and help end this neglect.
In honor of Native American Heritage Month, we here at National Community Reinvestment Coalition (NCRC) want to briefly mention where we are in the fight for economic justice in Indian Country. For over 40 years, the Community Reinvestment Act (CRA) has helped underserved communities across the country. The topline statistics are striking: $2 trillion in loans for community and economic development projects and $3 trillion in home and small business loans nationwide.
But Indian Country has hardly seen any of that positive activity. CRA has failed to meet even the bare minimum of needs of Native Americans. This has to change if the country is to make any progress in shrinking the Native American wealth divide.
NCRC is working hard to make that happen, in collaboration with leaders and advocates from Indian Country. One such group is the Native CDFI Network (NCN), which is the national association of Native CDFI’s working to increase community investment in Indian Country. In February of 2022, NCRC President and CEO Jesse Van Tol briefed the NCN policy team and leadership on pending regulatory updates to CRA, outlined how Native CDFIs can join NCRC’s efforts to hold banks accountable and sought guidance from NCN and other Native-lead organizations as to how NCRC can support specific priorities of tribal nations. The advice we received helped shape NCRC’s comment letter – and the conversations have set us up to build deep and lasting partnerships.
Through the course of the year, providing feedback, advice and counsel, NCN members made NCRC’s comment letter more impactful. From 2021 through 2022, NCN members from Arizona, Nebraska, Maine, New Mexico and South Dakota participated in NCRC’s community benefit agreement process with multiple banks.
On August 3, 2022, NCRC submitted its comment letter to the OCC, FDIC and the Board of Governor of the Federal Reserve System on NPR updating the Community Reinvestment Act (CRA). The full comment letter can be found here.
All of this matters because this year’s NPR represented the most significant changes to CRA regulation and exams in 27 years. For the first time, Native Land Areas are recognized and defined in the proposed CRA regulations. NCRC is thankful for all the input and believes our comment letter was strengthened to reflect the dire needs in Indian Country.
“For 45 years, the Community Reinvestment Act (CRA) has failed to incentivize desperately needed investments in Native communities. But the new CRA regulations promise a brighter investment future for Indian Country, thanks in part to the efforts of the National Community Reinvestment Coalition to uplift the priorities of Native CDFIs, tribal leaders, and other key Native voices,” said Native CDFI Network Board Chair and Interim CEO Pete Upton. “The Native CDFI Network salutes NCRC and CEO Jesse Van Tol for their advocacy and their partnership as we work together to ensure that CRA works for all underserved and underinvested communities across the United States.”
We look forward to future cooperation and collaboration with tribal nation leaders to increase community investment in Indian Country for years to come. Van Tol will be speaking at NCN’s Annual Policy & Capacity-Building Summit “Sowing the Seeds of Economic Justice Across Indian Country” on December 6th.
Greg Wilson is a Senior Organizer at NCRC.
Photo courtesy of US Dept. of Agriculture, via Flickr
