In 2018, the Office of the Comptroller of the Currency (OCC) published its Advance Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA). A number of policies were proposed by the OCC in the ANPR, which have the potential to significantly weaken the CRA and lead to discrepancies in lending to both low- and moderate-income (LMI) communities and to racial and ethnic minorities. There were some areas of agreement, but our analysis of the ANPR comments found many of the proposals from the OCC were seen as controversial, by not just community and civil rights groups, but also to many banks. In response to the ANPR, NCRC launched its #TreasureCRA campaign, which not only generated over 1,000 comments in opposition to the OCC’s proposals, but also led to local resolutions in support of a community-centered approach to CRA modernization.
Though the debate regarding the future of the CRA is with the federal regulators, we should not, and cannot, forget the role of our local communities and local governments, as they have the most to lose from potential changes to this vital law. Communities across the country will see substantial monetary losses if the CRA is significantly weakened. A recent NCRC forecast found that weakening the CRA could result in a $52 billion to $105 billion reduction in lending to LMI communities over five years. Local resolutions are a quick way for local governments to go on record with their support for the CRA and to highlight the important role CRA has played in their communities.
As of today, NCRC has worked with eight municipalities to pass CRA resolutions for the following cities:
- St. Louis, MO
- Baltimore, MD
- Milwaukee, WI
- Toledo, OH
- Boston, MA
- Oakland, CA
- San Fernando, CA
- New York, NY (NYC Community Board 12, Manhattan)
In addition to the municipal support, a number of national nonprofits are making CRA a major part of their policy agenda for 2020. The National League of Cities, for example, has included a section in their recent federal policy agenda on the need for CRA reform, which highlights many of the points NCRC makes in its sample resolution. We have also worked with the following nonprofits to pass resolutions:
- League of United Latin American Citizens (LULAC)
- National Black Caucus of State Legislators
- United States Conference of Mayors
Much has been accomplished but leading up to the publication of the Notice of Proposed Rulemaking (NPRM) on the CRA, which is rumored to be introduced in November or December, we need to hear from more local and state governmental entities about how critical CRA is to meeting the needs of LMI borrowers and neighborhoods in your communities.
If you are interested in working with NCRC to introduce a resolution, please reach out to Joseph Reed, NCRC’s Senior Policy Advocate at jreed@ncrc.org.
