Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule
U.S. House of Representatives
U.S. Capitol
Washington, DC 20515
Dear Representative:
On behalf of the undersigned organizations, we are writing to urge you to cosponsor and support H.J.Res. 90, a disapproval resolution that would overturn a poorly constructed rule change on the Community Reinvestment Act (CRA) hastily finalized in May, days before Comptroller Otting’s resignation from the agency, and published this month.
At the outset, it is critical to note that the Trump Administration is split on the CRA final rule. With a lack of interagency coordination among the nation’s bank regulators, different banks will be held to different reinvestment standards depending on their regulator – an outcome that both banks and advocates have cautioned against. Federal Reserve Chairman Jerome Powell testified just last week that he expects the agency to move forward with CRA updates intended to garner “broad support among the community of intended beneficiaries” something he considers to be “one non-negotiable condition for it.” The OCC’s final rule achieved no such support or consensus. The vast majority of public comments – about 90 percent – opposed the CRA evaluation measure and presumptive ratings framework that remains at the heart of the final rule, but the OCC adopted it anyway[1].
The OCC’s final rule makes a series of changes to the CRA regulatory framework that reduce incentives for banks to lend to low-and-moderate income(LMI) families and invest and serve LMI communities: home buyers and homeowners, small businesses, community development projects that primarily benefit and serve LMI people. It also expands the number of banks that will have no review of how they open and close bank branches and provide key bank services in LMI and underserved neighborhoods.
These harmful changes could not come at a worse time. The ongoing COVID-19 pandemic and widespread social unrest that is gripping the nation has hit LMI and communities of color the hardest and brought gapping disparities to the forefront. The changes to the CRA being pushed through by the OCC would do little to address the pressing national priorities of reducing the racial wealth gap, of better serving those traditionally underserved by the nation’s financial system or stimulating an economic recovery from COVID-19 that is equitable. While the OCC claims its aim is to increase CRA activity, the lack of interagency agreement among this Administration’s regulators should serve as a dire warning about that claim. We do not yet know the full impact of COVID-19 on local mortgage markets, small business resiliency, or how LMI households, neighborhoods, local jobs, and key sectors will recover. Weakening CRA at this moment is a blueprint for a crisis after the crisis.
For all these reasons and more, we urge you to cosponsor H.J.Res. 90 and support it when it is considered on the House floor.
Sincerely,
National Groups
National Community Reinvestment Coalition (NCRC)
AFL-CIO
Americans for Financial Reform
Center for Community Progress
Consumer Action
Local Initiatives Support Corporation (LISC)
NACEDA
National Association for Latino Community Asset Builders (NALCAB)
National Housing Resource Center
National Housing Trust
National NeighborWorks Association
National Urban League
Prosperity Now
The Leadership Conference on Civil and Human Rights
UnidosUS
Alabama
Titusville Development Corporation
Arizona
Arizona Housing Coalition
Local First Arizona
Local First Arizona Foundation
California
California Coalition for Rural Housing
California Reinvestment Coalition
California Resources and Training
CDC Small Business Finance
EAH Housing
Grounded Solutions Network
High Impact Financial Analysis, LLC
Peoples’ Self-Help Housing
The Greenlining Institute
VSEDC
Colorado
Urban Land Conservancy
Connecticut
Neighborhood Housing Services of Waterbury
District of Columbia
Africa Diaspora Directorate
Delaware
Delaware Community Reinvestment Action Council, Inc.
Edgemoor Revitalization Cooperative, Inc.
The Ministry of Caring Inc.
Florida
Affordable Homeownership Foundation, Inc.
Community Reinvestment Alliance of South Florida
Goldenrule Housing & Community Development Corp Inc
Metro North Community Development Corp.
Solita’s House
Hawaii
Hawai’i Alliance for Community-Based Economic Development
Illinois
Accion Serving Illinois & Indiana
Chicago Community Loan Fund
Chicago Rehab Network
Housing Action Illinois
NW HomeStart, Inc
Woodstock Institute
Indiana
Continuum of Care Network NWI, Inc.
HomesteadCS
Legacy Foundation
Prosperity Indiana
Kentucky
River City Housing
Louisiana
Multi-Cultural Development Center
Massachusetts
Greater Boston Legal Services
Massachusetts Affordable Housing Alliance
Maryland
African American Chamber of Commerce of Montgomery County
Maryland Consumer Rights Coalition
Maryland Consumer Rights Coalition
Rebirth Inc.
Residential Housing Counseling Agency
Maine
Coastal Enterprises, Inc.
Michigan
Fair Housing Center of Metropolitan Detroit
GenesisHOPE
Habitat for Humanity of Michigan
Southwest Economic Solutions
Missouri
Metropolitan St. Louis Equal Housing and Opportunity Council
Mississippi
Hope Enterprise Corporation
Montgomery Citizens United for Prosperity (MCUP)
Montana
Montana Fair Housing, Inc.
North Carolina
Reinvestment Partners
New Jersey
NCRC Housing Rehab Fund, LLC
New Jersey Association on Correction
New Jersey Citizen Action
New Jersey Community Capital
New Mexico
Southwest Neighborhood Housing Services
New York
Association for Neighborhood and Housing Development (ANHD)
Banana Kelly Community Improvement Association
Beaulac Associates LLC
BOC Capital Corp. CDFI
Business Outreach Center Network
Center for NYC Neighborhoods
Chhaya Community Development Corporation
Community Capital New York
Community Development Venture Capital Alliance
CNY Fair Housing, Inc.
Community Loan Fund of the Capital Region, Inc.
Cypress Hills Local Development Corporation
Fair Finance Watch
Fidelis Federal Credit Union
Fifth Avenue Committee
Genesee Co-op FCU
Greater Jamaica Development Corporation
Habitat for Humanity New York City
Habitat NYC Community Fund
La Fuerza CDC
Neighbors Helping Neighbors
NYS CDFI Coalition
Oswego County Federal Credit Union
PathStone Enterprise Center, Inc.
Renaissance Economic Development Corp.
The Knowledge House
Three Jewels Outreach Center
University Neighborhood Housing Program
Ohio
Cleveland Neighborhood Progress
Columbus Compact dba Columbus Empowerment Corp.
County Corp
Homes on the Hill, CDC
Ohio CDC Association
The Fair Housing Center for Rights & Research
Working In Neighborhoods
Oregon
Housing Oregon
Pennsylvania
Amani Christian Community Development
Beltzhoover Consensus Group
Berks Latino Workforce Development Corporation (BLWDC)
Bloomfield-Garfield Corporation
Chester Community Improvement Project
Fair Housing Rights Center in Southeastern Pennsylvania
Good Bricks Ventures LLC
Hilltop Alliance
Housing Committee
Jave Jive Coffee LLC
Mount Washington Community Development Corporation
Northside Leadership Conference
PHDA Pittsburgh Housing Development Association, Inc
Philadelphia Association of Community Development Corporations
Pittsburgh Community Reinvestment Group
Rising Tide Partners
Southwest CDC
The Enterprise Center
Tube City Renaissance
Wilkinsburg Community Development Corporation
Rhode Island
HousingWorks RI
Texas
Our Casas Resident Council INC.
Recon Foundation
Southern Dallas Progress Community Development Corporation
Utah
Rocky Mountain Community Reinvestment Corporation
Washington
Low Income Housing Institute
Wisconsin
Citizen Action of Wisconsin
Disability Justice
Metropolitan Milwaukee Fair Housing Council
Movin’ Out, Inc.
United Community Center
Urban Economic Development Association of Wisconsin (UEDA)
Washington Park Housing Comm
YWCA Southeast Wisconsin
Revitalize Milwaukee
[1]“Although commenters disagreed with the approach outlined in the proposal, the agency ultimately agreed with the minority of commenters who expressed support for the proposed framework. OCC Final Rule, p. 18 or p. 34738. See also, Statement by FDIC Chairman Jelena McWilliams on the CRA Joint Proposed Rulemaking, May 20, 2020.
