CRA Notice of Proposed Rulemaking

Help Preserve the Community Reinvestment Act
As you know, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have proposed a number of rules to modernize the Community Reinvestment Act (CRA). The proposed rules would remove your community’s voice in identifying your own local needs, undermines the flow of targeted resources available to your neighborhoods, and puts numerators and denominators ahead of communities and families – the ‘one ratio’ approach.
There is significant opposition to the proposed rule and not just from practitioners and industry leaders are concerned about the consequences. On the day the Notice of Public Rulemaking was released, FDIC Board Member Martin Gruenberg said, “These presumptive standards undermine one of the most important benefits of CRA – the incentive for banks to develop partnerships with local community organizations and other stakeholders to address community needs – because the banks can satisfy their CRA obligations by simply hitting the metric. Further, the single, dollar value-based metrics favor large, easy-to-accomplish investments and loans over more complex and innovative activities that may take longer to develop but have a higher impact on the community.”

The 60-day comment period is open until March 9 and this is one instance when quantity really matters. Please take 30 minutes to familiarize yourself with the issues by visiting ncrc.org/treasureCRA where you will find resources and sample comment letters you can adapt and submit. You can also visit www.naceda.org\cra for additional background on this important issue.

Please be sure to send a copy of your letter to the FDIC as well at: Comments@fdic.gov. Be sure to include the RIN 3064-AF22 on the subject line of the message. Also send a copy to your Representative(s) in Congress and Florida’s two Senators. You can find them at https://www.house.gov/ and https://www.senate.gov/senators/index.htm respectively.