ANHD Statement on the Federal Reserve Board’s CRA Proposal

The Association for Neighborhood & Housing Development (ANHD) appreciates the Federal Reserve Board introducing a thoughtful, comprehensive, data-driven framework to modernize the rules governing the Community Reinvestment Act (CRA). The Federal Reserve’s ANPR serves as a productive alternative to the OCC’s rushed, harmful update to the rules. They are providing the public ample time to review this proposal and respond to the questions posed and appear serious about incorporating community input. We are particularly pleased to see direct questions about how the CRA can better serve people and communities of color, combat displacement, and promote impactful activities, such as bank branches, access to banking, lending to the smallest of businesses, and housing for the unhoused and very low-income populations.

The CRA is one of the key civil rights era laws passed in response to systemic and explicit racism, redlining, and discrimination. It requires banks to lend and provide banking services equitably, and direct money and investments to low-income communities. The details of this proposal and final rule matter greatly and will determine how banks are analyzed and incentivized to equitably serve these communities. This is especially the case for low-income, Black, Indigenous, People of Color (BIPOC) and communities who have long suffered from systemic redlining and discriminatory policies, and who are disproportionately impacted by COVID-19 in illness and job loss.

We look forward to reading the full proposal and engaging our members to provide detailed feedback on what works and what we believe needs to be strengthened. We hope this launches a productive process and framework that will ultimately lead to a comprehensive, cohesive CRA framework for all three regulators that incorporates ANHD’s principles for CRA Reform, which are to measure the quantity and quality of activities to benefit LMI people and communities and further racial equity; downgrades for displacement; center community input and needs; and maintain strong local obligations.