The Problem

The CRA was originally passed as one of several landmark civil rights laws passed in the 1960s and 70s in response to systemic redlining, discrimination, and disinvestment. The CRA requires banks to lend and provide services equitably, and support community development in the places where they do business.

The CRA is the reason why banks make loans to lower-income homebuyers; open or maintain branches in lower-income neighborhoods; invest time, resources, and money into community-based organizations and local projects for affordable housing and economic development; and more. However, because the CRA remains color-blind and hasn’t kept up with changes in the banking industry, it has not done enough to combat persistent discrimination, racial disparities, or threats of displacement. 

We now have a historic opportunity to change this. The three federal bank regulators issued a joint Notice of Proposed Rulemaking (NPR) - the first major update in over 25 years - to modernize and update the rules banks must follow to meet their obligations under the CRA.  ANHD’s priorities for reform: create a race-conscious CRA that measures the quantity and quality of activities; downgrades for harm and displacement; centers community input and needs; and maintains strong local obligations.

Take Action

The three federal bank regulators at the Federal Deposit Insurance Corporation (FDIC), Office of Comptroller of the Currency (OCC), and Federal Reserve Board issued a joint Notice of Proposed Rulemaking (NPR) to modernize and update the rules banks must follow to meet their obligations under the CRA. This is the first major update to the CRA in over 25 years. Comments are due August 5th. 

Stay tuned for ways you can engage and submit comments to support ANHD’s priorities for reform: create a race-conscious CRA that measures the quantity and quality of activities; downgrades for harm and displacement; centers community input and needs; and maintains strong local obligations.  ANHD members can also join our Equitable Reinvestment Coalition as another space to get involved in CRA reform and more!

This proposal is based on the Federal Reserve Board’s framework laid out in an Advanced Notice of Proposed Rulemaking, that identified important objectives, such as more effectively meeting the needs of LMI communities and addressing inequities in credit, promoting community engagement, and recognizing that CRA and fair lending responsibilities are mutually reinforcing. (See ANHD’s Statement on the Federal Reserve Board’s CRA Proposal)

But, there are also areas ANHD felt needed to be improved upon and developed further.

Keep checking back here for resources, and also refer to NCRC’s Treasure CRA page.

Why the CRA Matters

Our advocacy and comments will help regulators draft CRA rules that reflect ANHD’s priorities for a strong, equitable CRA:

The CRA should never have been color-blind and must have an affirmative obligation to serve people and communities of color with responsive, impactful activities that reflect the following priorities:

  • Quality, Quantity, and Impact are important components of CRA.

    • Banks must be evaluated on the quantity and quality of CRA activities: retail lending, community development finance, branches, banking products, and services.

    • Downgrade for displacement and harm: There must be downgrades for harmful behavior, including products, practices, and patterns of lending that lead to harassment, displacement, high costs, and harm.

  • Community Input and Community Needs must be at the heart of the CRA.

    • Community input must be woven into the CRA process at all levels, including the performance context and needs assessment; evaluation of bank performance; and additional areas where CRA is taken into account, such as branch closures, mergers and acquisitions, and other applications. 

  • Assessment Areas must maintain place-based Local Obligations.

    • Maintain assessment areas where banks have branches/ATMs and expand to other areas where banks also do considerable business, such as lending and taking deposits.

    • Any assessment area reform must increase the size of the pie: maintain or increase quality reinvestment where it is needed within large cities like New York City, while also directing capital to under-banked regions.

How Do CRA-Regulated Banks Help You & Your Community?

  • Bank branches and affordable, accessible banking products
  • Affordable mortgages to buy a home or stay in a home
  • Loans to help small businesses operate and expand
  • Financing for affordable housing, economic development, and community services – the Low-Income Housing Tax Credit (LIHTC) is just one example
  • Investments in Community Development Financial Institutions (CDFIs) and credit unions that serve individuals, small businesses, and nonprofit developers
  • Philanthropic grants to nonprofits that develop, advocate for, and support affordable housing, economic development, financial empowerment, and community services

Why Do We Need to Preserve & Strengthen the CRA?

  • Discrimination and disparities in lending and banking are still a problem for Black, Indigenous, and People of Color (BIPOC) Black, Indigenous, and People of Color.
  • Speculative multifamily lending and lending to bad acting landlords contributes to harassment and displacement.
  • Banks continue to close branches and charge high fees for banking.
  • CRA covered lending is safer and less likely to result in foreclosure than non-CRA covered lending.
  • Online bank lenders lend nationwide yet are only evaluated on their lending around their headquarters. Non-bank lenders are not covered by the CRA, meaning no regulator evaluates how equitably they are lending, nor do they have any obligation to reinvest in local communities.
  • Low-income communities of color have disproportionately fewer bank branches and do not have the banking products they need to conduct transactions and build wealth.

Recent Blogs and Media

Related Resources

An updated State of Bank Reinvestment in New York City analyzing the OCC’s final Community Reinvestment Act rule and its local impact during a global health pandemic
ANHD Weighs in on Banking Policy in Response to COVID-19
The OCC and FDIC Need to Hear From Us! Tell Them Why the CRA Matters by April 8th
The Consumer Financial Protection Bureau (CFPB) is now looking to roll back Home Mortgage Disclosure Act (HMDA) data and limit the number of lenders who report to HMDA at all.
Trends in 1-4 family home lending in NYC based on newly released Home Mortgage Disclosure Act (HMDA) data from 2016
An annual analysis of local bank reinvestment activity and the impact of the Community Reinvestment Act
An annual analysis of local bank reinvestment activity and the impact of the Community Reinvestment Act
Recent trends in 1-4 family home lending in NYC based on newly released Home Mortgage Disclosure Act data from 2012 to 2014
An analysis of economic development-related bank reinvestment activity in NYC, how the Community Reinvestment Act support economic development activities, and the lost opportunities in NYC.

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