The Problem
The CRA was originally passed as one of the key civil rights laws of 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, with changes in the banking industry, persistent discrimination and racial disparities, and threats of displacement, the CRA needs updating.
The Trump Administration weakened the CRA for the nation’s largest banks. But now with the change in administration, we have the opportunity to work towards a CRA reform proposal that better reflects our priorities. We are hopeful for an interagency approach so that all banks play by the same rules.
Take Action
The Federal Reserve Board solicited comments on their framework in an Advanced Notice of Proposed Rulemaking, which lays out a more thoughtful, data driven process that identifies 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.
- Read ANHD’s final comments, co-signed by 13 member organizations
- Read ANHD’s sample comments that members personalized for their own comments
- ANHD is also an active member of NCRC, which coordinates a national Treasure CRA campaign
Why the CRA Matters
Our advocacy and comments will help regulators draft CRA rules that reflect ANHD’s priorities for a strong, equitable CRA:
- Quality, Quantity, and Impact are important components of 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.
- 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.
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