Take Action

Take Action to End Redlining & Strengthen the CRA! 

Federal bank regulators are taking steps to move forward the first major update to the CRA in over 25 years! Unfortunately, they proposed rules for this anti-redlining law and still failed to include race.

We are taking action to change that!

During the three-month comment period on the Interagency Notice of Proposed Rulemaking (NPR) that ended on August 5th, ANHD, our members, and allies in New York City and nationwide took this historic opportunity to make our voices heard! We told the regulators that while we appreciate several strong components of the proposal, we cannot support it without significant changes. Through direct communication, written comments, and the media, we told them we need bank rules that match ANHD and ERC’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.  Stay tuned for next steps in the campaign, and keep raising these priorities!

Learn More:

• Frequently Asked Questions: Read ANHD’s FAQ 

•  Check out the presentation from our CRA Reform webinar, "Take Action for Stronger Race-Conscious Bank Regulations"

• Comment letters: Read ANHD’s final comments here; Browse other comment letters (including from ANHD members and allies) submitted to FDIC, OCC, and / or Federal Reserve Board

  • Prior comments. This proposal is based on the Federal Reserve Board’s framework laid out in an Advanced Notice of Proposed Rulemaking, (See ANHD’s Statement on that initial Proposal). Read ANHD’s final comments, co-signed by 13 member organizations

• ANHD is also an active member of the National Community Reinvestment Coalition (NCRC), which coordinates a national Treasure CRA campaign

• ANHD members can also join our Equitable Reinvestment Coalition as another space to get involved in CRA reform and more

ANHD’s Priorities for CRA Reform

• Race-Conscious CRA: The CRA should never have been color-blind and must have an affirmative obligation to serve Black, Indigenous, and People of Color (BIPOC) people and communities of color with responsive, impactful activities and downgrades for harm to the same communities 

• 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.