Why the CRA Matters

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

1. 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.

2. 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. 

3. 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.

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.