Take Action

End Redlining & Strengthen the CRA! 
 

Comments due August 5th on the Interagency Notice of Proposed Rulemaking (NPR)

We have a historic opportunity to strengthen the anti-redlining CRA as bank regulators are taking comments on the first major update to the CRA in over 25 years! Tell the regulators we cannot support the proposal without significant changes. 

While we appreciate several strong components of the proposal, we cannot support it without significant changes. The proposal must match 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 member/ally organizations: Download & personalize our sample comment letter.

• Individual Community Member Comments: flyer & guide

• Tenant Association Comments: Flyer & guide

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

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"

• 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 the Federal Reserve Board’s CRA 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’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.