The Problem

The Community Reinvestment Act (CRA) is a civil rights law passed in 1977 to prevent discrimination in banking and lending in communities of color. 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, the CRA is color-blind, allows too many banks to pass without serving their communities, and hasn’t kept up with changes in the banking industry. As such, the system perpetuates discrimination, racial disparities, and displacement, and widens the racial wealth gap it was meant to narrow. Yet the interagency CRA Reform proposal maintains this color-blind approach

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

Learn More:

Why the CRA Matters

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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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.

Related Resources

Evaluating the threat to affordable housing by "predatory equity" investors who base a business model on overleveraging and harassment.

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