Housing Action Illinois is gearing up for the biggest fight in decades for fairness in America’s housing and finance laws.
The Community Reinvestment Act (CRA) was created in 1977 to challenge discrimination in America’s banking and housing markets, such as redlining, and to encourage investment in low-income communities. In just the last 20 years, it has facilitated nearly $2 trillion dollars in small-business and community development loans.
Now, we’re worried about proposals to weaken the CRA coming from President Trump’s administration. The Office of the Comptroller of the Currency (OCC) has announced an Advanced Notice of Public Rulemaking (ANPR) for CRA reform and is taking comments on proposed changes.
Housing Action Illinois strongly encourages our members and allies to submit comments in to support of strengthening, not weakening, the CRA. Submit your comment by November 19!
Our concerns with the ANPR include:
- Banks would be less accountable and less responsive to community needs. If CRA exams award points for financing or activities that do not address lack of access to banking or community development needs in lower income neighborhoods, such as financing projects with supposedly broad benefits, then CRA will be less effective in channeling resources to the communities that were the focus of the 1977 legislation. Research has shown that low -and moderate-income people rely on branches for access to loans and banking services. If CRA exams drop branches from consideration, the amount of lending and bank services in low -and moderate-income neighborhoods will decrease significantly.
- The importance of assessment areas on CRA exams should not be diminished. This will lead to a 10 – 20% reduction in both mortgage and small business lending in low- and moderate -income communities.
- Easing compliance with the implementation of a “one ratio” will make CRA ineffective. A mathematical formula cannot reflect whether a bank is responding to local needs. This can only be accomplished through a variety of means, including considering public comments.
Below is information you may use to submit your comment on the proposed CRA reforms. Has your organization worked with a bank on a local community development project or received funding from a lender that has CRA responsibilities? Think about how the proposed changes will affect your future plans and projects.
This is the main information hub for the campaign. Here you’ll find NCRC’s sample comment, helpful reports, and blog posts, as well as social media links and content to help spread the word.
We have drafted a comment letter to the OCC. Please use this letter in its entirety or use only the parts that you see fit for your organization. We have flagged sections where it would be helpful to include examples and observations specific to your organization and community.
When you are ready, use this link to submit your comment to the Federal Register. Just click the green “Submit a Formal Comment” button at the top of the page to get started. The #TreasureCRA site also has a direct link to this page next to the sample comment.
Don’t forget to submit your comment by November 19!
The deadline is a week from today. We have to ensure that financial institutions continue to invest in low-income communities and in communities of color. Take action and submit your comment during this important rule process.
Housing Action Illinois
67 E. Madison #1603
Chicago, IL 60603
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