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OCCRulemakingOCC-2018-0008

Community Reinvestment Act Regulations

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Natural Resources Defense Council (NRDC) filings
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Natural Resources Defense Council (NRDC) filed 2 comments on this docket between Apr 8, 2020 and Apr 20, 2020. 699 other organizations filed here. The comment window closed 2302d ago.

What Natural Resources Defense Council (NRDC) filed (2)

Apr 20, 2020· Natural Resources Defense Council (NRDC) 2· OCC-2018-0008-3232

The Natural Resources Defense Council April 8, 2020 Re: Community Reinvestment Act regulations: Docket ID OCC-2018-0008, Joint Notice of Proposed Rulemaking; Request for Comment on Proposed Community Reinvestment Act Regulations (NPR) Dear Comptroller Otting and Chairman McWilliams: The Natural Resources Defense Council (NRDC) is an international, non-profit environmental organization representing more than three million members and online activists. Since 1970, our environmental experts have worked to protect the world's natural resources, improve public health, and ensure a safe and sustainable environment for all. NRDC appreciates the opportunity to comment on Docket Number OCC-2018-0008, a proposed rule to implement the Community Reinvestment Act (CRA) regulation. NRDC is a founding partner in the Strong, Prosperous, and Resilient Communities Challenge (SPARCC) alongside Enterprise Community Partners and the Low Income Investment Fund. SPARCC addresses the structural barriers facing low-income communities and communities of color by advancing an authentically community-driven model of development, putting residents' priorities at the center of the decision-making process. NRDC is also a founding partner of Energy Efficiency for All (EEFA) alongside the National Housing Trust, Elevate Energy, and the Energy Foundation. EEFA connects climate, health, and equity by bringing energy efficiency to affordable housing. We are pleased that the agencies have turned their attention to the critical issue of updating CRA regulations to reflect the challenges and opportunities of our modern banking system. CRA has become one of the country's most powerful community development tools and has introduced much-needed capital and financial services in low-income communities, communities of color and other underserved areas. CRA also has a racial equity impact given the law's enactment to address redlining. As currently written, NRDC does not support the proposed changes to CRA included in the NPR. Please see our comments attached. Thank you.

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Apr 8, 2020· OCC-2018-0008-2667

April 3, 2020 The Honorable Joseph Otting Comptroller of the Currency Office of the Comptroller of the Currency The Honorable Jelena McWilliams Chairman Federal Deposit Insurance Corporation Re: Request to end, suspend CRA rulemaking Docket ID OCC-2018-0008 and RIN 3064-AF22 Dear Comptroller Otting and Chair McWilliams, We request that your agencies immediately end rule making efforts relating to the Community Reinvestment Act (CRA), with its comment period scheduled to close on April 8, 2020. At the least, we urge you to suspend such efforts during the current COVID-19 pandemic. This has no doubt been the reaction of most community organizations throughout the nation. Our efforts are focused on responding to the current crisis and the huge economic and health impacts it is having and will continue to have on our communities. Family members, friends, neighbors, clients and constituents, are worried about remaining healthy, paying rent, making mortgage payments, having a job to report to, keeping a small business open, and ensuring there is food on the table. As such, community organizations that would otherwise participate in the current rule making process by submitting comments, may be prevented from evaluating and commenting on every problematic aspect of the proposed rule. This is especially concerning in that the proposed rule is complex, and will dramatically alter a regulatory framework that has been in place for some time. In addition, public comments submitted by April 8, 2020 will not at all reflect the unknown needs of low and moderate income communities in a new post COVID-19 America. Accordingly, the public record on which you will be basing your decisions will be incomplete and inadequate. The idea that the agencies would consider pressing forward with this CRA rule making is all the more distressing given our collective analysis that the proposed rule will dramatically weaken this critical civil rights law, and result in LESS reinvestment in communities and LESS accountability for banks at a time when the vulnerable neighborhoods meant to be protected by the CRA are at great risk of being disproportionately harmed by the current crisis. Once we come out of this crisis, we will need a stronger CRA to urge banks to be more engaged partners in creating and preserving stable homeownership and affordable housing opportunities; building small businesses that support entrepreneurs, hire locally and serve their communities; providing accessible bank account and other products that help consumers build wealth while avoiding predatory lenders; and fighting discrimination and displacement. The current proposal will frustrate these goals. As such, we urge you to end your plans for reform to the CRA rules. In the alternative, we urge you to suspend CRA rule making efforts until the COVID-19 pandemic ends and communities that will be impacted by CRA rule changes have time to stabilize and recover. If you have any questions about this request, please feel free to contact Khalil Shahyd at the Natural Resources Defense Council at kshahyd@nrdc.org. Thank you for your consideration of these comments. Sincerely, Khalil Shahyd - Senior Policy Advocate Healthy People/Thriving Communities Natural Resources Defense Council 1152 15th STREET NW WASHINGTON, DC 20005 T 202.513.6264 M 504.259.1673 kshahyd@NRDC.ORG

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Abstract

The Office of the Comptroller of the Currency (OCC or agency) invites comments on this advance notice of proposed rulemaking (ANPR) to solicit ideas for building a new framework to transform or modernize the regulations that implement the Community Reinvestment Act of 1977 (CRA). A new CRA regulatory framework would help regulated financial institutions more effectively serve the convenience and needs of their communities by encouraging more lending, investment, and activity where it is needed most; evaluating CRA activities more consistently; and providing greater clarity regarding CRA-qualifying activities. A transformed or modernized framework also would facilitate more timely evaluations of bank CRA performance, offer greater transparency regarding ratings, promote a consistent interpretation of the CRA, and encourage increased community and economic development in low- and moderate-income (LMI) areas. Revisions of this nature are consistent with the original intent of the CRA: To help meet the credit needs of the communities that banks serve. In addition, these types of revisions would align with the transformation of the banking industry and reduce the complexity, ambiguity, and burden associated with the regulations.

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Community Reinvestment Act Regulations (OCC) — Natural Resources Defense Council (NRDC) | OpenPolis