STRENGTHEN CRA HEADER

Woodstock Institute is committed to protecting and strengthening the Community Reinvestment Act (CRA) so it fulfills its initial purpose: to keep banks accountable to local community needs.

 

Spurred by Chicago activists, including Gale Cincotta and Woodstock Institute, Congress passed the Community Reinvestment Act (CRA) in 1977 as an antidote to discriminatory policies blocking non-white neighborhoods from bank loans, a practice known as “redlining.”

The CRA creates an affirmative responsibility for financial institutions to intentionally invest in low- and moderate-income (LMI) areas. CRA provides vital streams of funding via home mortgages, loans to small businesses and grants to local nonprofit organizations. It is our best tool to ensure that banks are adequately serving all people in their footprint.

Now, two of the three federal banking regulators want to change how banks are evaluated under CRA. The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have issued a proposal that could dramatically reduce the amount and impact of banks’ community development activities. The CRA does need updating to accommodate for a changing – and increasingly, digital – financial services market. But this plan is not the way forward.


WHAT CAN YOU DO? SUBMIT A COMMENT LETTER

Tell federal bank regulators that you want a strong CRA. The public comment period for the proposed rule is only open through April 8, 2020 (March 9, 2020 deadline extended!)

Draft a unique comment, explaining why CRA matters to you/your organization. Use your voice to tell your story, but feel free to use our sample comment as a starting point.

Here’s how to submit your comment:

  1. Send your comment to the OCC by posting it on your comment to Regulations.gov’s online submission portal.

You can submit your letter by attaching it (in PDF, DOCX or JPEG format) OR you can copy/paste it into the comment box. We encourage organizations to use their letterhead. Comments by individuals, including organizations’ board members and clients, are also strongly encouraged. 

You will be directed to a confirmation page that indicates your comment was submitted successfully and gives you your official comment number. Your comment should be posted online within a few business days.

  1. Send it to the FDIC!

Email your comment to the FDIC at Comments@fdic.gov

Include the RIN 3064-AF22 on the subject line of your email.

Why submit again by email? The OCC and FDIC might issue separate final rules, and we want your comment to be seen by both agencies.

  1.   Send it to us, too!

Email your letter to Jenna (jseverson@woodstockinst.org) at Woodstock Institute so we can can read your comments and track the submissions we help solicit. Thank you!

 


RESOURCES

Sample Comment

Woodstock Institute’s Fact Sheets

Woodstock Institute, Chicago Community Loan Fund Comment Letter -- January 28, 2020

Woodstock Institute Comment Letter on OCC Calls to Advocates– January 27, 2020

Woodstock Institute Comment Letter to Urge Delay in Light of COVID-19 Crisis -- March 30, 2020

Federal Reserve Board Governor Lael Brainard’s speech

FDIC Board member Martin Gruenberg dissent

New York Times Editorial Board : “Changing Rules to Help Bankers and Hurt Poor Neighborhoods”

WEBINAR

We hosted a webinar with Housing Action Illinois to explain the proposal on Thursday, March 19, 2020.

Click here to watch the webinar.

Click here to view a PDF of the slides. 

We are hosting another webinar on April 1, 2020. 

Click here to register.