Testimony & Regulatory Comments

Testimony and comments from NCRC about pending legislation and regulatory issues.

FHA and FHFA Forbearance Letter

The Honorable Ben Carson Secretary U.S. Department of Housing and Urban Development 451 7th Street, SW Washington, D.C. 20210 The Honorable Mark Calabria Director Federal Housing Finance Agency 400 7th Street, SW Washington, D.C. 20219 Dear Secretary Carson and Director Calabria: We are writing to express our deep concern over recent policy changes regarding the …

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Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule

Sign On Letter in Support of H.J. Res. 90 to Overturn the CRA Rule U.S. House of Representatives U.S. Capitol Washington, DC 20515 Dear Representative: On behalf of the undersigned organizations, we are writing to urge you to cosponsor and support H.J.Res. 90, a disapproval resolution that would overturn a poorly constructed rule change on …

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Analysis of the OCC’s Final CRA Rule

The Office of the Comptroller of the Currency (OCC) released their Community Reinvestment Act (CRA) final rule on May 20. It will lessen the public accountability of banks to their communities by enacting performance measures on CRA exams that will be complex and opaque, while at the same time over-simplifying how to measure a bank’s …

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Resolution to protect the Community Reinvestment Act – To ensure that efforts to modernize regulations do not undermine the intent of the law

The following sample resolution provides the history, purpose, and some of the basic functions of CRA and includes the key principles that are critical to preserve in the on-going regulatory reform effort by the nation’s bank regulators. This template is a start and can be adapted by non-profits, localities, state legislatures and other governing bodies moved for immediate adoption. It should …

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NCRC Comment on the CFPB’s Request for Information to Assist the Taskforce on Federal Consumer Financial Law

(Download) June 1, 2020 Comment Intake Bureau of Consumer Financial Protection 1700 G Street NW Washington, D.C. 20552 Re:       Docket No. CFPB-2020-0013 85 FR 18214 Request for Information to Assist the Taskforce on Federal Consumer Financial Law Dear Chief of Staff Weber: The National Community Reinvestment Coalition (NCRC) would like to respond to the …

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Over 130 groups support more funding for housing counseling

Dear Senate Leadership and Senate Appropriators: The National Community Reinvestment Coalition (NCRC) and the undersigned organizations are writing to urge the Senate to support housing counseling provisions included in H.R. 6800, the HEREOS Act, recently passed by the House.  Housing counseling agencies have played an essential role following the nation’s housing crisis and numerous natural disasters since then.  Congress …

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NCRC Comment Letter on Monzo’s Charter Application

(Download) May 21, 2019 RE: NCRC Comment Letter on Monzo’s Charter Application To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) maintains that Monzo’s charter application has not demonstrated a significant commitment to meeting the convenience and needs of the community to be served as required by the Community Reinvestment Act and the …

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NCRC comment on OCC licensing and merger applications

April 28, 2020 RE: Docket ID OCC-2019-0024 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC), an association of 600 community-based organizations dedicated to increasing access to affordable and safe banking products in traditionally underserved communities, opposes the Office of the Comptroller of the Currency’s (OCC’s) proposed changes to its licensing manual that describes procedures …

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NCRC urges emergency support for mortgage servicers

The Honorable Steven Mnuchin Secretary U.S. Department of the Treasury 1500 Pennsylvania Avenue NW Washington, D.C. 20220 The Honorable Jerome H. Powell Chairman Board of Governors of the Federal Reserve System 20th Street NW & Constitution Avenue NW Washington, D.C. 20551 The Honorable Jelena McWilliams Chairman Federal Deposit Insurance Corporation 550 17th Street NW Washington, …

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NCRC Supplemental CRA Comment Using Federal Reserve CRA Data

(Download) April 8, 2020 NCRC supplemental comment on proposed CRA evaluation measure using Federal Reserve CRA data Notice of Proposed Rulemaking (Docket ID OCC–2018-0008 and RIN 3064-AF22) Reforming the Community Reinvestment Act Regulatory Framework To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) is submitting another comment on the proposed changes to the Community Reinvestment …

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NCRC Comments Regarding Notice of Proposed Rulemaking (Docket ID OCC–2018-0008 and RIN 3064-AF22)

(Download) April 8, 2020 RE: Notice of Proposed Rulemaking, Community Reinvestment Act Regulations, Docket ID OCC-2018-0008 and RIN 3064-AF22 To Whom it May Concern: The National Community Reinvestment Coalition, an association of 600 community-based organizations that promote access to basic banking services, affordable housing, entrepreneurship, job creation and vibrant communities for America’s working families, believes …

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Sign-On Letter asking OCC & FDIC to Suspend CRA Rulemaking during the COVID-19 Crisis

(Download) March 24, 2019 The Honorable Joseph M. Otting Comptroller of the Currency The Honorable Jelena McWilliams Chairman, Federal Deposit Insurance Corporation Dear Comptroller Otting and Chairman McWilliams: On behalf of the undersigned organizations, the National Community Reinvestment Coalition (NCRC) requests an immediate suspension until the end of the health crisis of the comment period for the proposed changes to …

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NCRC’s Letter to Congress on COVID-19 Stimulus Provisions

(Download) The Honorable Mitch McConnell Majority Leader U.S. Senate S-230, The Capitol Washington, DC 20515 The Honorable  Chuck Schumer Minority Leader United States Senate S-221, The Capitol Washington, DC 20510 The Honorable Nancy Pelosi Speaker U.S. House of Representatives H-232, The Capitol Washington, DC 20515 The Honorable Kevin McCarthy Minority Leader U.S. House of Representatives …

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NCRC comment on Notice of Proposed Rulemaking, AFFH: Streamlining and Enhancements

March 16, 2020 Regulations Division, Office of General Counsel Rules Docket Clerk Department of Housing and Urban Development 451 Seventh Street SW, Room 10276 Washington, D.C. 20410-0500 Re: Docket No. FR-6123-P-02 Notice of Proposed Rulemaking Affirmatively Furthering Fair Housing: Streamlining and Enhancements Dear Assistant Secretary Farias: On behalf of the National Community Reinvestment Coalition (NCRC), …

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NCRC Director of Policy and Government Affairs Testifies in Front of House Financial Services Subcommittee on Consumer Protection and Financial Institutions About Winners and Losers in Proposed CRA Changes

Good afternoon Chairman Meeks, Ranking Member Luetkemeyer and the Members of the House Subcommittee on Consumer Protection and Financial Institutions. Thank you for the opportunity to testify and for convening this important hearing on the Community Reinvestment Act (CRA) to discuss the winners and the losers in the proposed rulemaking formally published last week by …

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