fbpx

Testimony & Regulatory Comments

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

NCRC comment on FDIC proposed statement of policy

(Download) June 18, 2024 RE: Statement of Policy (SOP) on Bank Merger Transactions, RIN 3064–ZA31 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on proposed changes to the FDIC’s statement of policy on bank merger transactions. Bank mergers profoundly impact banks’ capacities to serve the convenience and […]

NCRC comment on FDIC proposed statement of policy Read More »

NCRC Testimony at FHFA Listening Session and Comments in Response to FHFA RFI on Equitable Housing Finance Plans

Josh Silver, Senior Advisor, NCRC, June 5, 2024 The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to comment on the equitable housing finance plan requirement for the Government Sponsored Enterprises (GSEs). The GSEs, Fannie Mae and Freddie Mac, are major entities in the secondary market providing liquidity for banks and other lenders when they

NCRC Testimony at FHFA Listening Session and Comments in Response to FHFA RFI on Equitable Housing Finance Plans Read More »

Letter to OMB Re: Improving Civic Engagement to Increase Public Participation in Government

Download May 17, 2024 Loren Schulman Associate Director Office of Performance and Personnel Management Office of Management and Budget 725 17th St., NW Washington, DC 20503 Samuel Berger Associate Administrator Office of Information and Regulatory Affairs Office of Management and Budget 725 17th St., NW Washington, DC 20503  Re: Methods and Leading Practices for Advancing

Letter to OMB Re: Improving Civic Engagement to Increase Public Participation in Government Read More »

NCRC Comment on CRA Supplemental Rulemaking

Download May 13, 2024 Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E–218 Washington, DC 20219 Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 regs.comments@federalreserve.gov James P. Sheesley Assistant Executive Secretary Attention: Comments RIN 3064–AG03 Federal Deposit Insurance Corporation 550 17th Street NW Washington,

NCRC Comment on CRA Supplemental Rulemaking Read More »

NCRC comment on OCC proposed merger policy statement

(Download) April 23, 2024 RE: Docket ID OCC–2023–0017 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on proposed changes to the OCC’s regulations regarding Business Combinations Under the Bank Merger Act. Bank mergers profoundly impact banks’ capacities to serve the convenience and needs of communities. If the

NCRC comment on OCC proposed merger policy statement Read More »

NCRC’s comment on OCC’s proposed changes to its Freedom of Information Act regulation

(Download) April 22, 2024 RE: Docket ID OCC–2022–0008 To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment regarding availability of information under the Freedom of Information Act (FOIA). NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but

NCRC’s comment on OCC’s proposed changes to its Freedom of Information Act regulation Read More »

NCRC’s Comment Letter to HUD About Community Development Block Grants (CDBGs)

Download March 11, 2024 Jessie Handforth Kome Director, Office of Block Grant Assistance Room 7282 U.S. Department of Housing and Urban Development 451 7th Street SW, Washington, DC 20410 Heidi Frechette Deputy Assistant Secretary for Native American Programs Room 4108 U.S. Department of Housing and Urban Development 451 7th Street SW, Washington, DC 20410 RE: Submission for

NCRC’s Comment Letter to HUD About Community Development Block Grants (CDBGs) Read More »

NCRC’s Letter to The Appraisal Subcommittee About Potential Solutions to Appraisal Bias in Response to February 13, 2024 Hearing

(Download) March 4, 2024 Jim Park Executive Director Appraisal Subcommittee 1325 G Street Suite 500, NW Washington, DC 20005 appraisalbiashearing@asc.gov Dear Executive Director Park: The National Community Reinvestment Coalition appreciates the opportunity to submit written comments to the Federal Financial Institutions Examination Council’s Appraisal Subcommittee. We thank The Appraisal Subcommittee of the Federal Financial Institutions Examination

NCRC’s Letter to The Appraisal Subcommittee About Potential Solutions to Appraisal Bias in Response to February 13, 2024 Hearing Read More »

NCRC’s Comment on Second Illinois CRA Notice of Proposed Rulemaking

(Download) March 4, 2024 VIA ELECTRONIC FILING Mr. Craig Cellini Rules Coordinator Illinois Department of Financial and Professional Regulation (IDFPR) 329 West Washington, 3rd Floor Springfield, IL 62789 Via Email: Craig.Cellini@Illinois.gov RE: Comment on the Notice of Proposed Rules (NPR) regarding the Banking Community Reinvestment Rule (38 IAC 345), Mortgage Lenders Community Reinvestment Rule (38 IAC

NCRC’s Comment on Second Illinois CRA Notice of Proposed Rulemaking Read More »

NCRC Comment on the Proposed Capital Rule

(Download) January 15, 2024 Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th St. SW Suite 3E-218 Washington, DC 20219 Secretary Ann E. Misback Board of Governors of the Federal Reserve System 20th Street and Constitution Avenue NW Washington, DC 20551 Assistant Executive Secretary James P. Sheesley Comments/Legal OES Federal Deposit

NCRC Comment on the Proposed Capital Rule Read More »

Comment on SBA Proposed Rule on Criminal Justice Reviews for the SBA Business Loan Programs

Download November 14, 2023 Dianna Seaborn, Director Office of Financial Assistance U.S. Small Business Administration 409 3rd Street SW Washington, DC 20416 RE:      RIN 3245-AI03, 2023-19183, Criminal Justice Reviews for the U.S. Small Business Administration’s Business Loan Programs and Surety Bond Guaranty Program, Dear Director Seaborn: The undersigned organizations appreciate the opportunity to comment on the

Comment on SBA Proposed Rule on Criminal Justice Reviews for the SBA Business Loan Programs Read More »

NCRC Applauds OCC for Intentions to Survey Trust in Banking, Calls for an Inclusive Sample of End-Users and a Focus on How Banking is Changing

(Download) October 10th, 2023 Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th St. SW Suite 3E-218 Washington, DC 20219 RE: Trust in Banking Survey; Docket ID OCC-2023-0003 Dear Honorable Acting Comptroller Hsu: Thank you for the opportunity to comment on how the Office of the Comptroller will develop

NCRC Applauds OCC for Intentions to Survey Trust in Banking, Calls for an Inclusive Sample of End-Users and a Focus on How Banking is Changing Read More »

NCRC’s Response to Better Markets CRA Comment

September 22, 2023 Dear Members of the Board of Governors, FDIC Chairman, and Acting Comptroller of the Currency: On August 7, Better Markets (BM) sent a letter to the federal bank agencies asserting that the proposed CRA rule “will not work and that redlining will continue.” The BM letter dismisses an interagency proposal that would

NCRC’s Response to Better Markets CRA Comment Read More »

NCRC To Banking Regulators: New Automated Valuation Model Technologies Must Not Affirm Historic Redlining

(Download) August 21, 2023 RE: Quality Control Standards for Automated Valuation Models: Docket ID OCC–2023–0002; FDIC RIN 3064–AE68; Federal Reserve Docket No. R–1807 and RIN No. 7100 AG60; Docket Number NCUA–2023–0019; FHFA RIN 2590–AA62; and CFPB–2023–0025 To Whom it May Concern: Thank you for the opportunity to comment on the use of automated valuation models

NCRC To Banking Regulators: New Automated Valuation Model Technologies Must Not Affirm Historic Redlining Read More »

Time to Change Bank Merger Reviews: NCRC Calls for New Rulemaking Process

(Download) July 31, 2023  The Honorable Martin Gruenberg Acting Chair of the Board The Federal Deposit Insurance Corporation 550 17th Street, NW Washington, D.C. 20429  The Honorable Michael Hsu Acting Comptroller of the Currency Office of the Comptroller of the Currency 400 7th Street, SW Washington, D.C. 20219  The Honorable Michael Barr Vice Chair for

Time to Change Bank Merger Reviews: NCRC Calls for New Rulemaking Process Read More »

Scroll to Top