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Testimony & Regulatory Comments

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

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 […]

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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

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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

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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

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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

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Letter to the FHFA on Tenant Protections for Enterprise-Backed Multifamily Properties

(Download) July 31, 2023 The Honorable Sandra Thompson Federal Housing Finance Agency Office of Multifamily Analytics and Policy 400 7th Street SW, 9th Floor Washington, D.C. 20219 RE:     Federal Housing Finance Agency’s Request for Input on Multifamily Tenant Protections Dear Director Thompson: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to submit written comments to the

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NCRC and Over 150 Organizations Unite in Support of Section 1071 of Dodd-Frank, Rejecting Congressional Repeal Efforts

(Download) July 25, 2023 The Honorable Patrick McHenry Chairman House Financial Services Committee 2134 Rayburn House Office Building Washington, DC 20515 The Honorable Sherrod Brown Chairman Senate Banking Committee 503 Hart Senate Office Building Washington, DC 20510 The Honorable Maxine Waters Ranking Member House Financial Services Committee 2221 Rayburn House Office Building Washington, DC 20515

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NCRC Letter to FHFA re Fair Lending, Fair Housing, and Equitable Housing Finance Plans Proposed Rule.

June 26, 2023 The Honorable Sandra Thompson Director Federal Housing Finance Agency 400 7th Street, SW Washington, DC 20024 Re:  RIN-2590-AB29, Proposed Rulemaking on Fair Lending, Fair Housing, and Equitable Housing Finance Plans Dear Director Thompson: The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to provide our comments on the Federal Housing Finance Agency’s (FHFA’s) Fair

NCRC Letter to FHFA re Fair Lending, Fair Housing, and Equitable Housing Finance Plans Proposed Rule. Read More »

A Maryland CRA Law Would Marshall Considerable Resources for Increasing Racial Equity and Reinvestment

(Download full whitepaper) Key Takeaways: A Maryland CRA law would apply to banks and credit unions with about $46 billion in assets. It would cover mortgage companies that made more than 68,000 loans in three years. The assets and lending activity are considerable resources that should have a CRA obligation for reinvesting in underserved neighborhoods.

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NCRC Comment Letter To The FTC And CFPB On Equity In The Tenant Screening Process

(Download) May 30, 2023 April Tabor Secretary Federal Trade Commission Office of the Secretary 600 Pennsylvania Avenue NW Suite CC-5610 (Annex B) Washington, DC 20580 Rohit Chopra Director Consumer Financial Protection Bureau 1700 G St. NW Washington, DC 20552 Re: FTC-2023-0024-0033 Dear Secretary Tabor and Director Chopra: The National Community Reinvestment Coalition (NCRC) appreciates the

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Environmental Justice Coalition Letter on HUD’s Affirmatively Furthering Fair Housing (AFFH) Rule

(Download) Honorable Marcia Fudge Secretary U.S. Department of Housing and Urban Development 451 7th St SW Washington, D.C. 20410 Re: Affirmatively Furthering Fair Housing, Docket No. FR–6250–P–01, 88 Fed. Reg. 8516 April 24, 2023 Dear Secretary Fudge: On behalf of the undersigned environmental justice and fair housing organizations and advocates, we are pleased to submit

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NCRC Comment Letter on HUD’s Proposed Affirmatively Furthering Fair Housing (AFFH) Rule.

(Download) Honorable Marcia Fudge Secretary U.S. Department of Housing and Urban Development 451 7th St SW Washington, D.C. 20410 Re: Affirmatively Furthering Fair Housing, Docket No. FR–6250–P–01, 88 Fed. Reg. 8516 April 24, 2023 Dear Secretary Fudge: On behalf of the National Community Reinvestment Coalition (NCRC) and our undersigned members, we thank you for this

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NCRC comment on FHFA Social Bond RFI

(Download) April 24, 2023 The Federal Housing Finance Agency Office of Fair Lending Oversight 400 7th Street SW 9th Floor Washington, D.C. 20219 RE: Enterprise Single Family Social Bond Policy RFI The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to submit written comments to the Federal Housing Finance Agency (FHFA) in response to its

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