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Testimony & Regulatory Comments

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

Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

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NCRC analysis of CRA Treasury report

The Department of Treasury released its long anticipated memorandum recommending changes and updates to the Community Reinvestment Act (CRA) in early April. Spring is a season of renewal and CRA is a law that indeed needs refreshing and updating. Passed in 1977, it imposes an affirmative obligation on banks to serve the needs of local communities. The statute directs federal bank agencies to examine and rate banks on their lending and service in low- and moderate-income communities.

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Letter to the Senate: Section 104 of S. 2155 undermines fair lending oversight & investment in underserved communities

The undersigned civil rights, fair housing, consumer, and community organizations write to highlight our strong concerns with Section 104 of S. 2155, “the Home Mortgage Disclosure Act Adjustment and Study”.  The tiered reporting proposed in Section 104 for banks and credit unions would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly.  The provisions would exempt 85% of depositories from the updated reporting required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank).

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NCRC’s congressional testimony on fintech oversight

Statement for the record from John Taylor, president and CEO, of the National Community Reinvestment Coalition to the House Financial Services Subcommittee on House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit   January 30, 2018 Chairman Luetkemeyer, Ranking Member Clay, and Distinguished members of the Subcommittee: The National Community Reinvestment Coalition (NCRC) appreciates

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Letter to Treasury: Strengthening the Community Reinvestment Act

The Honorable Steven T. Mnuchin Secretary of the Treasury Department of the Treasury 1500 Pennsylvania Ave NW Washington DC, 20220 Click here for a summary of the letter.   Dear Secretary Mnuchin, In February of 2017, President Trump issued an executive order mandating that federal agencies regulate the financial industry consistent with core principles including

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Don’t blame the affordable housing goals for the financial crisis 

Federal Research Financial Crisis Inquiry Report (2010)[1] “Conclusions of the Financial Crisis Inquiry Commission” “We also studied at length how the Department of Housing and Urban Development’s (HUD’s) affordable housing goals for the GSEs affected their investment in risky mortgages. Based on the evidence and interviews with dozens of individuals involved in this subject area,

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Rebuttal to personal privacy of HMDA in a world of big data

Anthony Yezer’s recent white paper, Personal Privacy of HMDA in a World of Big Data, is part of the banking industry’s continued effort to limit public access to data collected by federal agencies.[1] Yezer’s paper, which was funded by the Mortgage Bankers Association, fundamentally challenges data collection and reporting under the Home Mortgage Disclosure Act

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Oppose H.R. 2954 – “The Home Mortgage Disclosure Adjustment Act”

Dear Representative, The undersigned civil rights, fair housing, consumer, and community organizations strongly urge you to oppose H.R. 2954, “the Home Mortgage Disclosure Adjustment Act”. The bill would undermine efforts to ensure that the nation’s mortgage lenders are serving all segments of the market fairly by exempting the vast majority of lenders from the updated

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Summary of NCRC recommendations regarding Treasury Department review of CRA

Introduction: Last year, President Trump issued an executive order mandating that federal agencies regulate the financial industry consistent with core principles including empowering consumers to make informed financial decisions and build wealth. In June, the Treasury Department responded to this executive order by publishing the first of a series of reports on the financial industry

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Joint letter: request for meeting to discuss preserving access and affordability in Government Sponsored Enterprise reform

We, the undersigned civil and human rights organizations, write to express our profound concern with the ongoing discussions in Congress about comprehensive Government Sponsored Enterprise (GSE) reform legislation, and to request a meeting to ensure that our perspectives are taken into account in this very important effort.

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Sign-on letter regarding specific provisions of the “Tax Cuts and Jobs Act”

December 8, 2017 Dear Conferees: We, the undersigned members of the National Community Reinvestment Coalition (NCRC), are writing to urge you to adopt specific provisions included the Senate version of the “Tax Cuts and Jobs Act.” Although we have concerns overall with both versions of this bill, the Senate provisions regarding private activity bonds, the

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Comment Letter on Public Dissemination of HMDA Data

November 22, 2017 Docket No. CFPB-2017-0025 Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G. St. NW Washington, DC 20552   Dear Ms. Jackson: The undersigned organizations appreciate that the Consumer Financial Protection Bureau (CFPB) carefully applied the balancing test in determining which of the new Home Mortgage Disclosure Act (HMDA)

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Letter in Opposition to Bill H.R. 1

November 16, 2017 Dear Representative, We, the undersigned members of the National Community Reinvestment Coalition (NCRC), are writing to urge you to oppose H.R. 1, the Tax Cuts and Jobs Act.  Among other reasons, the bill includes several provisions that would undermine incentives in the nation’s tax code for low- and moderate-income (LMI) families to

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