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Testimony & Regulatory Comments

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

Workforce Development Is A Solution to Climate Change and Income Inequality: NCRC’s Comment on the EPA’s Environmental and Climate Justice Grant Program

(Download) April 10, 2023 VIA ELECTRONIC FILING Office of Environmental Justice and External Civil Rights Environmental Protection Agency ECJRFI@epa.gov RE: Request for Information – Environmental and Climate Justice Block Grants Attention: Docket No. EPA-HQ-OEJECR-2023-0023 The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Environmental Protection Agency (EPA) Office of Environmental Justice …

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Environment cog

NCRC comment letter on the District- Maryland-Virginia Regional Fair Housing Plan

(Download) March 28, 2023 RE: MWCOG Attn: Fair Housing Plan To Whom it May Concern: The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Metropolitan Washington Regional Fair Housing Plan. The region is to be commended for developing the first regional plan in 25 years. The plan provides an important opportunity …

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NCRC and 10 other Advocacy Groups Call on the FDIC to Downgrade Republic Bank & Trust

(Download) March 30th, 2023 Teresa Sabanty Deputy Regional Director Federal Deposit Insurance Corporation 300 South Riverside Plaza, Suite 1700, Chicago, IL 60606-3447 CC: Kentucky Department of Financial Institutions RE: Community Reinvestment Act exam for Republic Bank & Trust of Kentucky. Dear Deputy Regional Director Sabanty: Thank you for the opportunity to submit this comment on the …

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Incorporating Race into the Illinois Community Reinvestment Act

February 28, 2023 Mr. Craig Cellini Rules Coordinator Illinois Department of Financial and Professional Regulation 329 West Washington, 3rd Floor Springfield, IL 62789 Via Email: Craig.Cellini@Illinois.gov RE: NCRC’s Written Testimony for the Bank Community Reinvestment Hearing on March 2, 2023 Code Citation: 38 Ill. Adm. Code 345  Dear Mr. Cellini: The National Community Reinvestment Coalition (NCRC), an association …

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Incorporating Race into the CRA

Support the CFPB and Stop Credit Card Junk Fees

NCRC has joined with Americans for Financial Reform, the National Consumer Law Center, More Perfect Union, and numerous other organizations in a campaign in support of the Consumer Financial Protection Bureau’s new proposed rule that holds banks accountable to keep credit card late fees at $8 or less. Send a comment to support the CFPB …

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Environmental Justice Advocates’ Letter to HUD re Equity in Disaster Recovery (CDBG-DR)

(Download) Marion M. McFadden Principal Deputy Assistant Secretary for Community Planning and Development U.S. Department of Housing and Urban Development 451 7th St SW Washington, D.C. 20410 February 21, 2023 Re: Request for Information for HUD’s Community Development Block Grant Disaster Recovery (CDBG–DR) Rules, Waivers, and Alternative Requirements, Docket No. FR–6336–N–01 (87 Fed. Reg. 77864) …

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NCRC Submits Comments to the Appraisal Subcommittee About Tackling Discriminatory Home Appraisals in Response to its January 24th Hearing

(Download) February 8, 2023 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 …

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Preventing Bluelining: NCRC’s Comment on the Federal Reserve’s Principles for Climate-Related Risk Management

(Download) February 6, 2023 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 RE: Federal Reserve Principles for Climate-Related Financial Risk Management for Large Financial Institutions, 87 Fed. Reg. 75267 Attention: Docket No. OP-1793 The National Community Reinvestment Coalition (NCRC) appreciates the opportunity …

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Guidelines for Evaluating Account and Services Requests, Docket No. OP-1788

(Download) January 17, 2023 Ann E. Misback Secretary Board of Governors of the Federal Reserve System 20th and Constitution Avenue, NW Washington, DC 20551 RE: Guidelines for Evaluating Account and Services Requests, Docket No. OP-1788 Dear Secretary Misback: Thank you for the opportunity to provide comments on the Proposed Guidelines Evaluating Account and Services Requests. The …

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NCRC Comment To CFPB: Enhancing Public Data On Auto Lending

December 19, 2022 Comment Intake Auto Lending Data Gaps Consumer Financial Protection Bureau 1700 “G” St., NW Washington, DC 20052 RE: Enhancing Public Data on Auto Lending, Document ID CFPB-2022-0075-0001 Dear Sirs: Please accept this comment from the National Community Reinvestment Coalition. The National Community Reinvestment Coalition and its grassroots member organizations create opportunities for …

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NCRC and its Coalition Call on Regulators to Reform Bank Merger Reviews. All Mergers Must Result in Benefits for the Public

(Download) 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 Supervision Board of …

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NCRC Letter to ICIC on Opportunities and Challenges in Federal Community Investment Programs

(Download) December 5, 2022 Interagency Community Investment Committee (ICIC) U.S. Department of the Treasury U.S. Small Business Administration U.S. Department of Commerce U.S. Department of Transportation U.S. Department of Housing and Urban Development U.S. Department of Agriculture Re: Notice and Request for Information on Opportunities and Challenges in Federal Community Investment Programs, 87 Fed. Reg. …

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NCRC Response to Advance Notice of Proposed Rulemaking on Trade Regulation on Surveillance and Data Security, “Commercial Surveillance, R111004.”

(Download) Office of the Secretary Federal Trade Commission 600 Pennsylvania Avenue, NW Suite CC-5610 (Annex B) Washington, DC 20580  Re:  Response to Advance Notice of Proposed Rulemaking on Trade Regulation on Surveillance and Data Security, “Commercial Surveillance, R111004.” Dear Secretary: The National Community Reinvestment Coalition (NCRC) welcomes the opportunity to comment on the Federal Trade Commission’s (FTC) …

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How And Why CRA Reform Proposals Must Improve Access To Credit And Capital For Small Businesses

How And Why CRA Reform Proposals Must Improve Access To Credit And Capital For Small Businesses November 2022 Download Report Josh Silver, Senior Fellow In late spring of 2022, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) proposed the most far-reaching changes to …

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Small Business and CRA

NCRC Calls for Reforms to Federal Home Loan Bank System

(Download) October 31, 2022 The Honorable Sandra Thompson Director Federal Housing Finance Agency 400 7th Street, SW Washington, DC 20024 Dear Director Thompson, The National Community Reinvestment Coalition (NCRC) appreciates this opportunity to share insights on the structure and role of the Federal Home Loan Bank System (FHLBs). This written response includes and expands upon …

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