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Testimony & Regulatory Comments

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

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)

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

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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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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Groups Call on FDIC to Reject Ford Credit’s ILC Charter Application

(Download) August 24, 2022 Kathy L. Moe Regional Director Janet R. Kincaid Deputy Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square, Suite 2300 San Francisco, CA 94105 Re: Interagency Charter and Federal Deposit Insurance Application for Ford Credit Bank, a Utah State-Chartered Industrial Bank, Submitted to the Federal Deposit Insurance Corporation and

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NCRC Comment on Responsible Development of Digital Assets

(Download) August 8, 2022 Natalia Li Deputy Director Office of Financial Institutions Policy Department of the Treasury 1500 Pennsylvania Ave. NW Washington, DC 20220 RE: Docket 2022-14588 Ensuring Responsible Development of Digital Assets Dear Ms. Li: Thank you for the opportunity to comment on these questions. The National Community Reinvestment Coalition (NCRC) is an association

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NCRC’s Full Public Comment Letter On Community Reinvestment Act Interagency Rulemaking

(Download) Chief Counsel’s Office 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 James P. Sheesley Assistant Executive Secretary Federal Deposit Insurance Corporation 550 17th Street NW

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Testimony of Catherine Crosby, Town Manager, Town of Apex; Board Chairperson, National Community Reinvestment Coalition

(Download) “Better, Together: Examining the Unified Proposed Rule to Modernize the Community Reinvestment Act” House Financial Services Subcommittee on Consumer Protection and Financial Institutions, July 13, 2022 I am honored to testify before you today on the proposed regulatory reform of the Community Reinvestment Act. I am the board chairperson of the National Community Reinvestment

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40 Groups Urge FDIC To Downgrade TAB Bank

(Download) June 30, 2022 Janet R. Kincaid Deputy Regional Director Federal Deposit Insurance Corporation 25 Jessie Street at Ecker Square, Suite 2300 San Francisco, CA 94105 RE: Community Reinvestment Exam for TAB Bank Honorable Deputy Regional Director Kincaid: The National Community Reinvestment Coalition and the undersigned groups believe that the practices discussed in this comment

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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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Statement on the Need for An Interpretive Rule Concerning the Solicitation of Demographic Data for the Purposes of Fair Lending Self-Testing

(Download) June 22, 2022 We are a group of fintechs and consumer advocates who share a common interest in making the credit system fairer for historically underserved consumers. On June 29, 2021, the National Community Reinvestment Coalition and Affirm, Lending Club, Oportun, PayPal, Square (now “Block”), and Varo provided a joint statement to the Consumer

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