Health Practitioners and Advocates Provide CRA Comments on Fed’s ANPR

Wealth equity is intrinsically tied to health equity. Hospitals and health systems are stepping into the community development arena more frequently as there are many opportunities for them to partner with banks and other financial institutions to reduce economic disparities that could reduce health disparities.

One of the ways hospitals and health systems can partner with banks is through the Community Reinvestment Act (CRA). NCRC recognized this connection and worked to bring health equity advocates to the Federal Reserve’s CRA Advanced Notice of Proposed Rulemaking (ANPR) comment period. By providing templates, key messages and other tools and resources, NCRC paved the way for its member organizations and partners to comment on the Fed’s ANPR as a uniform front to demand a stronger CRA. The ANPR did not propose specific changes to the CRA regulations or examinations but included several ideas from the board for reforming CRA.  

The comment period resulted in 615 total comments to the Fed, of which 65 comments, or 10.6%, were related to the social determinants of health and ultimate health outcomes for low- and moderate-income (LMI) communities. While most of these comments came from national organizations, many local and state organizations and companies and individuals such as medical professionals participated. Some common themes among commentators were related to mental health outcomes, people with disabilities, and overall population health, especially in LMI communities. 

The impacts of COVID-19 were a very prevalent trend, as the pandemic has had a detrimental impact on many low-income and minority populations. Many of these communities were facing great health disparities before the pandemic, which were then exasperated by the virus. This is the result of the higher incidence of disease where low-income and minority families reside. Many commenters chose to pull from personal or community experiences to demonstrate this and emphasize the need for a stronger CRA. 

One example of this is Georgia Advancing Communities Together, a statewide membership organization of nonprofit housing and community development. “The pandemic exacerbated pre-pandemic health challenges in Southwest Georgia, rural Georgia and communities of color,” it said. 

This comment is one of many that drew attention to the pre- and post-pandemic differences, which will not go unnoticed for LMI neighborhoods.

Another particularly notable comment came from Empowering and Strengthening Ohio’s People & The Benjamin Rose Institute on Aging. “Without a strong CRA, these populations will continue to be consigned to poverty, housing instability and chronic health issues, rendering our efforts futile. We are losing ground.”

Many commenters also took an interest in those with disabilities, wanting them included as a community to be invested in as part of CRA. 

“Without specifically including people with disabilities in the CRA, there will not be any progress in helping this community advance in the financial mainstream of American society,” said the Pennsylvania Assistive Technology Foundation. 

The Fed’s ANPR came shortly after a final CRA rule by the Office of the Comptroller of the Currency (OCC), which would have decreased lending, investment and services in LMI communities by over-simplifying performance measures on CRA exams and broadening what counts on CRA to include activities that either partially or tangentially benefit LMI communities. The OCC announced in May 2021 that they would halt the implementation of this rule and reconsider before further action. The Fed’s ANPR is much more in line with the stance of NCRC for strengthening the CRA, inevitably increasing investment in LMI areas. 

CRA is a tool that allocates resources to underserved communities and it addresses affordable housing and community development needs that ultimately improve population health. For example, housing that does not contain lead paint hazards and other environmental dangers will clearly improve the health of lower-income communities. The content of the ANPR comments was filled overwhelmingly with emphasis on targeting underserved demographics, which inherently supports a strengthened CRA. With over 90% of the 615 total ANPR comments being pro-NCRC’s position, this is a step in the right direction. NCRC will continue to champion work for a strengthened CRA that holds banks accountable for their investments in their communities. Banks can better meet community needs if they are attentive to the view of health care providers in their localities.

Emily Orminski is a summer intern for NCRC’s Special Initiatives program.

Photo by Tom Fisk from Pexels

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