NCRC Opposes HR 6955: The Main Street Capital Access Act

July 21, 2026

The Honorable Hakeem Jeffries
Democratic Leader
U.S. House of Representatives
Washington, DC 20515

The Honorable Katherine Clark
Democratic Whip
U.S. House of Representatives
Washington, DC 20515

The Honorable Pete Aguilar
Chair, House Democratic Caucus
U.S. House of Representatives
Washington, DC 20515

Re: Oppose H.R. 6955, the Main Street Capital Access Act

Dear Leader Jeffries, Whip Clark, Chair Aguilar, and Members of Democratic Leadership:

The National Community Reinvestment Coalition (NCRC) and our network of 700+ community organizations urge Members to oppose H.R. 6955, the Main Street Capital Access Act and vote no on the House floor.

H.R. 6955 is a broad bank deregulation package that would weaken fair lending transparency, community accountability, bank supervision and merger review. The bill would reduce the tools regulators and communities rely on to detect redlining, monitor access to credit, evaluate bank mergers, prevent harmful consolidation and hold financial institutions accountable to the people they serve.

NCRC appreciates the inclusion of CDFI-related provisions, including CDFI Fund transparency and CDFI Bond Guarantee Program improvements. However, those revisions do not fix the bill’s core problem: H.R. 6955 moves federal banking policy in the wrong direction by weakening community accountability, fair-lending transparency, merger review and supervisory safeguards.

Earlier this year, NCRC urged a no vote when H.R. 6955 was considered in committee.  All Democratic members who were present voted no in Committee.^[1] We urge you to continue that opposition and vote no on the House floor.

1.  H.R. 6955 would sharply limit monopoly and competition review for mergers involving roughly 96% of all banks.

Section 601 would prohibit federal banking regulators when evaluating many mergers resulting in institutions below $10 billion in assets from engaging in a competition review and thus they cannot consider whether the mergers would create monopolies or substantially lessen competition. The latest floor version preserves competition review where a transaction would leave only one insured depository institution with a physical presence in the area. This narrow exception does not solve the problem and protects only against the most extreme case, while preventing regulators from reviewing many mergers that could still substantially reduce competition, reduce branch access, or weaken small-business, agricultural and consumer credit options in local markets.

Because roughly 4,129 of the nation’s 4,287 insured banks (or approximately 96 %) hold under $10 billion in assets, this carveout would cover a large share of community and regional bank merger activity.^[2] The problem is especially acute in rural counties and smaller local markets. A merger between two banks that are not nationally large can still have significant local consequences. In many communities, the loss of one local institution can mean fewer branches, reduced small-business lending, less agricultural credit, weaker customer service, and fewer banking choices.

NCRC conducted an analysis of every US county to assess the impact of potential mergers between the two largest banks in each county, with their combined assets being under $10 billion. NCRC found that 641 counties, predominantly rural, would shift from competitive markets to highly concentrated markets. In ten counties, one bank would control 100% of all local deposits. According to the FDIC’s Merger Decisions Annual Report to Congress (2024),^[3] regulators approved 61 regular bank-merger applications in 2023. Of those, 57 out of the 61 would have resulted in institutions less than $10 billion. Under H.R. 6955, many comparable transactions would fall within the bill’s competition-review safe harbor, unless the narrow one-physical-depository-institution MSA exception applied.

2.  H.R. 6955 would weaken CRA, HMDA and fair lending accountability

Section 204 would substantially reduce the tools communities rely on to ensure fair access to credit and hold banks accountable to local needs. The floor version no longer uses the same mechanics as the committee-reported bill, but the core concern remains: Section 204 would create an automatic increase for statutory thresholds across consumer and community-focused laws, including the Community Reinvestment Act and the Home Mortgage Disclosure Act.

Beginning in 2031 and every five years after that, Section 204 would require the Federal Reserve to raise the dollar cutoffs in laws like CRA and HMDA that determine which banks are subject to stronger reporting, examination and accountability rules. The Fed would decide whether to base those increases on nominal GDP or inflation.

That is the wrong test for community accountability.  Nominal GDP measures the size of the overall economy, while CPI measures inflation.  Neither one measures whether banks are serving communities fairly, the rates of redlining, the extent of market concentration, have sufficient data to detect discrimination, and whether credit needs in LMI communities are being met.  A larger economy does not mean community needs are being met.

The same problem applies to inflation indexing. Adjusting thresholds for CPI may sound technical or even routine, but in this context, this approach would still cause fair-lending transparency to shrink automatically over time without any finding that communities are being served fairly.

For NCRC and our members, the HMDA and CRA implications are especially serious. HMDA data is one of the primary tools used to detect redlining, evaluate whether lenders are serving borrowers and neighborhoods fairly, and identify gaps in mortgage access. CRA examinations are one of the few mechanisms that require banks to demonstrate that they are meeting the credit needs of their entire communities, including low- and moderate-income neighborhoods.

3.  H.R. 6955 would compress merger review and sideline community evidence

Section 604 would set a fixed 120-day clock for certain applications, beginning at the time of filing even if the submission is incomplete. If the Federal Reserve fails to act within that period, the application would be deemed granted.

That is a dangerous standard for complex bank transactions. Merger review should focus on whether a transaction will serve the convenience and needs of affected communities, preserve access to banking services, protect consumers and avoid harmful concentration. It should not be driven by an artificial clock that rewards incomplete applications and pressures regulators to approve deals quickly.

Section 604 would also restrict how regulators treat information from outside parties when determining whether an application is complete, potentially discounting community and consumer evidence that is often essential to understanding a transaction’s real-world impact. Community groups, local officials, small businesses and affected residents are often able to identify branch closure risks, fair lending concerns, weak CRA performance or service gaps that are not evident from the applicant’s own submission.

4.  H.R. 6955 focuses on how long merger approval takes, instead of whether mergers benefit local economies.

Section 603 directs the Inspector General of each Federal depository institution regulatory agency to conduct a study every three years on the “timeliness and efficiency” of merger approvals, including number of days it takes to process merger applications and the identification of “sources of delay.” Merger applications warrant scrutiny to evaluate their effect on each of the statutorily required factors of review, including how a proposed combination will serve the convenience and needs of the affected communities. Studies show signs of decreased small business lending after mergers, as well as lower rates paid to customers for deposits.^[4] However, despite this evidence, practically all merger applications are currently approved. Local economic needs would be much better served by directing the agencies to study the actual impacts of mergers and bank consolidation, instead of counting days to pressure regulators to make decisions faster.

Furthermore, concerns about the timeliness of merger reviews appear to be unfounded. NCRC analyzed the approval times of 18 merger applications submitted to the OCC in 2024.^[5] As shown in the table below, we found that the median days for approval after receipt of an application was 60 days, and that the average was 84 days. In other words, about half of these applications were approved 30 days after the end of a 30-day public comment period.