Travis Hill, Chair
Federal Deposit Insurance Corporation (FDIC) 550 17th Street NW
Washington, DC 20429
Via email: comments@FDIC.gov
Jonathan V. Gould, Comptroller
Office of the Comptroller of the Currency (OCC) 400 7th St. SW
Washington, DC 20219
Via: https://regulations.gov/
Re: Community groups request an extension of the CRA comment period
RIN 3064-AG31, Docket ID OCC-2026-0694
Dear Chair Hill and Comptroller Gould,
The National Community Reinvestment Coalition, Rise Economy, and 374 community groups and national partners formally request the OCC and FDIC extend the sixty (60) day comment period relating to the recently proposed changes to the Community Reinvestment Act (CRA) rules. We believe that the significant changes suggested by the proposal necessitate a comment period of at least one hundred and twenty (120) days.
The 60-day comment period is not sufficient for effective examination of and comment on the over 350 pages of material and over 60 questions posed in this complex proposed rule. It proposes to reclassify over 1200 banks and we are concerned that many of the numerous proposed changes, if finalized in substantially the same form, would lead to considerably less reinvestment in the low- and moderate-income (LMI) communities meant to be served by the CRA. More specifically, we are concerned that proposed changes will lead to significant outcomes, including: less support for affordable housing via the Low Income Housing Tax Credit (LIHTC) and other community development activity, less transparency of small business lending, fewer community development loans and investments that support small businesses, fewer branches in LMI and rural communities, less access to affordable bank accounts and higher fees for unbanked and underbanked consumers, less capacity for community based organizations to play their critical role in supporting communities and the financial service ecosystem, and less scrutiny of redlining and discrimination by banks.
The NPRM does not appear to clearly quantify or address the costs to, and impacts on, communities of the various changes proposed. This lack of analysis of community impacts makes it difficult for the public to comment meaningfully on the proposal and puts the burden on communities to identify and quantify the proposal’s impacts. More time is needed to conduct research and analysis to understand what the agencies’ proposed changes to the Community Reinvestment Act will actually mean for communities, including Native American and Tribal communities.
We note that in 2020, when the FDIC and the OCC similarly proposed a new CRA rule, the agencies agreed to extend the comment period.1
For these reasons, the undersigned community organizations urge the FDIC and the OCC to extend the comment period on this proposal to one-hundred twenty (120) days in total.
Thank you for your consideration of this request. Should you have any questions, please feel free to contact Kevin Stein at Rise Economy, at kstein@rise-economy.org or Kevin Hill at National Community Reinvestment Coalition at khill@ncrc.org.
Very Truly Yours,
Kevin Stein
Chief of Legal and Strategy Rise Economy
Kevin Hill
Senior Policy Advisor
National Community Reinvestment Coalition
1 https://www.occ.gov/news-issuances/news-releases/2020/nr-ia-2020-19.html
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List of Endorsing Organizations
Access Plus Capital
Administration of Resources and Choices
Affordable Homeownership Foundation Inc
Affordable Housing Clearinghouse
African Diaspora Directorate
Alberta Bair Theater
Allensworth Progressive Association
AltCap
Americans for Financial Reform Education Fund Ampac Business Capital
ANHD
Appalachian Community Capital
Arbor Hill Development Corporation
Artist Space Trust
Asian Americans United
Asian Pacific Islander Small Business Collaborative
ASIAN, Inc.
AssistNA
Association for Enterprise Opportunity
Bascomb Real Estate Group
Beneficial State Bank
Beneficial State Foundation
Benito Juarez Foundation
Big Tent San Leandro
Bill Sorro Housing Program
Black Economic Council of Massachusetts
Blues City CRC
Bonnewit Development Services
Boston Impact Initiative
Boston Tenant Coalition
Brown Dog Apiary
Build Healthy Places
Burbank Housing
Ca CLT Network
CA Community-Based Development
Collective California Coalition for Community Investment
California Coalition for Rural Housing
California Coastal Rural Development Corporation
California Community Land Trust Network
California Housing Partnership
California Intertribal Alliances
CAMEO Network
Carole Rogers
CASA of Oregon
Casita Coalition
Catapult Greater Pittsburgh
CB Harreld Consulting
CDFI Friendly America
CDFI Friendly South Bend
Ceiba
Center for Community Progress
Center for Mortgage Access
Central Valley Women´s Entrepreneur
Center Centre for Home Ownership
Centro de Vida Victoriosa Inc.
Certified Commercial Realty
Charity Cultural Services Center
Chattanooga Neighborhood Enterprise
Chicago Community Loan Fund
Chicago Lawyers’ Committee for Civil Rights
Chinatown Community Children’s Center
Chinatown Community Development Center
Chinese-American Planning Council
Citizen Potawatomi Community Development
Corporation City of Hartford
City of Little Rock
CLARIFI
Climate Reality Project – NJ
Coalition for an Equitable Economy
Coalition of California State Tribes
Coastal Bend Sierra Club group
CoBiz Richmond
Common Counsel Foundation
Commonspace CLT
Communitas Veterans Agency Inc
Community Alliance with Family Farmers
Community Development Network of Maryland
Community Economics, Inc.
Community Housing Council of Fresno
Community Housing Development Corporation
Community Services Employment Training
Congregations Organized for Prophetic Engagement, COPE
Consumer Action
Consumer Federation of America
Consumer Federation of California
Consumers for Auto Reliability and Safety Foundation
Crowdfund Better
CRT
Debthelper.com
Delaware Community Reinvestment Action Council Inc.
Designated Exceptional Service for Independence
Dominican University
DPRA Group.Inc
Dunn Police Athletic & Activities League, Inc.
E. Rene’ Soule’ & Associates
EastBay Housing Organizations
East Los Angeles Community Corporation
East Missouri Action Agency, Inc
Eastside Opportunity Ventures
Empire Justice Center Enterprise Development Fund
Enterprise Management Consulting LLC
Envision Realty, Inc.
Epic Community Impact Fund
ESHARA (Ethnic Self-Help Alliance for Refugee Assistance)
ESO Ventures
Esperanza Community Housing Corp
Esperanza Community Land Trust Exp
Fair Finance Watch
Fair Housing Advocates of Northern California
Fair Housing Center for Rights & Research
Faith and Community Empowerment (formerly KCCD)
Family Resources of New Orleans
Filipino Community Development Corporation (FCDC)
Finanta
First Community Capital FMK, llc
Foundation for Filipina Women’s Network
Frank Carvalho Consulting Services
Freedom Equity Inc.
Genesis Historymaker CDC
Genesis LA
GES Coalition
Global Detroit
Greater Philadelphia Hispanic Chamber of Commerce, President & CEO
Green West Strategies
Green+
Grounded Solutions Network
Growing Together
Guapaholics
Habitat for Humanity Pasadena
Habitat for Humanity St. Tammany West
Haven Services
Hawai’i Alliance for Community-Based Economic Development
Health in Partnership
Heartatwork LLC
Hip Hop Caucus
His Sanctuary Community Development Corporation
Homestead Resources
Hope and Action: An Economy for All
Hope Village Revitalization
Housing Action Illinois
Housing and Economic Rights Advocates
Housing and Family Services of Greater New York
Housing California
Housing Channel
Housing Justice Center
Housing Now!
Housing Opportunities Made Equal of Greater Cincinnati
Housing Opportunities of Fort Worth
Housing Oregon
Housing Rights Center
Human Relations Council
I Rise FL, inc.
ICON CDC
IFF
Imole Otito Community Service
Impact Clint
Inclusive Action for the City
Inclusivity Institute
Indianapolis Neighborhood Resource Center
Indigenous Futures Society
Inland Empire Prism Collective
Inland Equity Community Land Trust
Inland SoCal Housing Collective
Innovative Housing Opportunities, Inc.
Isles, Inc
Jacksonville Area Legal Aid
Jamaica Plain Neighborhood Development Corporation
James’ Solar
JEDI
Jewish Family Services of Washtenaw County
JOURNEY TO DEVELOPER INITIATIVE, INC.
Joy Community Association
Justice Informed
Keene Development
Kingdom Community Development Corporation
Knowledgepanel
KPT Consulting
LA Forward
Lacasa, Inc.
Lafayette Habitat for Humanity
Land + Liberty
Larger Aim
Latino Leadership Council
Latino Texas Policy Center
Legacy Landmark Holdings
Leviticus 25:23 Alternative Fund, Inc.
LHOME
Little Manila Rising
Little Tokyo Service Center
Living Cities, Inc.
Local First Arizona
Logan Heights Community Development Corporation
Los Angeles
LDC
LUCHA (Latin United Community Housing Association)
MAHA
Manilatown Heritage Foundation
Massachusetts Association of Community Development Corps (MACDC)
Mastin Real Estate Services
MAUC
Melon 29:7 SE
Michigan LLC
Metro Milwaukee Fair Housing Council
Microenterprise Collaborative of Inland Southern California Midland Community Development Corporation
MidPen Housing Corporation
Mission Economic Development Agency MNC
Monte Vista Care Home LLC
Monterey County Black Caucus
Mothers with DAR Fighting Human Trafficking
Multicultural Real Estate Alliance
My Way Home (DBA of VCCDC)
MyPath
NAACP Stockton – San Joaquin County Branch
NACDC Financial Services
NARRATUR STUDIO LLC
National Association for Latino Community Asset Builders (NALCAB)
National Coalition for Asian Pacific American Community Development (National CAPACD)
National Community Development Association
National Consumer Law Center (on behalf of its low-income clients)
National Fair Housing Alliance
National Housing Resource Center
National Low Income Housing Coalition
National Urban League
Natural Resources Defense Council (NRDC)
Neighborhood Concepts, Inc.
Neighborhood Development Alliance, Inc.
Neighborhood Housing Services Los Angeles County
Neighborhood Housing Services of New York City
Neighborhood Housing Services of the Inland Empire (NHSIE)
Neighborhood Housing Services Oklahoma
Neighborhood Improvement Association
Neighborhood Partnership Housing Services
NeighborWorks Laredo
New Community Federal Credit Union
New Economics for Women
New Hope Housing Inc.
New Jersey Citizen Action
New Way Homes
Nimiipuu Community Development Fund
Nixyaawii Community Financial Services
Northeast Community FCU
Northwest Center Chicago
Office of Community and Economic Development
Old North St. Louis Restoration Group
Open Communities
Operation HOPE
Operation Relief Center
Opportunity Resource Fund
Orange County Asian and Pacific Islander Community Alliance (OCAPICA)
Oregon Consumer Justice
PACE Finance Corporation
Pacific Community Ventures
Pacific Islander Community Partnership
Pacific Islander Health Board of WA
Paterson Housing Authority
PCR Business Finance
Pennsylvania CDFI Network
People’s Opportunity Fund
People’s Self-Help Housing
Philadelphia Association of Community Development Corporations
PHIL-WILL CONTRACTING
Piedmont Housing Alliance
Pima County Community Land Trust
Pittsburgh Community Reinvestment Group (PCRG)
Placer People of Faith Together
Pleasant Drive Animal Rescue
Prestamos CDFI
Private Law Office- Jan Perkins Law Office
Prosperity Indiana
PT Partners Public Counsel
Puerto Rico NHS Corp.
Quarles Realty Development Enterprise
RAIL CDC
RAISE Texas
RCAP Solutions, Inc.
RealTree Capital Advisors
Rebuilding Together
Redbud Financial Alternatives, Inc.
Reinvest Toledo
Renaissance Economic Development Corp.
Renaissance Entrepreneurship Center
Resilience OC
Revitalize Community Development Corporation
Riverworks Development Corporation
RMJAssociates
Rural Community Assistance Corporation (RCAC)
Rutgers CLiME
Sacramento Housing Alliance
San Francisco Community Land Trust
San Joaquin Valley Housing Collaborative
Sand Hills Urban Development Inc
Sandra Morey Company
Sawyer County Housing Authority Scale Link
SCANPH
Scientists for Social Progress
Self-Help Enterprises
Sierra Business Council
Sisters of Seton Hill
Small Business Majority
Smith Aquatic
Safety Service
Social Equity Empowerment Network NY
SOUTH ASIAN NETWORK, INC
Southeast Asian Community Center
Southern California Black Chamber of Commerce
SouthFair CDC
Southwest Fresno CDC
Springboard CDFI
St. Bartholomew Parish
St. Philip’s School & Community Center
Stanislaus Community Foundation
Stanislaus Equity Partners
Stark Mountain Woodworking Starting Over Inc
State of AZ
Stearns
Supportive Housing Alliance
Taala Fund
Tacoma-Pierce County Affordable Housing Consortium
Texans For Housing
Texas Appleseed
Texas Housing Conservancy
Thai Community Development Center
The Academy of Financial Education
The Black CREED Institute of America
The Cedric Group
The Central Valley Urban Institute
The Enterprise Center at PathStone
THE FAIR HOUSING COUNCIL OF SAN DIEGO
The Fair Housing Council of The Capital Region
The Greenlining Institute
The Housing Fund
The Olevia Community Development Corporation
The Public Interest Law Project
The Redress Movement
The Sacramento Environmental Justice Coalition
The Unity Council
Toledo Design Collective
Transparency Task Force
TREC Community Investors
Turtle Island Community Capital
Two Valleys Community Land Trust
U SNAP BAC NON PROFIT HOUSING CORPORATION
United Housing, Inc.
United South Broadway Corporation
United Way of San Diego County
Universal Housing Solutions CDC
UpSpring Associates
Uptima Entrepreneur Cooperative
Urban Habitat
Urban Land Conservancy
Urban Strategies, Inc. (USI)
Urban Sustainability Directors Network (USDN)
US Green Bank 50
Vacant and Abandoned Property Action Council
Vianey Gibbons Consulting
Waco Habitat for Humanity
Walker Montgomery C.D.C.
Washingtonians for Public Banking
WE ACT for Environmental Justice
West Community Economic Development Corporation
West Oakland Job Resource Center
Westside Neighbors United
Wildlings Conservatory
Women’s Economic Ventures
Women’s Resource Network (WRN)
Womxnwise
Working Solutions CDFI & Main Street Launch 1DROP
