Under the current federal administration, the Community Reinvestment Act (CRA) continues to be under attack. The biggest challenge to equitable access to capital in decades has just begun.
We have 62 days to act, starting now.
The Office of the Comptroller of the Currency (OCC) opened comment on an advanced notice of proposed rule-making (ANPR) for “modernizing” CRA. The notice, which you can find here, solicits comments on nearly three dozen questions that could fundamentally alter how CRA functions. The OCC’s questions show a clear interest in making it easier for the banks to pass CRA exams AND inflate scores, leaving the very communities it is supposed to protect open to regulator-sanctioned redlining.
Reforming CRA must not become a pretext for relaxing CRA. Here are four principles PCRG believes CRA should include for a modern CRA:
1) Don’t strip ‘community’ out of a law that’s supposed to strengthen communities.
2) Protect communities of color with explicit language against racial discrimination.
3) Keep all lenders accountable.
4) Set a clearly-defined CRA grading system.
Interested in learning more information or joining the fight to #TreasureCRA? Contact Alix Levy at email@example.com to get involved or learn more about PCRG’s local advocacy work. Here are some additional resources for more educational information on CRA, articles covering CRA reform, and sample social media language to use for promoting this issue to your networks — stay tuned for more to come on this critically important topic:
Access and customize your own comment letter here, using PCRG’s CRA Template Letter: https://docs.google.com/document/d/1ixkXTJIvLEdF2AmkjEWWEb_4_fexEjneXqBQ2zAe0-E/edit?usp=sharing