The Housing Assistance Council submitted comments to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) on their proposal to modernize the Community Reinvestment Act.
For numerous reasons, The Housing Assistance Council does not support the OCC and FDIC’s proposal. HAC appreciates efforts and ideas in the plan to improve CRA’s reach and effectiveness in rural communities. These proposed improvements, however, are far outweighed by a considerable number of ill-conceived and unsubstantiated aspects of the plan that run counter to the intent, value, and effectiveness of CRA. Furthermore, the Housing Assistance Council is disappointed that the OCC and FDIC did not include the Federal Reserve as part of this proposal. Uniform implementation and oversight is critical for an effort as far reaching and important as CRA. Additionally, with the health and economic catastrophe created by the COVID-19 pandemic, there should be an indefinite suspension of the CRA comment period. The comment period deadline, which was initially proposed for only 60 days, should have been at least 120 days even under the best of circumstances.
The Housing Assistance Council unequivocally supports the Community Reinvestment Act and what it stands for. In any effort to modernize or modify CRA, it is imperative to fully consider the impact of those modifications and to ensure that CRA continues to build upon its unparalleled legacy of expanding access to financial products and services. HAC believes CRA can be modernized and improved, but it is important to acknowledge that CRA has been responsible for more than $1.5 trillion in capital investments to underserved communities. Without CRA, many communities would lack access to capital, revitalization efforts would have not occurred, and disinvestment would be more common. CRA should build upon its established platform for improving communities’ access to credit, not jeopardize the ethos, intent, and effectiveness of this vital institution.