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Action Alert: Comments for CRA Reform

February 14, 2020
Ohio CDC Association
The Community Reinvestment Act (CRA) was passed by Congress in 1977 as a response to redlining and lending discrimination. Since 1996, banks have issued $2 trillion in community development loans and investments in low- and moderate-income (LMI) communities. 

Recently the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released a Notice of Proposed Rulemaking (NPR) to "reform" the CRA. Former FDIC chair and current board member Martin Gruenberg explained succinctly that it's a "deeply misconceived proposal that would fundamentally undermine and weaken the CRA."

Why is this "reform" misconceived:
  • Banks could get CRA credit for investments in sports stadiums, roads, bridges, and other infrastructure projects that are disconnected from CRA's purpose of ending redlining and supporting disinvested people and places.
  • A modern-day form of redlining could be an unintended consequence by allowing banks to choose which of its assessment areas to serve and which to ignore.
  • Banks would be held accountable to a ratio instead of their communities.
  • By proposing a list of CRA-eligible activities, Washington will now decide your community's needs, instead of you.

There is real fear that the net effect will decrease lending and access to capital in the communities that need it the most. A modest 10% decrease in CRA lending would cause Ohio to realize a loss of $975 million in LMI mortgage and small business lending over five years. That's nearly $1 billion for every 10% decrease in CRA lending.

CRA works. We need to modernize CRA - not weaken it!
OCDCA urges every member to submit a public comment that's customized to your organization. Here are some helpful templates, but supplementing with your own voice is important.
For additional summary information read this article from NACEDA's Frank Woodruff or my opinion piece.

Public comment (March 9 deadline) is critical in building the case against the proposed changes. Tell the OCC and FDIC that any changes to CRA should strengthen it and live up to the spirit and intent of the act - ensuring that LMI communities and communities of color have equal access to capital and credit.

Please take the time to make your voice heard.

If you have any questions please contact me at or 614-461-6392 ex. 207.

Thank you for your advocacy!

Nate Coffman
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