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CRA Public Comments Due April 8th

Nate Coffman March 30, 2020
Ohio CDC Association
The Community Reinvestment Act (CRA) was passed by Congress in 1977 as a response to redlining and lending discrimination. One would think that a nationwide pandemic would cause the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) to halt the rulemaking process. That unfortunately is not the case. 

Public comments remain due April 8th. Your voice is urgently needed to go on the record in opposition to this harmful proposal that would:
  • Allow banks to receive 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.
  • Create a modern-day form of redlining by allowing banks to choose which of its assessment areas to serve and which to ignore.
  • Have banks held accountable to a ratio instead of their communities. Washington will now decide your community's needs, instead of you.
  • Run counter to the intent of CRA and reduce community investment. A modest 10% decrease in CRA lending would cause Ohio to realize a loss of $1 billion in LMI mortgage and small business lending over five years.
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 the Op-Ed from members in the Cincinnati Enquirer, New York Times editorial, Jesse Van Tol's Op-Ed in The Hill, and my Op-Ed in the Columbus Dispatch and the Ohio Doorsteps podcast.

Public comment (April 8 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
Executive Director
Ohio CDC Association
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