SAHF Comments on OCC's Proposed Changes to Community Reinvestment Act
SAHF provided comments to the Office of Comptroller of the Currency's (OCC) proposed amendments to the Community Reinvestment Act Regulatory framework. We appreciate OCC's desire to modernize the Regulations so that regulated financial institutions are better able to serve the convenience and needs of their communities. As mission-driven nonprofits with decades of experience investing in and transforming communities through the development and preservation of affordable housing, SAHF members have witnessed the vital role that a strong Community Reinvestment Act (CRA or the Act) plays in attracting investment and lending to low and moderate income (LMI) communities and connecting the LMI people who live there to stable homes and economic opportunity. Efforts to modernize CRA should seek to provide clarity and predictability in the evaluation process, but in doing so must also prioritize meeting the needs of LMI people and communities.