SAHF Offers Comments on the CRA Joint Notice of Proposed Rulemaking
August 05, 2022
Stewards of Affordable Housing for the Future (SAHF) appreciate the opportunity to provide comments on the Community Reinvestment Act (CRA) Joint Notice of Proposed Rulemaking (NPR) issued by the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC).
SAHF and its members appreciate the agencies’ goal to modernize the CRA regulations to increase equitable access to banking services, including credit, for low and moderate income (LMI) communities and to adapt to the many structural and technological changes that have occurred in the banking industry in the two and half decades since CRA regulations were updated.
This letter provides comments and recommendations to strengthen the CRA framework, and generally focuses on the NPR sections/questions relevant to Community Development investments, and especially to affordable housing. SAHF strongly believes that CRA regulations must do more to maximize statutory intent and the opportunity this rulemaking affords to address racial inequity and close the racial wealth gap. The NPR acknowledges that CRA was passed in response to redlining however, the NPR does not propose taking race into account for the purpose of a CRA review.
In this letter, SAHF offers several recommendations to the agencies. To review the list of recommendations in it's entirety, access the full letter below.