Public Comment Community Reinvestment Act April 8, 2020 Comment Letter
Laurie Goodman, Ellen Seidman, Jun Zhu
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This comment letter responds to the December 12, 2019, Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation jointly issued notice of proposed rulemaking proposing to significantly change regulations under the Community Reinvestment Act (CRA). The researchers note that while the proposal is a useful starting point for discussion, it needs substantial revision, warranting a new proposal. They applaud the agencies for recognizing the need for CRA modernization and more objective ways to measure how much banks are doing for their communities, and agree that a bank’s ability to confirm whether an activity will count before committing to an investment is a welcome improvement. But the proposal has significant weaknesses and many unknowns, which must be addressed.

Research Areas Economic mobility and inequality Wealth and financial well-being Social safety net Race and equity Housing finance Housing
Tags Federal housing programs and policies Asset and debts Racial and ethnic disparities Single-family finance Financial products and services Wealth inequality Public and private investment Inequality and mobility Opportunity and ownership Finance Racial barriers to accessing the safety net Racial inequities in economic mobility Financial stability
Policy Centers Housing Finance Policy Center