Read the Full Comment Letter

Monica Palmeira

Associate Director of Economic Equity

Read Bio

×

Monica Palmeira

Associate Director of Economic Equity

Monica Palmeira (she/her/hers) was raised in Eastern North Carolina as a first-generation American in a Portuguese family. Her professional background includes ethnographic research, affordable housing advocacy, climate policy, and community engagement. Prior to joining Greenlining, Monica most recently held positions at the California Public Utilities Commission leading environmental justice initiatives, as well as at the California Governor’s Office of Planning and Research – Strategic Growth Council where she spearheaded various outreach and technical assistance programs to support communities in accessing climate-related funding programs. She received a B.A. in International Studies and Public Policy from the University of North Carolina at Chapel Hill and a Master’s in Public Administration from the University of Southern California. In her free time, Monica loves spending time with her young son, visiting family back in Portugal, and rediscovering her home state.

Policy Staff Transformative Communities

Rami Ibrahim

Program Manager for Economic Equity

Read Bio

×

Rami Ibrahim

Program Manager for Economic Equity

Rami Ibrahim (he/him/his) is the Economic Equity Coordinator team, supporting The Greenlining Institute’s vision of economic investment among communities of color and holding financial institutions accountable. As a second-generation Palestinian American, Rami is passionate about ending U.S. destabilization of our homelands and centering refugee and immigrant communities in policies surrounding economic, climate, housing, and health justice. Prior to joining Greenlining, he conducted research pertaining to refugee resettlement and engaged San Diego refugee and immigrant communities in State, County, and City redistricting processes. Rami was born and raised in San Diego, California and received a B.A. in Political Science from UC San Diego. His dream is to continue fighting in coalition with Palestinian youth and elders and marginalized communities throughout the world for our collective liberation.

Economic Equity Policy Staff

On October 13, 2026, The Greenlining Institute submitted comments opposing the Proposed Rule from the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) to amend the regulations implementing the Community Reinvestment Act (CRA).

The CRA rests on an important principle: banks must meet the credit needs of the communities where they do business, including low- and moderate-income (LMI) communities. Congress enacted the CRA in 1977 because banks systematically denied services and investment to Black communities and other communities of color through redlining. Nearly 50 years later, the harms of redlining have persisted and evolved.

The Proposed Rule would drastically reduce the number of banks subject to CRA scrutiny, narrow bank examinations, reduce transparency, greatly erode access to capital, and undermine support for community organizations. By the agencies’ own estimate, approximately 79.8% of banks subject to the CRA would be classified as small, leaving more than three quarters of covered banks without any Community Development Test. These changes are not simple adjustments. They represent a wholesale retreat from the CRA’s founding promise.

Community reinvestment is necessary accountability grounded in documented history and ongoing disparities. It is not a political favor, a handout, or an unjustified burden on banks.

Greenlining urges the OCC and FDIC to withdraw the Proposed Rule, return to the 1995 CRA regulatory framework, and:

• Protect CRA oversight: Maintain meaningful examinations and community development requirements for banks of all sizes.
• Preserve community reinvestment: Protect incentives for affordable housing, CDFIs, small businesses, disaster recovery, and other community development investments.
• Support community organizations: Reject restrictions on grants that limit flexible funding and capacity building.
• Maintain transparency: Preserve lending data collection and reporting so communities can identify gaps and hold banks accountable.
• Ensure consistent standards: Coordinate with the Federal Reserve to maintain a strong, consistent CRA framework.

Greenlining also led a coalition sign-on letter with community organizations and advocates across the country, including the Center for Responsible Lending, CAMEO Network, The Unity Council, and the Southern California Black Chamber of Commerce. Together, we called on the agencies to withdraw the Proposed Rule and ensure that no changes result in decreased bank lending, investment, and services in underserved communities.

Read Greenlining’s technical comment letter here.
Read the coalition sign-on letter here.

Rami Ibrahim

Program Manager for Economic Equity

Read Bio