On behalf of Americans for Financial Reform Education Fund, The Greenlining Institute, Public Citizen, and the 88 undersigned organizations with missions to further financial inclusion, affordable housing, and racial and climate justice, we appreciate the opportunity to comment on the above referenced joint Notice of Proposed Rulemaking (“NPR” or “proposal”) by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively “the agencies”) to amend the regulations implementing the Community Reinvestment Act of 1977 (CRA), including updates to CRA activities qualify for consideration, and how those activities are evaluated and inform bank ratings.
This thoughtful proposal would provide additional opportunities for investment that communities have been seeking, including opportunities to build climate resiliency, in addition to providing greater clarity and consistency for all stakeholders involved. The agencies should strengthen the regulations to better ensure that communities most impacted by redlining and environmental injustice receive the intended benefits of the CRA. Communities of color should explicitly be prioritized for investment, alongside low- and moderate-income (LMI) communities. Additionally, the final rule should further define activities eligible for CRA credit and properly incentivize banks to reduce their contributions to climate risk.
To read our full comment letter, please click here.