The Greenlining Institute appreciates this opportunity to comment on the Interagency Notice of Proposed Rulemaking (NPR) by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Federal Reserve Board regarding the Community Reinvestment Act (CRA). The Greenlining Institute and our coalition submit this letter in support of strengthening the Community Reinvestment Act and realizing the promise of the CRA serving the needs of communities of color and addressing the lasting impacts of historic and modern redlining. The Community Reinvestment Act has been an effective tool in driving reinvestment in low-income communities, but we know that more must be done to direct investments to the communities that need it most.

We’re calling on the OCC, Federal Reserve Board, and the FDIC to meaningfully address decades of race-based disinvestment by including explicit race-based language and requiring additional analysis of race within the Proposed Rulemaking of the Community Reinvestment Act. The Community Reinvestment Act must fulfill the initial intent of the law to end the illegal and discriminatory acts of redlining, and its new frotiers, which have most adversely affected communities of color and their opportunities to build wealth, live in healthy places filled with economic opportunity, and are ready to meet the challenges posed by climate change.

To read our full letter, please click here.

If you have any questions about this public comment, or would like to discuss the matter further, please contact Debra Gore-Mann at debra.goremann@greenlining.org.