Community Reinvestment Act 

NACEDA Comment Letter to Reform CRA

The Community Reinvestment Act (CRA) shapes how financial institutions behave in low- and moderate-income communities and how they deploy resources through the community development industry. NACEDA submitted comment letter on August 5, 2022 in response to a Notice of Public Rulemaking from the federal agencies that regulate CRA -- the Federal Reserve, OCC, and FDIC. We also supported numerous NACEDA members and partners in crafting their letters. Changes to CRA regulations will chart the community development sector's course for a generation or more

Focus Areas  
NACEDA used 7 lenses to examine the proposed rule in our comment letter. We paid careful attention to how the rule:

  1. addresses race and equity as part of the exam process,
  2. changes assessment areas and the impact on community developers' ability to attract resources and capital
  3. balances stakeholders' desire for objective with communities' need to for local control and impact,
  4. clarifies and strengthens the role of community-based development organizations,
  5. impacts community development resources flowing through financial institution,
  6. establishes new structures for public data collection, particularly as it relates to community development finance,
  7. empowers communities and regulators to engage with each other as a new rule is finalized and implemented.