Community Reinvestment Act 

NACEDA advocacy works to ensure the voice of community-based developers is understood and prioritized by the Federal Government. Our voice and memberships’ advocacy around the Community Reinvestment Act (CRA) continues to play an important role in the CRA modernization process and in the process of keeping banks accountable to the community development needs of the communities they serve. Come back to this page often as CRA modernization continues in the months and years ahead.

Regulatory Action

NACEDA Supports OCC Proposal to Rescind Their 2020 CRA Rule
On October 29, 2021, NACEDA submitted a comment letter to the Office of the Comptroller of the Currency (OCC) on their proposal to rescind their own 2020 rule regarding the Community Reinvestment Act (CRA). NACEDA's letter reminds regulators why we were originally opposed to the rule and offers ideas for a community-minded CRA modernization process.

Previous NACEDA regulatory actions:

NACEDA Comments on Federal Reserve Proposed CRA Rule Change
On February 26, 2021, NACEDA submitted comments on the Federal Reserve Board's Advance Notice of Proposed Rulemaking (ANPR) for CRA. The ANPR solicited input on ways to evaluate how banks meet the needs of low- and moderate-income communities. Overall, NACEDA thought the Fed asked the right questions and engaged in a productive dialogue with community development stakeholders. However, we raised the concern that the ANPR did not adequately address how banks are documenting and identifying community development needs and engaging with community stakeholders. NACEDA also opposed the ANPR's proposed a non-exhaustive list of activities eligible for CRA. As our letter states, "Why would a bank participate in months of community planning meetings when they can pick something from a list developed by their regulator?" In addition, NACEDA signed this comment letter urging the Federal Reserve Board to adopt a more race-conscious Community Reinvestment Act.

NACEDA Strongly Opposed 2020 OCC Rule 
On May 20, 2020, the OCC announced a final CRA rule with a list of qualifying activities. The NACEDA network strongly opposed this Trump administration rule because it would redirect billions of dollars in bank loans, investments, and critical financial services away from low- and moderate-income communities and enable redlining. The OCC's rush to push through a rule without the participation of the Federal Reserve and FDIC creates multiple sets of CRA regulations across agencies which are burdensome to community development nonprofits. NACEDA issued this media statement.

NACEDA Comments on Proposed OCC and FDIC Rule 
On April 8, 2020, NACEDA submitted comments to the OCC and FDIC. The comment letter interprets and responds to the proposed rule through the lens of those 4,000 community-based organizations and community development corporations, particularly the smaller and medium-sized organizations that serve the hardest to reach communities. 

NACEDA Network Called for Suspension of Rulemaking During Pandemic
On March 27, 2020, NACEDA and 32 state and regional association for community development submitted a comment letter to the OCC and FDIC. It stated, "Continuing the rulemaking process with an April 8, 2020 comment deadline forces community based organizations to choose between saving lives and livelihoods now and helping to shape the long-term economic opportunities their communities will be able to access for decades to come."

Media Action

Will Federal Regulators Gut Community Development under Cover of COVID? 
Nonprofit Quarterly article cites the NACEDA letter signed by 32 state and regional community development associations to halt the CRA rulemaking process during the pandemic & Frank Woodruff's op-ed explaining why the new rule would be a clear invitation to redlining. | April 8, 2020

Calls to Cease Non-Coronavirus rulemaking grow louder
American Banker article
quotes NACEDA letter signed by 32 state and regional community development associations plus other calls to halt the CRA rulemaking process during the pandemic. | March 31, 2020

Questionable Reforms To A Law Ensuring Banks Do Right By Low-Income Neighborhoods Are Moving Forward Amid The COVID-19 Pandemic
Blavity article features Nate Coffman of the Ohio CDC Association and Bill Faith of Coalition on Homelessness and Housing in Ohio | April 1, 2020

Redlining would be relegalized by CRA reform proposal
Shelterforce article by Frank Woodruff of the National Alliance of Community Economic Development Associations | January 9, 2020

Member Action

Civil rights and housing advocates warn proposed change to federal law could spell the return of redlining 
Cleveland Plain Dealer article featuring Nate Coffman of the Ohio CDC Association, Chris Alvarado of Slavic Village Development and Bill Faith of Coalition on Homelessness and Housing in Ohio | March 2, 2020

Proposed changes would slow progress toward equitable lending in minority communities
MinnPost Op-Ed by Jim Roth of the Metropolitan Consortium of Community Developers, Nasibu Sareva of the African Development Center, and Kathy Wetzel-Mastel of PRG | March 2, 2020

Rule change could allow redlining to resume
The Columbus Dispatch Op-Ed by Nate Coffman of the Ohio CDC Association

Changes to Community Reinvestment Act will return us to redlining
Houston Chronicle Op-Ed
by Lori Pampilo Harris of the Houston Housing Collaborative | February 3, 2020

Fearing proposed changes to community lending regulations would re-legalize redlining
NJ Spotlight Op-Ed
by Staci Berger of Housing and Community Development Network of New Jersey and John Restrepo of Garden State Episcopal Community Development Corporation | January 28, 2020