Washington, D.C. - Congressional Progressive Caucus Co-Chairs Mark Pocan (WI-02) and Raúl M. Grijalva (AZ-03), joined Financial Services Committee members Carolyn B. Maloney (NY-12) and Nydia M. Velázquez (NY-7) to express concern with a number of suggested changes in the Advanced Notice of Proposed Rulemaking (ANPR).
Read the full letter below:
November 19, 2018
Dear Comptroller Otting:
We write to share our views on the Office of the Comptroller of the Currency’s proposed rulemaking of the Community Reinvestment Act (CRA) and to express our concerns with a number of the suggested changes and proposals outlined in the Advanced Notice of Proposed Rulemaking (ANPR).
Historic discrimination in access to credit has had a disastrous impact on low-income households and communities of color. By lowering hurdles and expanding access to equitable financing for targeted communities across the country, the CRA is a proven tool to reduce discriminatory credit practices in low-income neighborhoods, known as redlining. For this reason, we oppose any policy changes that would undermine the intent and purpose of the CRA and we urge regulators to ensure any regulatory changes uphold the intended goal of expanding lending access for these communities.
Specifically, we are concerned that many of the questions included in the ANPR would open the door for disastrous changes to the CRA, jeopardizing the progress made for these communities and threatening their future economic success. Along these lines, we oppose any new rulemaking that:
- Removes or weakens the prioritization of lending to low- and moderate-income (LMI) individuals.
- Restricts evaluation of bank lending practices and their investments in the underserved communities where they have a physical or significant digital footprint.
- Relaxing the metrics used to determine bank compliance with CRA standards, including reliance on a “one ratio”approach or other efforts that weaken qualitative analysis of lending practices in favor of rigid quantitative approaches.
- Weakens the rigor of existing CRA exams and amends the asset-size thresholds in a way that exempts additional institutions from the CRA’s community development financing or service examinations.
- Removes opportunities for local stakeholders to provide feedback on financial institution consolidation or when evaluating whether a lender is appropriately serving their local community.
- Occurs without the full participation of other relevant regulators/agencies in the rulemaking process, including the FDIC and the Federal Reserve.
While we strongly oppose efforts to weaken the CRA, we support modernization of the law to more fully realize the law’s goals and meeting the needs of underserved communities. Advancements in technology and a changing economic landscape have made it clear that the CRA is in need of modernization to fulfill the intent of the law for the 21st century. Instead of weakening the law, we encourage you to pursue policy options that would increase credit and banking opportunities to LMI families and expand investment in business activities that serve these communities. Further, we strongly support increased enforcement actions against financial institutions that violate their obligations under the CRA.
The Community Reinvestment Act is critical to the equitable access to credit for millions of historically underserved individuals, and communities across the country depend on CRA requirements to jumpstart economic opportunity. We strongly urge you to preserve and expand the benefits of the CRA rather than take steps to weaken protections for these communities.
Thank you for your prompt attention to this matter.
Sincerely,
Mark Pocan Raúl M. Grijalva
Member of Congress Member of Congress
Carolyn B. Maloney Nydia M. Velázquez
Member of Congress Member of Congress
