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