Unlike the Office of the Comptroller of the Currency's (OCC) CRA approach, NCRC believes the Fed's approach is a good first step. However, especially now with the Biden Administration at the helm, we will be seeking more rigor in some of the performance measures to ensure that CRA ratings will not be as inflated as they are today. These changes are essential in ensuring that CRA exams leverage more lending, investing and services for communities of color and low- and moderate-income communities.

If you would like to comment, NCRC's sample comment letters are on its #TreasureCRA page. On the page, under the "take action" tab, you will find both a long and a short version of the comment letter, which you can copy and edit as you see fit to submit to the Fed. You can find instructions on how to submit comments on the page as well. Please feel free to forward our sample comment letters and the link to our #TreasureCRA page to everyone in your network and encourage them to submit comments. 

If you have any questions about the comment letter or submitting a comment, feel free to contact Joe Reed at [email protected].