Comments on CRA reform are due this Friday, August 5, at 11:59 pm ET!

I want to thank these additional members and allies for sending in comments (if I missed you, let me know...not all comments have been posted yet by the agencies): 

• Lower Marshall Shadeland Development Initiative
• Greater Ohio Policy Center 
• Veteran's Center of Greater Atlanta 
• Healthy Communities Delaware 
• Oasis Center 
• Brooklyn Neighborhood Association 
• Tule River Economic Development Corporations 

Organizations working on comment letters include (and a number of these are coalitions): 

• Metropolitan Milwaukee Fair Housing Council 
• Americans for Financial Reform Education Fund 
• The Greenlining Institute 
• Public Citizen 
• Natural Resources Defense Council (NRDC) 
• Child Care Aware of America 
• Prosperity Now! 
• Woodstock Institute 
• California Reinvestment Coalition 
• Association for Neighborhood and Housing Development 
• California Housing Partnership 
• UnidosUS 
• Pittsburgh Community Reinvestment Group (PCRG) 
• Housing Assistance Council  
• Opportunity Finance Now 
• Coastal Enterprises Inc.  
• NACEDA 
• National NeighborWorks Association 
• Georgia ACT and SCACED 
• Poverty and Race Research Action Council 
• National People’s Action 
• Chicago Community Loan Fund 
• Center for Community Progress 
• Ceres 
• AARP 
• Devotion USA 
• Manna, Inc.  
• Pacific Community Ventures 
• Main Street Alliance 

So far the "pro" comments outweigh the "con" comments, but we have to keep our comments flowing! 

These could be the most consequential changes to CRA in my 27 years of doing this. Let's make this one count!  

• We need the agencies to make significant improvements, particularly in the area of CRA and race where they largely punted.  

• Let's stop the proposed changes to about 20% of the bank CRA exams that would make those exams easier and reduce the level of community development financing in smaller cities and rural areas!  

• Let's preserve the proposed improvements to data collection and assessment areas so online or hybrid banks have most of their loans covered by CRA exams. Let's also make sure that the agencies do not backpedal on their proposals to combat CRA ratings inflation.

Sample comments including one for health care practitioners:  https://www.ncrc.org/treasureCRA/ 

The Treasure CRA website also has data tools to calculate the number of CRA dollars in local communities over the last decade. If you are a NCRC member, you can also access our fair lending tool to identify racial disparities that CRA reform must address in your community.  

Continue writing and commenting! Let us know if you have any questions.  

Josh Silver