New York Housing Conference submitted comments last week to the Federal Reserve Board about their proposed rulemaking and reforms to the Community Reinvestment Act.
New York Housing Conference appreciates the Federal Reserve Board’s interest in strengthening the CRA so that banks can better meet the credit needs of low- and moderate-income communities and communities of color and we support their efforts to align the CRA regulations among all three regulators.
Overall, we believe that any CRA modernization must address the following basic principles:
- Increase investment in communities that are currently underserved
- Benefit more low- and moderate-income households, particularly minority households, who live in those communities
- Ensure CRA lending and investment does not lead to displacement of the very people it is intended to serve
- Community input must be woven into the CRA process at all levels
- Make both bank performance and government enforcement more transparent and predictable
Our comments reflect our belief that the CRA should incentivize high-quality, responsive, impactful activities and downgrade for displacement and harm. You can see our full comments here.
If you are looking to learn, you can watch our Winter Thought Leader Series, moderated by Matthew Singh, Vice President of Commercial Real Estate at TD Bank with panelists Mark Willis, Senior Policy Fellow at the NYU Furman, and Jaime Weisberg, Senior Campaign Analyst at ANHD, discussed the CRA reforms. See more here.