This letter submitted with our partners comments on the needs to update regulations that significantly affect whether banks respond to the financial needs of low income communities and communities of color. We understand the EGRPRA process creates the opportunity to identify regulations that need to be updated and modernized in order to best meet their original purpose and intent. However, we are concerned that the agencies will lean toward eliminating regulations considered outdated, unnecessary or unduly burdensome, rather than updating them to reflect current needs and realities.
community reinvestment act
This letter to the Federal Reserve and the Office of the Comptroller of the Currency comments on the proposed merger between CIT Group and OneWest Bank. The merger highlights several issues that should be addressed before completed. The first issue is that the merger would create a Systematically Important Financial Institution. The second issue is that both banks lack a strong history in community reinvestment. OneWest Bank received a “low satisfactory” rating from the Community Reinvestment Act and CIT Group invests primarily in communities near its headquarters.
Register for a briefing on CRA Q&A updates
We have an opportunity today to let bank regulators know that it’s high time to update CRA for the modern era in a way that does not discourage banks from providing needed branches and in-person services. Federal regulators have released proposed changes to the Interagency Questions & Answers (Q&A), some of the documents that guide banks in implementing CRA. We have until November 10, 2014, to submit comments on the proposed changes.
The report, A UK Banking Disclosure Act: From theory to practice, uses the experiences of Community Reinvestment Act (CRA) and Home Mortgage Disclosure Act (HMDA) in the US to assess the major benefits—and risks—involved in requiring bank transparency.
While US advocates have for decades used detailed reporting data from banks to advance community investment goals, current reporting requirements for UK banks are less detailed:
The regulators released proposed changes to their documents that implement CRA (called Interagency Questions and Answers).
We have until May 17 to comment on these proposed changes and let regulators know that they don’t go far enough, so please act today!
Your comments matter. Regulators will be hearing from legions of bank representatives, and we need to make sure that they hear from advocates as well. Here is a sample comment letter that we encourage you to personalize and send to regulators:
We need to update CRA to reflect the realities of the modern banking era. Instead of branch-based banking, many transactions take place online or through networks of brokers. CRA must be changed so that banks have community responsibilities wherever they do business, not just wherever they have branches. And we need stronger ways to hold banks accountable for providing important services--such as affordable checking accounts--to low-income communities.