Take Action Now and Comment on Proposed Rule Changes to CRA

Following up on our previous updates and preparation, we now have the materials you will need to complete your comment letters to the FDIC and OCC regarding the proposed rule changes to the Community Reinvestment Act. Through our work as part of the ACTION Campaigns CRA working group, we have included talking points you may use to draft an original letter, as well as a sample comment letter you may use, plugging in your relevant information about your experience with investments and financing by financial institutions satisfying their CRA obligations. Please submit your comment letter on your letterhead. 

The letter and talking points focus on the key points we believe are relevant to the changes the regulators are proposing for financial institutions and how those changes would affect affordable housing investment, financing, and production. Comments to the regulators are due October 13th and may be submitted using this link. 

In addition to your comment letter, we have previously asked you to consider signing onto a letter to the regulators from the National Association of Affordable Housing Lenders. The Housing Advisory Group has signed onto this letter, and we encourage you to do the same. The deadline to sign on to this letter is October 6th. 

As we have outlined in our previous updates on the CRA rulemaking, reclassifying banks with assets ranging from $1.649 billion to $10 billion as intermediate banks rather than large banks subject to the full CRA examination, including the investment test, could reduce competition in the Housing Credit equity market, leading to lower pricing on credits and less housing produced. These changes could have an even more dire effect in rural areas, where the number of banks required to meet CRA requirements may shrink significantly. 

We are here to answer any questions you may have, and we thank you for your attention to this important request. At a time when we are making strides in addressing the housing crisis, this proposed rulemaking is a significant step in the wrong direction. Regulators need a strong response from our industry emphasizing the negative impact this would have on affordable housing production. 

Thank you.