Comments to the Office of the Comptroller of the Currency (Docket ID OCC-2022-002), the Board of Governors of Federal Reserve System (Docket No. R-1769 and RIN 7100-AG29), and the Federal Deposit Insurance Corporation (RIN #3064-AF81)
OUR POSITION
Two federal agencies have joined the nation’s central bank and jointly proposed regulatory changes to the Community Reinvestment Act (CRA). We strongly applaud the agencies for ensuring financial support for CDFIs is recognized as a community development activity for regulated institutions. Concurrently, we have serious reservations that the rule fails to address racial inequities, a major gap in the existing regulatory framework. While the regulations are a good first step, our comments highlight that additional work is needed to realize the CRA’s ambitious policy goals.
WHY THIS MATTERS
As the United States strives to create a more inclusive financial system, the CRA and similar regulations need to be updated. The set of changes outlined by regulators are sweeping and will shape community development practice for decades to come. The proposed framework represents significant improvements over other changes that have been proposed in the past few years. But there are still major gaps that need to be addressed in order to minimize unintended consequences. VIEW CSBDF’S FULL PUBLIC COMMENT:
SUGGESTED CITATION: Carolina Small Business Development Fund. 2022. “Comments on Community Reinvestment Act Joint Notice of Proposed Rulemaking.”