Comments to the Office of the Comptroller of the Currency (#OCC-2018-0008) and the Federal Deposit Insurance Corporation (RIN #3064-AF22)
OUR POSITION
The federal government has proposed several changes to the CRA, representing the first major changes to the law in many years. We argue some changes may cause unintended adverse consequences for community economic development. We recommend several changes to ensure the regulatory intent of the Act is maintained. Additionally, we support several changes related to the treatment of CDFIs and data transparency.
WHY THIS MATTERS
Regulatory incentives created by the Community Reinvestment Act are a key driver of development activity across the financial sector and affiliated industries. Changes to these incentives will have immediate and potentially negative consequences to communities. Though there are valid reasons to update the regulations, we believe a careful approach is required to avoid unintended consequences.
VIEW CSBDF’S FULL PUBLIC COMMENT:
SUGGESTED CITATION:
Carolina Small Business Development Fund. 2020. “Comments on Community Reinvestment Act Regulations Proposed Rule.” https://carolinasmallbusiness.org/publications/comment-cra-rulemaking/.