Groups send Community Reinvestment Act reform letter to regulators

Groups send Community Reinvestment Act reform letter to regulators
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More than 500 community-based groups send Community Reinvestment Act reform letter to regulators

WASHINGTON, DC — Today, 520 state and national community-based groups called on the three federal bank regulatory agencies that implement the Community Reinvestment Act (CRA) to not include a one-ratio metric in the upcoming proposed CRA rule change.

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In a letter written and submitted by the National Community Reinvestment Coalition (NCRC), the coalition of housing, consumer protection and community development organizations urged the Federal Reserve, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation to drop the idea of a "one-ratio" metric from new CRA rules expected to be proposed by the agencies this fall.

“As we have stated in our comment letters regarding the Advance Notice of Proposed Rulemaking (ANPR), if a metric of this nature is determinative of the Community Reinvestment Act rating either at the assessment area or overall, it will likely distort CRA activity in a way that is not responsive to local needs,” the letter said. “In order to boost the numerator of the ratio, banks will likely favor large dollar community development activity or purchases of mortgage-backed securities (MBS).”

“The one ratio also has the potential to interfere with sound business practices. If empirical benchmarks for passing ratings are set too high during economic downturns, banks could feel pressured to seek large deals when smaller loans or other financial assistance could better support communities and avoid over-leveraging banks. Different agency heads under various administrations could also adjust ratios that promote particular policies but do not take local credit needs into account.”

“A one ratio approach will make Community Reinvestment Act exams less transparent and will deter public input. If the one ratio replaces existing metrics such as percent of loans to low- and moderate-income borrowers or communities, it will be harder for community organizations and members of the public to understand which needs banks are responding to and which ones they are neglecting.”

View the list of signers; read the full letter:

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Jacob Wolinsky is the founder of, a popular value investing and hedge fund focused investment website. Jacob worked as an equity analyst first at a micro-cap focused private equity firm, followed by a stint at a smid cap focused research shop. Jacob lives with his wife and four kids in Passaic NJ. - Email: jacob(at) - Twitter username: JacobWolinsky - Full Disclosure: I do not purchase any equities anymore to avoid even the appearance of a conflict of interest and because at times I may receive grey areas of insider information. I have a few existing holdings from years ago, but I have sold off most of the equities and now only purchase mutual funds and some ETFs. I also own a few grams of Gold and Silver
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