Comments on Federal Reserve Board's ANPR to Modernize the CRA

On February 16, Enterprise submitted comments to the Federal Reserve Board (Board) on its advance notice of proposed rulemaking (ANPR) to modernize regulations implementing the Community Reinvestment Act (CRA). The CRA helps low- and moderate- income (LMI) communities gain access to financial services, loans, and community development investments that would otherwise be unavailable. It has been an important driver of financial institution investment in the Low-Income Housing Tax Credit, the New Markets Tax Credit, and Community Development Financial Institutions. Enterprise provided a number of recommendations, including how best to evaluate a bank’s community development activity and encourage affordable housing development. Enterprise also commended the Board for its emphasis on addressing discrimination and redlining as central to the purpose of the CRA and urged the Fed to join together with the other two banking regulators – the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) – to establish one, final CRA rule.