Comments on the OCC’s and FDIC’s Proposed Changes to the CRA

Enterprise CRA Comment Letter April 2020

On April 8, Enterprise submitted comments on the Office of the Comptroller of the Currency’s (OCC) and Federal Deposit Insurance Corporation’s (FDIC) joint notice of proposed rulemaking to modernize regulations implementing the Community Reinvestment Act (CRA). We strongly urge the two U.S. banking regulators to delay even modest rulemaking on CRA to allow banks and community stakeholders to thoughtfully plan and respond to the current COVID-19 pandemic, as well as find common ground with the third U.S. banking regulator, the Federal Reserve. Should the OCC and FDIC proceed with the present rulemaking, Enterprise offers its comments to reinforce the need for a consistent, transparent regulatory framework that properly gives banks credit for sound community development work. Our comments emphasize the importance of retaining the original purpose of the law: helping low- and moderate-income communities gain access to financial services, loans and community development investments that would otherwise be unavailable; CRA’s importance in providing affordable housing and our strong support for regulations that continue to allow for a robust affordable housing finance system; and the importance of retaining a focus on the community voice in CRA by lifting up local perspectives and needs, specifically through a commitment to performance context.

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