The Housing Credit and the Community Reinvestment Act

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC), two of the three federal banking regulators, recently published a Notice of Proposed Rulemaking (NPR) that would change their current rules that implement the Community Reinvestment Act (CRA).

The proposed rule would revise the asset thresholds that determine how CRA is applied to different banks based on the amount of their assets, cap the amount of grant money going to overhead that banks give to local nonprofits at 15 percent, and make other changes. CRA drives around 80 percent of annual Housing Credit investments. Changes such as what the regulators are now considering threaten to disrupt the Housing Credit equity market and reduce investment in our nation’s most important tool for the production and preservation of affordable rental housing.

Get Involved:

• Use ACTION’s talking points to make the case to policy makers that the CRA proposal under consideration would reduce equity investments in Housing Credit properties. Make sure you’re raising your concerns with members of your congressional delegation.
• Log your concerns with the OCC and FDIC by submitting a comment letter on behalf of your organization. ACTION has drafted a template letter that you can use and adjust to meet your needs.
• Join organizations and businesses from across the country by signing onto this national comment letter organized by the National Association of Affordable Housing Lenders (one of ACTION’s Steering Committee members) by Tuesday, October 6.