Dear Friend,

Two of the most important housing policy developments this year will be efforts to modernize the Community Reinvestment Act of 1977 (CRA) and the development of regulations and guidance from the Internal Revenue Service on the implementation of the Opportunity Zones, both of which we have discussed in previous Member Briefs. Rather than tell you what we think, NHC needs your thoughts on how we should think about these issues.

There is broad bipartisan support for CRA modernization that makes it easier to comply with the law. A recent letter from Democratic members of Congress to the banking regulators responsible for CRA makes that clear. I am optimistic that we will ultimately see significant improvements in the timeliness of CRA evaluations, consistency of CRA findings and clarity on what kinds of investments and activities should count towards CRA ratings. But the “elephant in the room” is the future of branch banking and how it relates to CRA compliance. Branch banking was central to the evolution of CRA. Since 1977, we have seen the rise of interstate banking, automated teller machines, smartphone banking applications and a host of other new technologies that are being developed as we speak. The question of what is the future of branch banking and CRA in the 21 ^st century is the big issue that we have a once-in-a-generation opportunity to answer. How reliant should we be on geography in a world of online deposits? Are there more cost-effective ways to reach consumers than through traditional branches? How do we differentiate between the CRA requirements of large banks that take deposits from across the country and small banks that may still look much like they did in 1977? Are branches more important in community development lending and investment than in mortgage lending? Will they still be ten years from now? Please share your thoughts on this with me at davidmdworkin@nhc.org. I am interested in what you think!

In the case of Opportunity Zones, we are on the leading edge of an entirely new program. Treasury staff has made clear they want to minimize the regulatory burden to ensure the maximum amount of investment dollars is committed. But the law allows Treasury to draft regulations to minimize abuse. I can’t think of a worse scenario than a great new program being destroyed by abuse of a few bad actors, but it wouldn’t be the first time. Just as frustrating would be a draconian set of regulations that inhibit private capital from being invested. There has to be a balance. At NHC, our Opportunity Zones Task Force is seeking to draft thoughtful regulatory language for Treasury to consider that would help prevent abuse while keeping the program as streamlined as it is intended to be. We are very interested in your specific thoughts about this. What are the opportunities for abuse, and based on your experience, how would you address them? NHC’s members are our single most important asset, so your thoughts on this are incredibly valuable.

Finally, NHC’s 46^th Annual Housing Visionary Award Gala is just two weeks away. We are planning an evening to remember, with a delicious plated dinner, music by The Alternate Routes and plenty of time to network with your colleagues in housing and beyond. There is still time for you to join our many generous members and sponsors in recognizing our honorees with a tribute in the program book, or by sponsoring the event. Contact us today to learn more about how to support NHC’s efforts to defend the American Home.

Sincerely,