WASHINGTON, D.C. – In response to the proposed Community Reinvestment Act rules released today by the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, National Housing Conference President and CEO David M. Dworkin has issued the following statement:
“There is no question that CRA needs to be modernized, but the proposed approach is the wrong way to do it. After more than a year of consideration and 1,500 comment letters, the OCC and FDIC have come up with a formula-driven approach that almost nobody in the housing community supports and is rife with millions of dollars in hidden costs and enormous unintended consequences. This is a missed opportunity,” said Dworkin.
Dworkin continued: “The National Housing Conference and its members look forward to working with FDIC, OCC and the Federal Reserve board to establish final rules that meet the needs of a 21st century banking system, improve clarity, and increase the availability of banking services, investments and lending to underserved communities and people.”
Among the National Housing Conference’s concerns with the FDIC/OCC approach:
- A ratio-driven approach is too simplistic. “CRA can’t be done with elementary school math,” Dworkin said. “We need rules that both accommodate the diverse needs of our underserved communities yet are transparent so that financial institutions understand what counts and what does not.”
- There’s no common ground among the three major federal banking regulators. “The OCC and FDIC squandered an opportunity to propose CRA reform that achieves bipartisan consensus,” Dworkin said. “We are hopeful the Fed will do this when it issues its own CRA reform proposal.”
- A proposed 60-day comment period that overlaps four federal holidays is a clear attempt to minimize public input. “We call upon the FDIC and OCC to give stakeholders 120 days to comment,” Dworkin said. “Anything this important requires careful consideration and time to prepare detailed and thoughtful recommendations.”
The National Housing Conference represents the broadest array of stakeholders in housing finance, policy, advocacy and community development. NHC and its members have been engaged with CRA reform over the last year. “We worked closely with all three regulators to find reasonable compromise and look forward to working with them to get this critical regulation right.”
About NHC: The National Housing Conference has been defending the American Home since 1931. Everyone in America should have equal opportunity to live in a quality, affordable home in a thriving community. NHC convenes and collaborates with our diverse membership and the broader housing and community development sectors to advance our policy, research and communications initiatives to effect positive change at the federal, state and local levels. Politically diverse and nonpartisan, NHC is a 501(c)3 nonprofit organization.