The Bank Policy Institute1 appreciates the opportunity to comment on the advance notice of proposed rulemaking (the “ANPR”) issued by the Board of Governors of the Federal Reserve System soliciting feedback on approaches for building a new framework for the agency’s Community Reinvestment Act (“CRA”) regulations.2
BPI and its members support the longstanding goals of the CRA. This letter provides our views on how the Board should pursue CRA reform efforts that ensure the Act continues to be an effective force for strengthening our members’ entire communities, including low- and moderate-income (“LMI”) individuals and neighborhoods, small businesses, and communities in need of financial services to sustain economic development. Section I of this letter describes the principles that should guide CRA reform initiatives. First among these principles is the need for coordinated, interagency rules that apply evenly to banks regardless of their primary federal regulator. Section II of this letter addresses key elements of the ANPR and provides specific recommendations for the Board to consider as it moves forward in the rulemaking process toward a formal proposal.
1 The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
2 Community Reinvestment Act, 85 Fed. Reg. 66,410 (Oct. 19, 2020).