ACTION Campaign Comments on CRA
On August 5, 2022, the ACTION Campaign, led by NCSHA and Enterprise Community Partners, submitted comments to the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Federal Reserve System on the joint notice of proposed rulemaking to strengthen and modernize the regulation of the Community Reinvestment Act (CRA).
The comments recommended that the Board, FDIC, and OCC take care not to undermine the flow of CRA-motivated equity investment that forms the base of the capital stack for affordable housing upon which millions of families rely. Further, they urged banking regulators to “name equity investment in the Housing Credit as a positive impact review factor for the community development test, given that state and local allocating agencies distribute Housing Credits through a highly competitive process to only the most impactful properties that best address the state or localityโs affordable housing needs.” ACTION also called for equal weighting of the retail and community development tests, rather than the 60/40 retail/community development weighting currently proposed.
