NCSHA Comments on OCC and FDIC Joint CRA Advanced Notice of Proposed Rulemaking
On April 8, NCSHA sent a letter to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) in response to their joint January 9 Advanced Notice of Proposed Rulemaking and Request for Comments on proposed amendments to Community Reinvestment Act regulations. This letter raises several concerns with the proposed regulations and argues that the final regulations must encourage banks to invest in Housing Credits, Housing Bonds, and HFA mortgage-backed securities; maintain a separate investment test; drive significantly more investment and other banking activity into rural areas; and eliminate the proposed regulationsā āsingle-ratioā approach.
