New rules are being considered which, if implemented, will have a damaging impact on the Community Reinvestment Act (CRA) program.
The rules, which have been proposed by the Comptroller of the Currency and FDIC, are available to review online.
The deadline to submit comments on the rules is Tuesday, October 13 at 11:59pm.
We could encourage all who are able and have experience with the CRA program to submit comments, using personalized experience with the program in data that you can share about the possible impact it has made in your communities where appropriate.
Please be sure to use customized comments.
You can review GOPC's submitted comments below.
The Greater Ohio Policy Center (GOPC) is a nonpartisan, not-for-profit organization operating statewide. We advance strong local economies and community revitalization across Ohio by equipping communities and leaders with place-based research, collaboration, and advocacy. Our vision is a revitalized Ohio.
Through our work, GOPC stewards several peer-learning networks that share information on community revitalization and housing. These networks include leaders from Ohio’s small legacy, or postindustrial, cities; and leaders who finance, build, and champion housing for Ohio’s low and moderate income residents. GOPC also supports Ohio’s community development financial institutions, which provide needed lending to borrowers and projects that otherwise can not access traditional financing.
Our vision of a revitalized Ohio compels us to share our concerns with the proposed Community Reinvestment Act (CRA) rules as outlines in RIN 1557-AF57 and RIN 3064-AG31.
(1) Limits on Reviewed Lenders. We are concerned that by reducing the number of lenders who are subject to the most comprehensive aspects of the rule, this proposal will significantly reduce the investment capacity of proven supply-side housing strategies. Communities throughout Ohio utilize a number of investment tools, including the federal and state Low Income Housing Tax Credit (LIHTC), state Single-Family Housing Tax Credit, and the Welcome Home Ohio (WHO) program, to name just a few.
We are also concerned that faith-based housing providers, who are working to create and advance homeownership opportunities, will access less equity and debt if CRA rules change.
Ultimately, in a state like Ohio where development costs exceed what the market can bear, debt is hard to access and equity investments are often needed. The flexible and diversified approach that financial institutions take to investing in community projects and housing remains a cornerstone to community development financing.
(2) Impediments to Critical Community Development and Housing Services. We believe the proposed rules will impede critically needed housing and community development services, such as self-sufficiency trainings to Ohioans in need. These services are largely delivered by non-for-profits throughout Ohio; restrictions on grants and administrative fees will make it financially difficult to cover the actual costs of those services.
Examples of housing and community development services that could be shuttered if the proposal CRA rules are implemented include:
Technical assistance and education that improves the success and longevity of entrepreneurs and small businesses
Financial Empowerment Centers, which teach Ohioans how to budget, financially plan for the future, and prepare to be responsible homeowners
Preapproved housing plan catalogs that reduce permitting delays and construction costs—a priority in the 21st Century ROAD to Housing Act
Risk tolerant lending to emerging housing types that can provide stable housing and homeownership opportunities to Ohioans, including manufactured homes, Accessory
Dwelling Units, and “missing middle” housing
These initiatives have immense benefit to urban and rural communities throughout Ohio, and they rely on expanded access to credit and the training and expertise needed to successfully utilize credit. The implementation of the new proposed CRA rules risks these, and other needed, initiatives.
Given the recent enactment of the 21st Century ROAD to Housing Act, we believe it would be prudent to delay action on these rules in order to ensure that they do not conflict with new initiatives designed to strengthen access to affordable housing and incentivize place-based work to address the national housing challenge.
GOPC respectfully requests that the proposed rules for the CRA program be suspended or delayed for further consideration and engagement with the concerns we and others have raised.
Thank you for your consideration. We are happy to address these directly with you should you have any questions.