History of CRA CRA, a landmark civil rights law passed in 1977 as a response to redlining. CRA is a critical tool for ensuring banks meet the credit of needs of low- and moderate-income people in the communities they serve. Since 2016 banks have pledged more than $84 billion in lending and philanthropy.

CRA in NJ In NJ, Housing & Community Development Network of NJ along with NJ Citizen Action has negotiated CRA agreements with more than 40 financial institutions. These agreements have resulted in over $40B in commitments to low- and moderate-income (LMI) communities across the state in below-market rate mortgages, discounted home improvement loans, affordable consumer lending products, construction & permanent financing for nonprofit affordable housing developers, and small business loans for women & minority-owned businesses.

ANPR Summary Advanced Notice of Proposed Rulemaking Undertaken by one of three regulators Oriented toward easing compliance for currently regulated banks “One-ratio” Feedback requested from commercial lenders Responses due by November 19

NACEDA’s Critique Should not be undertaken by a lone regulator “One-ratio” approach is fundamentally flawed/undermines assessment areas $50b - $100b in decreased investment over 5 years. $1b - $3b loss in New Jersey Does not consider other institutions Fails to incorporate fair lending/housing considerations in a CRA rating

Three-pronged Response Strategy Respond prudently to the ANPR with your own letter, volume matters Importance of the Federal Reserve Banks Advocacy to banking partners

This presentation will be available at: www. hcdnnj This presentation will be available at: www.hcdnnj.org/taresources Sign on to the Network’s letter by Friday at: https://tinyurl.com/defendcra