2. 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.

3. 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.

5. 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

6. 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

7. 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

8. This presentation will be available at: www. hcdnnj
This presentation will be available at: Sign on to the Network’s letter by Friday at: