NH&RA submitted comments to the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation’s (FDIC) proposed rule on Community Reinvestment Act (CRA) regulations. Comments can be submitted here through 11:59 pm ET.
Our comments focus on the impact of LIHTC investment under the proposed CRA regulations. We believe the expanded Community Development Loans and Investments Category strays too far from housing and do not believe that the doubling of credit for LIHTC investments is a sufficient incentive for banks to continue their current levels of investments in these types of activities. We are also concerned about the single-ratio approach, which may cause banks to seek out a few large investments to meet their CRA obligations. The proposed single-ratio approach would only consider balance sheets, and not originations, which could mean that banks that have met their single-ratio targets based on their current balance sheet assessment would limit or halt new investment activity. Finally, we raised concerns about the new assessment areas and urged the OCC and FDIC to consider the public comments, the views of their fellow regulator—the Federal Reserve Board—and the challenges the affordable housing industry is already facing as a result of the COVID-19 pandemic.
