The Community Reinvestment Act (CRA) remains a driving force behind private sector investment in underserved communities, including Cinnaire’s work to raise capital through equity investments and lending. Last year, the Federal Reserve Board indicated it would go forward with its own rulemaking to update CRA regulations and solicited comments from the public, which were due on February 16th.

Given the importance of CRA to our communities, we submitted a comment letter in response to the Federal Reserve Board’s Advance Notice of Proposed Rulemaking (ANPR) on CRA reform. In our comment letter, we explain the value of CRA to our work and partners while responding to some of the Federal Reserve Board’s questions about CRA reform.

All of this may sound familiar: Last year, another federal regulator — the Office of the Comptroller of the Currency (OCC) — proposed and finalized its own update to CRA regulations. The affordable housing and community development industries widely criticized the OCC’s approach, citing its likely impact on investment in impactful activities. However, with a new head of the OCC likely coming soon, it is expected that the OCC will take a different approach, perhaps joining the Federal Reserve and the Federal Deposit Insurance Corporation (FDIC) in a joint rulemaking. For that reason, the Federal Reserve’s approach will be important to follow.

If you have questions about our comment letter or would like to discuss, please contact Chris Neary.