August 11, 2010
The Honorable Barney Frank
Chairman, House Financial Services Committee
2129 Rayburn House Office Building
Washington DC 20515
Dear Chairman Frank:
First, we would like to congratulate you and thank you for your leadership in enacting financial regulatory reform that will go a long way towards leveling the playing field for consumers, increasing the safety and soundness of our financial system and helping to curb the worst abuses that caused the economic collapse. We want to thank you in particular for including enhancements to the Home Mortgage Disclosure Act and small business lending data in financial reform.
We are writing you today to ask you to continue your leadership by moving forward with the introduction and passage of Community Reinvestment Act (CRA) modernization legislation. For many months communities, advocates, and your colleagues in Congress have been told that the introduction of comprehensive CRA reform is coming. It is now time for CRA reform to begin moving forward in earnest.
As you are aware, the four bank regulators have begun the process to modernize the regulations of CRA by scheduling hearings that began in July. We thank you for your support and work to ensure that this process was started, including your participation at the Brockton, MA Federal Reserve field hearing, one of 9 hearings the PICO National Network and National People’s Action organized last year. While we welcome this and will be working with the regulators to ensure the most effective update possible, we know that regulatory changes alone are not enough. To begin with, there is no guarantee regulators will make adequate changes to CRA. We think the passage of a bill in the House would spur the federal bank agencies to make better changes to the CRA regulation. There is also the danger that with a new crop of regulators, under a future administration, we might lose much of what we gained.
There are also substantial inadequacies in the law itself that can only be addressed through legislation. For example, due to changes in the marketplace over the last two decades, CRA does not apply to the bulk of mortgages and lenders in the country. Applying CRA to mortgage companies and mainstream credit unions is absolutely essential and can only be achieved through a change in the underlying law. It is worth remembering that, at the height of the housing bubble, only 6% of high-cost loans – the irresponsible lending that led to the melt-down – were made by the CRA covered lenders. Had CRA been applied to all lenders, it is likely that many of the worst abuses could have been curbed or avoided altogether. Moreover, applying CRA to additional institutions such as investment banks and insurance companies will leverage substantial investments and other financial products for communities of color and low- and moderate-income communities.
As pivotal a tool as CRA can be in preventing the next crash, equally crucial is the role an updated CRA will play in rebuilding the neighborhoods and businesses decimated by the Great Recession. CRA has brought billions of dollars of investment to our nation’s communities. We see now, more than ever, the need for such investment in neighborhoods devastated by foreclosure and reeling from job losses brought on by inaccessible small business credit. America needs capital and investment now, and a modernized CRA can spur our financial system to provide it.
We, and the thousands of community leaders we represent, are committed to working with you, the members of your Committee, Congress as a whole and the Administration to make the passage of effective CRA reform a reality this year. We look forward to seeing legislation introduced and votes scheduled quickly.
If you have any questions, please contact either Dion Spencer, Director of Legislation and Regulatory Policy (
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<:
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> ) at National Community Reinvestment Coalition or Liz Ryan Murray, Senior Policy Analyst (
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<:
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> ) at National People’s Action.
National Organizations:
- AFL-CIO
- Americans for Financial Reform (AFR)
- American Community Partnerships
- Center For Responsible Lending (CRL)
- Consumer Action
- Consumers Union
- Demos
- Greenlining Institute
- HomeFree USA
- Housing Assistance Council
- The Leadership Conference On Civil And Human Rights
- National Association Of Consumer Advocates
- National Association Of Housing Counselors And Agencies
- National Committee For Responsive Philanthropy
- National Community Reinvestment Coalition
- National Council Of La Raza
- National Housing Trust
- National Housing Conference
- National League Of Cities
- National People’s Action
- A New Way Forward
- PICO National Network
- Service Employees International Union (SEIU)
- US Conference Of Mayors
- US Jesuit Conference
Local / Regional Organizations:
1. ACCION Texas
2. ACTION-Housing Inc.
3. Affordable Housing Clearinghouse
4. Alaska Works Partnership Inc.
5. Alliance For Better Housing
6. Alliance to Develop Power
7. Anchorage Neighborhood Housing Services Inc.
8. Andrew H. Foster, Clinical Professor of Law, Duke Law School
9. Apprisen Financial Advocates
10. Association For Neighborhood & Housing Development
11. Athens Land Trust
12. Arc of Hilo
13. Baltimore Cash Campaign
14. Baltimore Neighborhoods, Inc.
15. Baltimore Trades Guild, Inc
16. Bay Area Women's Center
17. Beans And Rice, Inc.
18. Birmingham Business Resource Center
19. Brazos Valley Affordable Housing Corporation
20. Capital Area Asset Management Company
21. California Coalition For Rural Housing
22. California Reinvestment Coalition
23. California Resources And Training
24. Calvert Asset Management Company
25. Casa Of Oregon
26. CCCS Delaware Valley
27. CDC Of Marlboro County
28. CDC Of Tampa Inc.
29. CDC Small Business Finance Corporation
30. Ceiba Economic Development Corporation
31. Center For Community Development Inc.
32. Center For Community Justice And Advocacy
33. Center For New York City Neighborhoods
34. Central City Renaissance Alliance
35. Centre For Homeownership And Economic Development Corporation
36. Chester Community Improvement Project
37. Chhaya Community Development Corporation
38. Chicago Community Loan Fund
39. Chicago Rehab Network
40. Chicanos Por La Causa, Inc.
41. City Life/Vida Urbana
42. Clearinghouse CDFI
43. Columbus Urban League
44. Common Wealth Development Inc.
45. Communities United For Action
46. Community Action Committee Of Lehigh Valley, Bethlehem, PA
47. Community Action Program Of Evansville And Vanderburgh County Inc.
48. Community Development Council Of Greater Memphis
49. Community Empowerment Coalition Inc
50. Community Housing Opportunities Corporation
51. Community Reinvestment Fund Inc.
52. Community Renewal Team Inc.
53. Community Service Network Inc.
54. Community Service Programs Of West Alabama Inc.
55. Couleecap Inc.
56. Covenant Faith Outreach Ministries/Covenant Community Development Corp.
57. Delaware Community Reinvestment Action Council Inc.
58. Democracy Collaborative
59. Detroit Nonprofit Housing Corp
60. Disability Opportunity Fund
61. Dominion Financial Management
62. East Side Organizing Project
63. Eastside Ministerial Alliance
64. Economic Opportunity For Savannah Chatham County Area Inc.
65. Economic Resources Corporation
66. Eden Council For Hope And Opportunity
67. El Paso Affordable Housing CUSO
68. Empire Justice Center
69. Escambia County Housing Finance Authority
70. Fair Finance Watch, South Bronx
71. Fair Housing Center Of Greater Boston
72. Fair Housing Center Of West Michigan
73. Fair Housing Council Of Central New York, Inc.
74. Fair Housing Council Of Suburban Philadelphia
75. Fair Housing of The Dakotas
76. Family Management Credit Counselors
77. Financial Literacy Network Inc.
78. Florida Community Loan Fund
79. Florida Low Income Housing Associates Inc.
80. Franklin County, Ohio
81. George Washington University-Professor Gregory Squires
82. Global One Development Center
83. Grass Roots Organizing, MO
84. Greater Boston Legal Services
85. Greater New Haven Community Loan Fund
86. Greater Rochester Community Reinvestment Coalition
87. Habitat For Humanity Of WA State
88. Harlingen Community Development Corporation
89. Hartford Community Loan Fund Inc.
90. Hazard Hill / Branch CDC
91. HBC Services Inc.
92. High Plains Community Development Corp.
93. Hispanic American Chamber Of Commerce Of Greater Boston
94. Home Repair Resource Center
95. Homeward Inc.
96. Housing Action Coalition Of Rhode Island
97. Housing Action Illinois
98. Housing Alliance Of Pennsylvania
99. Housing America Corporation
100. Housing Association Of Nonprofit Developers
101. Housing Development Fund Inc.
102. Housing Education And Economic Development (HEED)
103. Housing Education Resource Center
104. Housing Network Of Rhode Island
105. Housing Opportunities Collaborative
106. Housing Opportunities Made Equal Of Virginia
107. Housing Opportunities Project For Excellence Inc.
108. Housing Options & Planning Enterprises, Inc.
109. Housing Research & Advocacy Center
110. Housing Resources Of Western Colorado
111. Illinois People’s Action
112. Indiana Association For Community Economic Development Inc.
113. Indiana Community Action Association Inc.-Region 5
114. Inland Fair Housing Mediation Board
115. Insight Center For Community And Economic Development
116. Instituto Socio-Economico Comunitario, Inc.
117. Iowa Citizens For Community Improvement
118. Iowa Home Ownership Education Project
119. Jacksonville Area Legal Aid
120. Jewish Community Action
121. Justine Petersen Housing And Reinvestment Inc
122. Lake View Towers Residents Association Inc.
123. Legal Assistance Resource Center Of Conn.
124. Local Economic And Employment Development Council Inc. (LEED Council)
125. Local Initiatives Support Corporation (LISC)
126. Long Island Housing Services Inc.
127. Los Angeles LDC Inc.
128. Macoupin County Housing Authority
129. Main Street Birmingham, Inc.
130. Maine Affordable Housing Coalition
131. Manna, Inc.
132. Maryland Cash Campaign
133. Mason City Human Rights Commission
134. Massachusetts Affordable Housing Alliance
135. Massachusetts Association Of Community Development Corporations
136. Massachusetts Community Action Network
137. MEO Business Development Corporation
138. Metro St. Louis Coalition For Inclusion & Equity (M-Slice)
139. Metropolitan Consortium Of Community Developers
140. Metropolitan Milwaukee Fair Housing Council
141. Metropolitan St. Louis Equal Housing Opportunity Council
142. Miami Valley Fair Housing Center Inc.
143. Miami-Dade Affordable Housing Foundation Inc.
144. Mid-Ohio Regional Planning Commission
145. Movin' Out, Inc.
146. Mt. Pleasant Community Zone
147. NAACP Mississippi State Conference
148. NC Institute Of Minority Economic Development
149. Neighborhood Economic Development Advocacy Project
150. Neighborhood Housing Services Of Greater Cleveland
151. Neighborhood Housing Services Of South Florida
152. Neighborhood Legal Services Of LA County
153. Neighborhood Recovery CDC
154. Neighbors Helping Neighbors
155. New Jersey Citizen Action
156. New Orleans Neighborhood Development Foundation
157. New Orleans Redevelopment Authority
158. New York City AIDS Housing Network
159. New York State Rural Housing Coalition Inc.
160. Northeast Denver Housing Center
161. Northern New England Housing Investment Fund
162. Northwest Bronx Community and Clergy Coalition
163. Northwest Fair Housing Alliance
164. Northwest Indiana Reinvestment Alliance
165. Oakpark Regional Housing Center
166. Opening Doors Inc.
167. Oregon Opportunity Network
168. Organizing Neighborhood Equality, DC
169. Pacific Asian Consortium In Employment (PACE)
170. Partners In Community Building Inc.
171. Partnership For Fair Housing Center Of SW Michigan
172. Pathstone
173. People Organized For Westside Renewal, Los Angeles
174. People United For Sustainable Housing
175. People's Self-Help Housing Corporation
176. Philadelphia Association Of CDC
177. Philadelphia Unemployment Project
178. Phoenix Housing Counseling Non-Profit Inc.
179. Piedmont Housing Alliance
180. Pittsburgh Community Reinvestment Group
181. Pride Through Empowerment Foundation
182. Quitman County
183. Quitman County Development Organization, Inc.
184. RAFI-USA
185. Raleigh Area Development Authority
186. Reach Community Development Inc.
187. RISE Foundation
188. River City Community Development Corporation
189. Rock Island Economic Growth Corporation
190. Rural Development And Finance Corporation
191. Rural Housing Inc.
192. Sacramento Home Loan Counseling Center
193. San Diego Reinvestment Task Force
194. Scott County Housing Council
195. Select Milwaukee, Inc.
196. Self-Help Enterprises
197. Small Business Alliance Of Central Florida-The
198. South Austin Coalition Community Council
199. South Carolina Appleseed Legal Justice Center
200. South Philadelphia H.O.M.E.S. Inc.
201. South Shore Chamber Inc.
202. Southeast Rural Community Assistance Project Inc.
203. Southern Mutual Help Association Inc.
204. Southern New Hampshire University
205. Southern Regional Community Reinvestment Corporation
206. Southwest CDC
207. Southwest Fair Housing Council
208. Southwest Georgia United Empowerment Zone
209. Spanish Coalition For Housing
210. Spokane Low Income Housing Consortium
211. St. Johns Housing Partnership
212. St. Mary Development Corporation
213. St. Petersburg Neighborhood Housing Services, Inc.
214. Sunflower Community Action
215. Sunnyside Up Campus Neighborhoods Revitalization Corp.
216. Syracuse United Neighborhoods
217. TakeAction Minnesota
218. Texas Association Of Community Development Corporations
219. Toledo Fair Housing Center
220. Unidos Para La Gente
221. United Community Center
222. United Neighborhood Centers Of Northeastern Pennsylvania
223. United Neighbors Inc.
224. United Planning Organization
225. United South Broadway Corporation
226. Urban Economic Development Association Of Wisconsin Inc.
227. Vermont Slauson Economic Development Corporation
228. WIN Action Organizing Project
229. We Help Community Development Corp
230. West Central Missouri Community Action Agency
231. West Company
232. West Humboldt Park Family & Community Development Council
233. West Virginia Affordable Housing Trust Fund
234. Westchester Residential Opportunities Inc.
235. Western New York Law Center Inc.
236. Western States Center
237. Women’s Business Development Center
238. Woodstock Institute
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