HOPE Submits Comment to Federal Reserve’s Proposed Changes to the Community Reinvestment Act

February 16th, 2021

Please find HOPE’s comments to the Federal Reserve here.

The Community Reinvestment Act (CRA) has been a critical, though imperfect, tool for HOPE to leverage the resources it needs to serve low-income communities, rural communities, and communities of color in the Deep South. Rooted in our experiences in serving communities that are frequently underserved by banks and our experience in utilizing the CRA to help do this work, HOPE seeks to strengthen the CRA and its ability to significantly increase banks’ lending, services, and investments in our region.

The racial wealth gap is deep, and the economic and social benefits of closing it are vast. The financial system, particularly banks’ lending practices, has been a driving factor in this gap, and must play a significant role in closing it. Ultimately, closing the racial wealth gap has the potential to increase the national Gross Domestic Product (GDP) between $1 and $1.5 trillion by 2028.¹ Closing the gap in access to capital for people and communities of color is a critical pathway to closing the racial wealth gap. Lenders and communities alike will benefit from the resulting economic activity from a fairer, more robust marketplace. The CRA can be a helpful tool in guiding banks’ actions to ensure they repair, rather than repeat, centuries of racial and economic inequality.

These comments provide HOPE’s recommendations to move the CRA to its full potential for Deep South communities. It focuses on the following priority areas:

1. Objective and Overview
2. Assessment Areas
3. Designated Areas of Need
4. Increasing Investments in MDIs
5. Increasing Investments in CDFIs
6. Provisions Related to Rural Areas
7. Increasing Investment in Minority-Owned Businesses
8. Recommendations for the Retail Test
9. Strengthening Fair Lending Enforcement
10. Summary of Recommendations on Race

¹ McKinsey and Company, “The economic impact of closing the racial wealth gap,” Aug. 13, 2019, https://www.mckinsey.com/industries/public-and-social-sector/our-insights/the-economic-impact-of-closing-the-racial-wealth-gap