What Is the Community Reinvestment Act (CRA)?

The Community Reinvestment Act (CRA) is a federal law enacted in 1977 to encourage depository institutions to meet the credit needs of the communities where they operate, including low- and moderate-income neighborhoods.

Under the CRA, federal banking agencies are required to evaluate how well each institution serves these communities. These performance assessments are then considered when reviewing applications for bank mergers, charters, acquisitions, branch openings, and deposit facilities.

Understanding the 💙Community Reinvestment Act (CRA)

Before the Community Reinvestment Act (and other fair housing laws), U.S. banks systematically denied mortgages to Black Americans and other people of color who lived in certain areas "redlined" by a federal government agency called the Home Owners' Loan Corporation (HOLC). The HOLC created maps that classified neighborhoods across the country on a "perceived level of lending risk" based on information gathered from various sources, including local appraisers, loan officers, city officials, and real estate agents.

The neighborhoods were color-coded on maps, with each color representing the area's perceived risk to lenders. HOLC deemed the red communities hazardous, describing them as "characterized by detrimental influences in a pronounced degree, undesirable population, or an infiltration of it." Neighborhoods with predominantly racial and ethnic minority populations were colored red—hence, "redlined."

The maps were a tool for widespread 澳洲幸运5官方开奖结果体彩网:racial discrimination. The immediate effect of redlining was that residents in these areas couldn't access credit to buy or improve their housing. However, the long-term effects of redlining persist:

• 74% of neighborhoods that HOLC colored red ("hazardous") more than 80 years ago are low- to moderate-income neighborhoods today.
• 64% of the "hazardous" neighborhoods remain racial and ethnic minority neighborhoods today.
• 91% of areas colored green ("best") in the 1930s remain middle- to upper-income areas today, and 85% are still predominantly White.

The objective of the Community Reinvestment Act was to s﷽trengthen existing laws requiring banks to sufficiently address the banking needs of all members of the communities they served.

Three federal regulators—the Office of the Comptroller of the Currency (OCC), the 澳洲幸运5官方开奖结果体彩网💜:Federal Deposit Insuran𒐪ce Corporation (FDIC), and the 澳洲幸运5官方开奖结果体彩网:Federal Reserve Board—share oversight of the CRA. However, the last is chiefly responsible for assessing whether state member banks are fulfilling their obligations under the law.

CRA Performance Ranking

The 澳洲幸运5官方开奖结果体彩网:Federal Reserve uses one of five methods to rank a bank’s performance based on its size and mission. Though a 1995 update to the CRA requires regulators to consider lending and investment data, the evaluation process is somewhat subjective, with no specific quotas that banks have to satisfy. Still, each bank is given one of the following ratings:

• Outstanding
• Satisfactory
• Needs to improve
• Substantial noncompliance

The FDIC maintains an online database where the public can see a particular bank’s score. Additionally, banks are obliged t🦋o provide consumers with their performance evaluations upon request.

Criticisms of the CRA

The CRA has faced criticism, particularly from some conservative politicians and commentators, who argue that it contributed to risky lending practices that played a role in the 2008 financial crisis. Critics claim that banks relaxed lending standards to meet CRA requirements, resulting in a proliferation of subprime mortgages.

However, some economists, including Neil Bhutta and Daniel Ringo of the Federal Reserve Bank, argued in 2015 that CRA-based mortgages represented a small percentage of the subprime loans issued during the financial crisis. As a result, Bhutta and Ringo concluded, the law was not a major factor in the housing market’s subsequent downturn.

The CRA has also received criticism that it has not been particularly effective. Though low- and moderate-income communities saw an influx of loans after the CRA’s passage, research by the Federal Reserve’s Jeffrey Gunther concluded that lenders not subject to the law—that is, 澳洲幸运5官方开奖结果体彩网:credit unions and other non-banks—represented an equal share of those loans.

Modernizing the CRA

More recently, some economists and policymakers have suggested the law needs to be revised to keep up with changes in the industry and make the evaluation process less onerous for banks. For example, the physical location of bank branche𝓰s remains a component in the scoring process, even though an increasing number of consumers are conducting their banking online.

In a 2018 op-ed piece, former Comptroller of the Currency Joseph Otting asserted that the CRA’s outdated approach had led to “investment deserts,” where "CRA activity often fails to reach by preventing banks from receiving consideration when they want to lend and invest in communities with a need for capital."

The Office of the Comptroller of the Currency (OCC) proposed a new rule in May 2020 to modernize the CRA, receiving more than 7,500 comments from stakeholders. Critics, including the National Community Reinvestment Coalition, claimed that the changes would reduce banks' accountability to communities. However, Otting defended the rule, arguing it would increase credit for mortgage origination and promote affordable mortgages in lower-income areas.

In December 2021, the OCC rescinded the June 2020 rule to be replaced with a rule designed jointly by the OCC, Federal Reserve, and FDIC. On May 5, 2022, the agencies jointly proposed a new rule intended to account for the ubiquity of online banking and distribute reinvestment more broadly across the country.

In 2023, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a final rule to modernize regulations implementing the CRA. The final rule focuses on eight key objectives, including strengthening the CRA's core purpose, adapting to changes in the banking industry, promoting transparency, and ensuring consistency in regulatory approaches.

The Bottom Line

The CRA ensures that🍌 federally insured banks meet the credit needs of all communities, especially low- and moderate-income areas. The law was initially created to combat redlining and promote equitable access to credit, and it has evolved over time to address🐽 changes in the banking sector.

While some have criticized the CRA for its role in the 2008 financial crisis and question its effectiveness, many believe that the CRA remains vital for promoting equitable access to credit. Recent updates aim to mod🌼ernize the CRA, focusing on transparency and adapting to current banking🧔 practices, to ensure fair financial services for all communities.