November 7, 2018

The CRA at a Crossroads Forum Featured a Speech by FDIC Martin J. Gruenberg, Community Development Panel and a Large Crowd


UNHP was one of the sponsors of the 10/29/18 CRA at a Crossroads Forum; Understanding the Impact and Ensuring the Future of the Community Reinvestment Act. The well-attended Forum was held at the Lincoln Center campus of Fordham University and featured a speech by FDIC Board member Martin J. Gruenberg and a community development panel.

Moderator Lorraine Collins of Enterprise Community Partners; Panelists Jim Buckley UNHP, Will Spisak CHHAYA CDC, Elizabeth Strojan NYC HPD & HDC, speaker Martin J. Gruenberg FDIC and Panelist Jaime Weisberg ANHD.

The CRA at a Crossroads Forum was sponsored by Fordham University’s International Political Economy & Development Program (IPED), Association for Neighborhood and Housing Development (ANHD), Enterprise Community Partners and University Neighborhood Housing Program (UNHP). Dr. Henry Schwalbenberg, Director of Fordham’s IPED Program, welcomed the crowd of over 100 to Fordham’s Lincoln Center campus and introduced Martin J. Gruenberg, Member, Board of Directors, Federal Deposit Insurance Corporation who delivered a speech entitled: The Community Reinvestment Act: Its Origins, Evolution, and Future.

The CRA at a Crossroads Forum, held on 10/29/18, featured a speech by Martin J. Gruenberg, Board member of the FDIC, Lorraine Collins of Enterprise Community Partners as moderator of a panel of community development experts and a sizeable crowd of people from financial institutions, community development groups, and regulatory agencies.

Mr. Gruenberg’s full remarks (available at this link) detail the history and changes to the Community Reinvestment Act since 1977. He emphasized the need to keep to the intent of the law which has always been to combat redlining and disinvestment and ensure banks are meeting local needs. He also spoke out strongly against the one-ratio idea suggested in the Office of the Comptroller of the Currency (OCC) request for comments. We encourage you to read the full speech by Martin J. Gruenberg. Below are some excerpts from the speech that resonated with us.

From the outset, the agencies made clear that the institutions would be evaluated on their outreach and engagement with the community, their compliance with anti-discrimination and other consumer protection statutes, and the geographic distribution of their loans. The intention to address redlining on the basis of income and race was evident, as was the community-based focus of the law.

A reliance on a single ratio of CRA performance could allow banks to pick and choose which communities to serve and which products and services to offer in those communities. It is not clear how it would be made compliant with the statutory requirement that the CRA evaluation be presented separately for each metropolitan area in which a bank maintains one or more branches.

Such an approach could also undermine the incentive that banks currently have to develop constructive partnerships with community organizations. It is these partnerships between community organizations and banks that have been central to community development in low- and moderate-income neighborhoods throughout New York City and around the country.

The Office of the Comptroller of the Currency released an Advance Notice of Proposed Rulemaking (ANPR) seeking comments on the best ways to modernize the regulatory framework implementing the Community Reinvestment Act (CRA). Comments are due by November 19th.

Panelist Jaime Weisberg of ANHD highlighted some of their efforts and advocacy about preserving and strengthening the CRA. ANHD’s work on this issue, as well as a draft comment letter, is available on their website.

At the forum, Jim Buckley, UNHP’s Executive Director, shared the experiences of Bronx tenants and neighborhood leaders in the 1970’s who were able to use the newly passed CRA to fight for improvements in their bank-mortgaged buildings. In subsequent years, neighborhood leaders were able to use CRA as a tool to encourage banks to join in their community improvement and development efforts. UNHP continues to fight for appropriate private investment in the Bronx and increased access to financial services by residents. Here are the links to UNHP’s most recent work towards this end; CRA’s Bronx Impact, The Bronx Banking GuideBronx Financial Services Survey, improved financial access for immigrants, and
the impact of alternative financial services.

Elizabeth Strojan, Vice President for Government Affairs at NYC’s HPD and HDC, spoke about the integral role of the CRA in the affordable housing preservation and development work of New York City. The bank loans and investment in affordable housing allow City investment dollars to be used in such a way to have a greater impact in New York City.

Will Spisak of Chhaya CDC spoke about the importance of small business lending and banking services for all immigrants including the South Asian and Indo-Caribbean community that Chhaya represents in Queens, New York. He acknowledged the benefit of maintaining the Community Reinvestment Act as a tool to uphold the current level of service and to strive to bring more banking and lending services to New York’s many self-employed and immigrant communities.

All four of the panelists and forum moderator, Lorraine Collins of Enterprise Community Partners indicated that their organizations will submit comments in response to the OCC Notice of Proposed Rulemaking. While all the speakers acknowledged areas where the CRA could be improved, they all emphasized the importance of preserving the Community Reinvestment Act in such a way as to retain its value as a tool to bring banks to neighborhoods to address people’s needs in a meaningful way.

A special thanks to:

Host, Fordham University IPED Program

Speaker, Martin J. Gruenberg for his thoughtful remarks

Moderator, Lorraine Collins of Enterprise Community Partners

Panelists from UNHP, ANHD, NYC HPD and HDC, and Chhaya CDC


We all thank you for your interest in the history, impact
and the future of the CRA