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Here's a short run-down of recent movement. CRA regulations are handled by 3 separate bodies: The Comptroller of the Currency (OCC), the Federal Reserve (FRB), and the FDIC. The OCC pushed through a very bank-friendly rule last year, led by a Steve Mnuchin appointee. https://twitter.com/lwinling/status/1361332779498278914
"Mnuchin ally" or "former employee," I should say.
Both the FRB and the FDIC were going to be part of the revision, but bailed when they realized there was so little industry support. The FRB started its own regulatory revision process. The OCC finalized its revision, despite public and business opposition.
The House passed a bill to block the revision in the fall (the House Banking Comm, led by @RepMaxineWaters and with both @AOC and @RepKatiePorter on it, is very good) but it died in the Senate.
The CRA should reasonably be updated, legislatively or in terms of regulation! Bank branch location was a key element of the original legislation (banks would take deposits from Black savers, but not make loans to Black borrowers or in the community).
After Redlining is a great book by @rmarchiel about the creation of this movement and legislation, btw.
Another aspect up for consideration in these revisions is whether bank investments and lending go to small businesses based in the districts/census tracts, or to large chains and corporations for activity in the local areas. (There are many, many other pieces to this).
What to make of all this? @HOLCRedlining and the @UR_DSL have worked with the @NCRC and I use their guides and analyses. If you make a comment at the link @ToddMichney posted, I suggest making 3 points that don't require you to be a policy wonk:
1. Keep to the spirit of the original legislation in promoting community equity, especially racial equity.
2. To do this, consider race among demographic data to evaluate targeted areas and to evaluate impact of investments.
2. To do this, consider race among demographic data to evaluate targeted areas and to evaluate impact of investments.
This is because community CRA evaluations have usually been income-based and color-blind, with community racial demographics as only an indirect consideration.
3. I think we can ask that the Fed evaluate the reach of banks to online customers through demographic analysis as well as in bank branch location, for the goal of promoting racial equity (and taking reporting data for later analysis).
So if you put in a comment to the Fed, consider those above points. And if you have any line to @RepMaxineWaters, @RepAOC, or @RepKatiePorter, encourage their continued attention to CRA and redlining issues.
Finally, I must say I love the work of @DanImmergluck on medium-term policy evaluation, @rmarchiel on the pre-history of CRA, and @NCRC on current issues, plus @Aaron_Glantz, formerly of @reveal for recent journalism
