NAHREP responds to the Federal Reserve’s proposed changes to the Community Reinvestment Act (CRA)

In response to the Federal Reserve’s proposed changes to the Community Reinvestment Act, NAHREP urges the Federal Reserve to strengthen the rigor of CRA exams in order to expedite a full economic recovery, particularly for those most affected by the COVID-19 pandemic. NAHREP encourages the Federal Reserve to prevent grade inflation by preserving the five subtest threshold at the state-level, require race and ethnicity data on CRA exams, and continue support for enhanced data collection, including community development financing data.  NAHREP commends the rule’s focus on transparent data analysis and quantitative measures of impact on communities.