The Community Reinvestment Act
The Community Reinvestment Act established an affirmative obligation for deposit insured lenders to serve their entire community. Since 1986, our agency has catalyzed more than $40 billion of CRA commitments from large and small institutions in North Carolina and the Southeast.
In 2017, Reinvestment Partners is challenging First Horizon’s acquisition of Capital Bank headquartered in North Carolina. You can read our July 14 comment to the Federal Reserve here.
First Horizon issued a response to public comment letters on August 2, as well as a supplement to their application to the Federal Reserve. Reinvestment Partners submitted a second comment on August 9 to the Federal Reserve, which you can read here.
In 2016, Reinvestment Partners challenged the First National Bank of Pittsburgh’s acquisition of Yadkin Valley Bank. This challenge lead to FNB’s development of a franchise-wide community reinvestment plan with input on North Carolina’s needs and opportunities.
In 2015, Reinvestment Partners challenged the purchase of Durham-based Square 1 Bank by PacWest. This letter to regulators references many of the points of our campaign. As a result of this work, Square 1 agreed to make $30 million in grants and investments in Durham.
Reinvestment Partners’ Research and Regulatory Comments on the CRA
- Comment: Advance Notice of Proposed Rulemaking on Prepaid Cards Under the Electronic funds Transfer Act (CFPB 2019-0019) (2012)
- Comment: Proposed Review of the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (OCC Docket FFIEC 2014-1) (2015)
Reinvestment Partners also influences federal CRA regulations. In our May 17, 2013, comments on the reform of CRA, we argued for a community benefits tests for qualified investments and illustrated how the Senior Crime Prevention Foundation inflated CRA evaluation grades. As a follow up, Bloomberg News covered the issue. In response, new federal Interagency CRA guidelines on qualified investments (69675 I. Qualified Investments) no longer allow credit for the Senior Housing Crime Prevention Foundation old model.
- Comment: Case Study of Why the Senior Housing Crime Prevention Program Evidences the Need for a Community Benefits Test in CRA Examinations (2013)
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Home Mortgage Disclosure Act