NAR submitted a comment in response to the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation's notice of proposed rule making (NPRM) on modernization of the community reinvestment act (CRA).
While supportive of modernization efforts, NAR made a number of points where the proposed rule could be improved and better align with NAR policy. The final rule should:
- Be done in consult with the FED,
- Reflect and demonstrate a thorough analytical review of the impact of the proposed changes,
- Be based on units lent rather than dollar volume,
- Focus on investments that support ownership,
- Avoid credit for large infrastructure projects rather than investments in RE ownership,
- Avoid burdens on small lenders, and
- Be delayed until after the COVID crisis has passed.