On February 16, 2021, NAR responded to the Federal Reserve Board of Governors' (FRB) Advance Notice of Proposed Rulemaking (ANPR) to modernize the Community Reinvestment Act (CRA). NAR laid out it's priorities for modernizing CRA. NAR comments pointed out that it hoped: 1) modernization would lead all banks to serve all communities and provide fair access to financial services; 2) while the retail lending matrix seemed sound, it was concerning that a "satisfactory" grade could be achieved by providing only a fraction of current services; and, 3) recycling the same loans amongst banks to get CRA credit, i.e. churning, should be prevented.
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