CBA: Regulators’ CRA Proposal Does Not Address Needs of CRA

October 20, 2017

Washington, D.C. – The Consumer Bankers Association (CBA) today submitted comments to the Office of the Comptroller of the Currency, Federal Reserve Board and Federal Deposit Insurance Corporation on proposed rulemaking to amend the Community Reinvestment Act (CRA). The proposal would require financial institutions to combine home equity lending data with home mortgage lending data when reporting it to regulators. Given these two loan types service entirely different consumer needs, CBA strongly believes merging this data will only serve to degrade the quality and limit the usefulness of the information regulators receive when conducting CRA exams.

In the letter CBA’s Regulatory Counsel Stephen Congdon writes:

“Collapsing home equity products into the broader definition which includes refinances, home purchases, and home improvement will do much to confuse the mortgage data and little to advance the purposes of CRA.  The CRA was based on the principle that banks have an affirmative obligation to serve their entire community, including low-and-moderate income communities.  Treating home equity products in the same manner as purchase money mortgages or other real estate secured lending fails to address the significant differences in the availability and use of these products across different geographies and incomes.”

You may read the full letter here.


About the Consumer Bankers Association

The Consumer Bankers Association represents America’s retail banks above $10 billion in assets. We advance legislation and promote policies geared toward creating a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.6 million jobs in America, extend roughly $3 trillion in consumer loans, and provide $270 billion in small business loans. Follow us on Twitter @consumerbankers.