The Affordable Housing Tax Credit Coalition (AHTCC) has submitted comments to the Office of the Comptroller of the Currency (OCC) regarding its Advanced Notice of Proposed Rulemaking (ANPR) on the modernization of the Community Reinvestment Act (CRA). The ANPR, released on August 28, 2018, garnered nearly 1,300 comment letters by the deadline of November 19, 2018.
The CRA, created in 1977, has not been significantly revised since 1995. While we applaud the OCC’s efforts to modernize the program, we urge that any changes to the CRA continue to support robust investment in the Housing Credit, to ensure that our nation’s primary affordable housing delivery mechanism is at least as efficient and effective as it is today. As rents continue to rise at a faster pace than wages, our affordable housing needs are greater than ever, and the CRA remains an absolutely vital incentive for investment in affordable housing.
In our comment letter, we encourage the OCC to retain a separate investment test to ensure that financial institutions continue to have an incentive to make investments in impactful products like the Housing Credit, to expand CRA assessment areas beyond the current outdated physical footprints, to ensure that any expansion of CRA-eligible activities does not discourage investment in the Housing Credit, and to allow for more timely and transparent examinations. Earlier this fall, representatives from the AHTCC participated in a listening session at the OCC in which we thanked Comptroller Joseph Otting for his interest in modernizing CRA, but expressed our concern that several of the proposals under consideration could significantly weaken investment in affordable housing.
The OCC is the first of the three regulators with jurisdiction over CRA to take a major step towards CRA reform; the Federal Reserve and Federal Deposit Insurance Corporation (FDIC) have not yet undertaken similar efforts. The AHTCC will be closely monitoring all developments related to CRA modernization and weighing in at every opportunity to urge that the CRA continue to incentivize at least the current level of investment in affordable housing.
If you have any questions, please contact Emily Cadik, Executive Director, at firstname.lastname@example.org.