The Office of the Comptroller of the Currency (OCC) invited public comment to advance an updated framework to modernize the regulations that implement the Community Reinvestment Act of 1977 (CRA). CRA was approved by Congress to encourage and monitor bank performance to meet the credit needs of their local communities, including low- and moderate-income (LMI) neighborhoods and individuals.
Each year, banks spend more than a billion dollars on community development in LMI neighborhoods and under CRA must be held accountable for credit and financial services for LMI borrowers. Since the first publication of CRA regulations in 1978, there has been no mention of people with disabilities as part of LMI populations, despite their disproportionately high poverty rate in all geographic areas nationwide.
National Disability Institute submitted public comments to OCC on November 10, 2018 in response to an Advanced Notice of Proposed Rulemaking (ANPR) to update the regulations in light of the changes in the way banks provide financial services (online in addition to physical locations) and the responsibility under CRA to meet the needs of LMI populations and neighborhoods.
NDI comments provided empirical data that people with disabilities make up a significant share of LMI neighborhoods and have the highest rate among economically vulnerable populations of being unbanked and underbanked. Without bank performance evaluation of coverage of people with disabilities as part of LMI populations, there is no investigation of possible discriminatory lending practices, review of availability and effectiveness of retail banking services to meet the needs of people with disabilities or scrutiny of targeted community development investments that impact the disability audience.
NDI offered a nine-part disability framework to CRA modernization that would create an “inclusive community development” imperative that would accelerate CRA bank activities that would result in dedicated disability-related lending, investment and financial service access and use.
