The Greenlining Institute Urges Regulators to Include Racial Equity in the Nation’s Landmark Community Reinvestment Act


 [ Article originally appeared in ]

Today, the comment period on a historic update to the regulations implementing the Community Reinvestment Act closed. The Greenlining Institute urges regulators to seize this opportunity to ensure banks play their role in addressing the harm inflicted on communities that were redlined. Redlining was the practice of systematically denying financial services to low-income communities and communities of color that banks perpetuated prior to the CRA’s enactment in 1977, which outlawed the practice. 

In May 2022, federal regulators including the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and Federal Reserve Board proposed amended regulations to the CRA’s implementation and announced a public comment period that closed today. Despite regulators’ stated commitment to leveraging the CRA to advance racial equity, the Notice of Proposed Rulemaking failed to include race as a consideration in the updated regulations.

“We have seen major changes in banking since 1977–nationwide banks, bank consolidation into megabanks, and internet banking or fintechs. The CRA must keep pace with the evolution of the banking sector,” said Debra Gore-Mann, Greenlining’s CEO & President. “A strong CRA is still vital to America’s low-income communities of color. And, we must continue to hold financial institutions and the entire regulatory system accountable to the harm they’ve done.”

Greenlining submitted a comment letter outlining its analysis of, and key improvements to the regulators’ Notice of Proposed Rulemaking. Highlights of the letter include:

  • Racial Equity: Greenlining recommends assessing bank performance through percentage of home lending to Black, Indigenous, and people of color borrowers, using race to determine additional assessment areas, analyzing lending by race and ethnicity in underserved neighborhoods in all CRA exams (including community development financing and retail lending), and considering a bank’s creation and deployment of Special Purpose Credit Programs. These recommendations should both increase transparency of the context in which banks are doing business, and reward or penalize banks for failing to meet the needs of BIPOC communities.
  • Climate resilience:  Climate change is a risk multiplier that exacerbates racial and economic inequality, and it is progressing at an alarming rate. The agencies must update CRA regulations with this reality in mind so that the banking system meets the changing credit needs of all communities. The proposed rule includes a new definition of “disaster preparedness and climate resiliency” and lists eligible investments that would provide meaningful support to communities. Greenlining supports this change, and provides additional climate resilience strategies for consideration. Greenlining also recommends strategies for scrutinizing investments in fossil fuels.
  • Assessment Areas: Currently, a bank’s CRA obligations are only within assessment areas where a bank’s main office, branches and/or ATMs are located. However, increasingly, banks make a significant number of loans outside of those areas. The NPR proposes to create assessment areas where a large bank does not have branches, but has made a significant number of loans. Greenlining supports this change and also proposes that the regulators require additional assessment areas, especially rural areas, Native American reservations, and counties with high percentages of people of color. 

“How can we expect our nation’s anti-redlining law to work without addressing this country’s history of systemic racism?” she continued. “Regulators must strengthen and modernize investments in communities that were historically exploited and continue to experience severe climate and economic inequities. Our future depends on it.” said Gore-Mann. 

To read Greenlining’s comment letter and additional information about the organization’s push to strengthen the CRA, please visit our website at


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