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March 25, 2020
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March 25, 2020
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the Comptroller

As we discussed in class, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation are taking comments on their proposal to reform CRA. Comments are due to the regulators April 8, 2020. Providing feedback is critically important to ensure that the reforms enacted strengthen rather than weaken CRA.  However, there is honest debate about how to do that.  There is no right answer to what you will write in this letter – it is your opinion, supported by evidence presented in class or that you find through research, that we will be looking for.

Requirements

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Your comment letter should be between 800 and 1,200 wordssingle spaced12 pt font, and include your signature. (A letter template is provided with this assignment.)

A good comment letter:

  • – Begins by articulating who you are and why you care about the issue.
  • – Focuses on the parts of the regulatory revisions that most concern you and/or that you understand the best.  You do not need to comment on every aspect of the proposed rule. We are expecting that you comment on 2 aspects of the proposed changes.
  • – Is clear about which parts of the rule you support and which you disagree with.
  • – Supports your point of view with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment. By supporting your arguments you are more likely to influence agency decision making.
  • – If you disagree with a proposed action, suggest an alternative and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective

These letters should be written by you, and include citations for materials that you take from other reports or websites.  We will be using TurnItIn for this assignment.  Organizations often encourage their members to submit form letters –you will find examples of this online.  DO NOT TURN IN A FORM 

LETTER.  Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues but this is not true. A single, well-supported comment carries more weight than a thousand form letters.

USE THESE RESOURCES!!!!:

  1. https://www.occ.treas.gov/news-issuances/federal-register/2020/85fr1204.pdf
  2. Proposed Rule (Part III) https://www.federalregister.gov/documents/2020/01/09/2019-27940/community-reinvestment-act-regulations#h-10 
  3. https://www.occ.treas.gov/topics/consumers-and-communities/cra/cra-notice-of-proposed-rule-fact-sheet.pdf
  4. https://bankingjournal.aba.com/2019/12/bonus-podcast-digging-into-the-details-on-cra-modernization/
  5. https://www.forbes.com/2009/10/03/community-reinvestment-act-mortgages-housing-opinions-contributors-peter-schweizer.html#b7740013b907
  6. https://www.heritage.org/commentary/the-cra-cover
  7. https://ncrc.org/treasureCRA/
  8. https://www.novoco.com/periodicals/articles/proposed-cra-regulations-greeted-great-concern-aggregate-balance-sheet-ratio-could-overwhelm-other
  9. https://thehill.com/blogs/congress-blog/politics/484063-the-government-has-a-policy-that-could-help-banks-reduce-lending
  10. https://penniur.upenn.edu/uploads/media/Quantitative_Performance.pdf

 

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