community reinvestment act, community based organization, credit, enforcement, low income communities


The Community Reinvestment Act (“CRA”) represents a continuing, affirmative obligation on banks to meet the credit needs of their communities — including low and moderate income neighborhoods — by providing appropriate credit products and deposit services. Federal regulators have been hesitant to enforce the CRA aggressively, and community based organizations (“CBO’s”) have taken the lead in using the CRA to improve bank lending in low and moderate income communities. A combination of recent legislation and social developments ensure an increase in the CBO’s CRA enforcement activity. This Guide’s purpose is twofold. The first is to catalogue and analyze the decisions, policy statements, testimony, and regulations of the Board of Governors of the Federal Reserve System (“Board”) regarding the CRA, in an attempt to describe the Board’s CRA enforcement standards. The second purpose is to provide a framework for a CBO to follow when seeking to use the CRA to increase the amount of credit available in its community.



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