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“It’s in the best interest of regulators to not rush modernizing CRA. It’s more important to get it right. NHC has dozens of our members working on a detailed response, along with a team from Nixon Peabody and Georgetown Law School. If the OCC and FDIC really want to improve CRA without gutting it, they need to take this comment period and the resulting feedback very seriously. Extending the comment period is an important first step.” -David M. Dworkin

“CRA modernization is overdue and needs to be done so banks and communities get the clarity and flexibility they need to ensure they have maximum positive impact. ” – David M. Dworkin

“It’s a once-in-a-generation opportunity. If modernization is done without broad support across the political spectrum, it’s just another swing of the pendulum that will cost banks hundreds of millions to retool the compliance system, and hundreds of millions more when the pendulum swings back and they have to retool again — all for what could be a much more problematic CRA regime in the first place.” – David M. Dworkin

“Using a simplistic ratio, even though they’ve made some improvements to it, is going to significantly undercut the kind of smaller, more targeted investments that communities need the most.” – David M. Dworkin

“The proposal would significantly undercut the kind of smaller, more targeted investments that communities need the most.” -David M. Dworkin

“Influential organizations spanning the political spectrum — including the National Association of Realtors, the National Association of Real Estate Brokers, the National Association of Hispanic Real Estate Professionals, the National Community Reinvestment Coalition, the National Housing Conference and the National Consumer Law Center — support the effort to end life of loan premiums. Now, with the Actuarial Report in hand, it is time for the FHA to act to end this policy.”

“In many cases, individuals earn below $10 an hour, a wage that would be a barrier for most households in Greenville to affording even the most affordable housing unit. The National Housing Conference’s Paycheck to Paycheck study indicates a household would need to earn $60,000 a year to purchase a home and about $33,000 a year to rent a two-bedroom apartment in the Greenville metro area.”

“There are more than 550,000 Americans without homes, according to federal data compiled in 2017. An increasing portion of the homeless population are men and women who’ve been priced out of homes and neighborhoods they were once able to afford.” – David M. Dworkin

“The Housing as Infrastructure Act has received support from a number of organizations, including Enterprise Community Partners, Local Initiatives Support Corp., National Association of Housing and Redevelopment Officials (NAHRO), National Housing Conference, National Low Income Housing Coalition, and National Multifamily Housing Council.”

“Groups ranging from the National Association of Home Builders, a trade group for housing construction companies, to affordable housing advocates, like the National Housing Conference and the National Low Income Housing Coalition, have endorsed the [Housing is Infrastructure Act].”