Weekly update from the National Housing Conference
August 8, 2018
President's Message I By David M. Dworkin

This week, I joined several of my affordable housing colleagues at the Office of the Comptroller of the Currency (OCC) for a meeting with Comptroller Joseph Otting to discuss his efforts to modernize the Community Reinvestment Act of 1977 (CRA). It was an excellent opportunity for us to become acquainted in advance of what will be an extensive regulatory process likely to last throughout the rest of the year and well into 2019. I expect that this process will begin soon with the release of the OCC’s Advance Notice of Proposed Rulemaking (ANPR), the first in a series of legal steps necessary to revise the existing CRA regulation.

To help facilitate NHC’s leadership in this important initiative, I am announcing the formation of a CRA Modernization Working Group so our members can actively participate in this important work. Issues that require additional deliberation and debate may also be taken up by the NHC Policy Committee as well. If you are member with an interest in the CRA rulemaking process, I encourage you to join us in this effort by notifying Kaitlyn Snyder. If you are not currently a member and would like to be involved, please contact Amanda Mitchell so you can join today. The first meeting of the CRA Working Group will take place in September.

Last week, I wrote an article for HousingWire’s ReWired blog, which you can read here. In it, I say I believe there is a unique opportunity to improve this important tool to make access to credit and investment fairer while maintaining the safety and soundness of our financial institutions. Most banks have long ago learned to appreciate the value of CRA; though they are often frustrated by the how it is applied. We want CRA compliance to be fair, timely and accurate, and so do they. I am optimistic that this process will result in a strengthening of the effectiveness of CRA through sensible improvements.

There is unusually broad agreement on many areas that are overdue for CRA modernization. With the rise of interstate banking and bank consolidation, as well as the merging of investment banking and commercial banking in so many large banks, defining what constitutes a bank’s Assessment Area and how to count investments outside those boundaries is a key point of interest and one that potentially has the greatest impact for America’s cities – as well as the greatest risk to CRA's effectiveness. This is an area that must be done right.

Assessment Area definition and application present unique challenges today because banks have alternate channels for accepting deposits, like mobile and online banking, that did not exist in 1977; customers with deposits are much more mobile today, and rural areas have experienced a disproportionate number of bank branch closures not envisioned in 1977. At our meeting with Comptroller Otting, I suggested that the following tests be applied to any new approach:

  • Will there be more or less investment in low- and moderate-income communities under a new regulatory structure? Successful CRA modernization must increase investment in communities that are currently underserved.

  • Who is likely to be served by CRA investments? Will they benefit more or less underserved communities and individuals? CRA changes that disadvantage low- and moderate-income individuals, particularly people of color, are unacceptable and put all other CRA reforms at risk.

  • Will gentrification (the displacement of low- and moderate-income residents from their communities) increase or decrease? Limiting gentrification through federal policy is a vexing problem. We want underserved communities to benefit from new investment, but current residents should not be displaced by the arrival of amenities that improve their community.

  • Will bank performance be more or less transparent? Transparency is critical to CRA’s success.

We have an historic opportunity to modernize the CRA and improve the lives of millions of Americans. 
Let’s do it right!

David M. Dworkin
President and CEO
News from Washington I By Kaitlyn Snyder
Kurtz sign-on letter 

NHC signed a letter led by the Council of Large Public Housing Authorities to support the nomination of Hunter Kurtz for assistant secretary of Public and Indian Housing at HUD. If you would like to sign the letter, please email Nicole Barrett by Thursday, Aug. 8. 
Fed study: Additional building won't make city housing more affordable 

The Federal Reserve Board (Fed) recently published “ Can more housing supply solve the affordability crisis? Evidence from a neighborhood choice model.” The researchers used 2014 American Community Survey data to track rents in the context of new housing supply, finding that “rent elasticity is low, and thus marginal reductions in supply constraints alone are unlikely to meaningfully reduce rent burdens.” Rents are perhaps more likely to be tied to neighborhood amenities and thus unlikely to decrease as more housing is built. The researchers suggest improving amenities outside of core city neighborhoods may be a more effective way to decrease rents. 

Senate passes FY 2019 HUD appropriations, few housing-related amendments

Last week, the Senate passed H.R. 6147 by a 92-6 vote. The bill would fund FY 2019 HUD programs with $12 billion more than President Trump’s FY 2019 request. The bill passed with several housing-related amendments, including:

1.        S. Amdt. 3476 from Sen. Jeanne Shaheen (D-N.H.) directs HUD to ensure that survivors of domestic violence and sexual assault are not unlawfully evicted or denied housing by certain landlords based on their experience as survivors. The full text of the amendment is on page 37 of the congressional record.

2.        S. Amdt. 3621 from Sen. Gary Peters (D-Mich.) requires HUD and the Environmental Protection Agency to work with the Government Accountability Office to prepare a report on their efforts related to the removal of lead-based paint and other hazardous materials. The full text of the amendment is on page 39 of the congressional record.

3.        S. Amdt. 3671 from Sen. Dean Heller (R-Nev.) that would prohibit people charged with aggravated sexual abuse, murder, trafficking, sex trafficking or child pornography from receiving housing assistance. The full text of the amendment is on page 41 of the congressional record.
Register for Opportunity Starts at Home webinar

On Aug. 16 from 3-4 p.m. EDT, the newly formed Opportunity Starts at Home campaign will host a webinar, “Broadening the Housing Movement.” Opportunity Starts at Home is a multi-sector campaign that aims to meet the rental housing needs of low-income people. Speakers will cover the campaign’s progress, short- and long-term plans, policy advocacy goals and ways to get involved. Register here.  
View blog posts from NHC’s summer interns

Last week, we said goodbye to NHC’s summer interns, Grant Kirkpatrick and Patrick Clifford. You may have bumped into Grant and Patrick at our Annual Gala, Policy Symposium or around town, or read their stories in the Member Brief and Restoring Neighborhoods newsletters. They were both invaluable to us this summer and will be greatly missed. As a final assignment, they wrote blog posts on what they learned during their time at NHC and in D.C. Grant’s post is available here and Patrick’s is available here
Our Homes, Our Votes webinar series 

The Our Homes, Our Votes campaign is hosting a six-part webinar series on nonpartisan voter engagement. The remaining webinars will be held from 3-4 p.m. EDT on Aug. 14 and Aug. 21. Register for all of the webinars here. The slides and recording from the first webinar, “Our Homes, Our Votes: An Introduction and an Exploration of Legal Considerations,” are available here. The slides and recording from the second webinar, “Building the Base: Voter Registration of Low Income Renters and Their Allies,” are available here. The slides and recording from the third webinar, “The Importance of Voter Lists! A Key Tool for Successful Mobilization,” are available here. The slides and recording from the fourth webinar, “An Informed Debate: Effectively Engaging Candidates while Remaining Non-Partisan,” will be available here.
The National Housing Conference has been defending the American Home since 1931. Everyone in America should have equal opportunity to live in a quality, affordable home in a thriving community. NHC convenes and collaborates with our diverse membership and the broader housing and community development sectors to advance our policy, research and communications initiatives to effect positive change at the federal, state and local levels. Politically diverse and nonpartisan, NHC is a 501(c)3 nonprofit organization.
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