Search Results for “kevin hill” – NCRC https://ncrc.org National Community Reinvestment Coalition Mon, 24 Aug 2026 18:57:30 +0000 en-US hourly 1 https://wordpress.org/?v=7.0.4 https://ncrc.org/wp-content/uploads/2017/10/cropped-512_v1-32x32.png Search Results for “kevin hill” – NCRC https://ncrc.org 32 32 NCRC, Rise Economy and 374 Organizations Submit Letter to OCC, FDIC Calling for CRA Comment Period Extension https://ncrc.org/ncrc-rise-economy-and-374-organizations-submit-letter-to-occ-fdic-calling-for-cra-comment-period-extension/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-rise-economy-and-374-organizations-submit-letter-to-occ-fdic-calling-for-cra-comment-period-extension Mon, 24 Aug 2026 18:43:14 +0000 https://ncrc.org/?p=291728

Travis Hill, Chair
Federal Deposit Insurance Corporation (FDIC) 550 17th Street NW
Washington, DC 20429
Via email: comments@FDIC.gov

Jonathan V. Gould, Comptroller
Office of the Comptroller of the Currency (OCC) 400 7th St. SW
Washington, DC 20219
Via: https://regulations.gov/

Re: Community groups request an extension of the CRA comment period
RIN 3064-AG31, Docket ID OCC-2026-0694

Dear Chair Hill and Comptroller Gould,

The National Community Reinvestment Coalition, Rise Economy, and 374 community groups and national partners formally request the OCC and FDIC extend the sixty (60) day comment period relating to the recently proposed changes to the Community Reinvestment Act (CRA) rules. We believe that the significant changes suggested by the proposal necessitate a comment period of at least one hundred and twenty (120) days.

The 60-day comment period is not sufficient for effective examination of and comment on the over 350 pages of material and over 60 questions posed in this complex proposed rule. It proposes to reclassify over 1200 banks and we are concerned that many of the numerous proposed changes, if finalized in substantially the same form, would lead to considerably less reinvestment in the low- and moderate-income (LMI) communities meant to be served by the CRA. More specifically, we are concerned that proposed changes will lead to significant outcomes, including: less support for affordable housing via the Low Income Housing Tax Credit (LIHTC) and other community development activity, less transparency of small business lending, fewer community development loans and investments that support small businesses, fewer branches in LMI and rural communities, less access to affordable bank accounts and higher fees for unbanked and underbanked consumers, less capacity for community based organizations to play their critical role in supporting communities and the financial service ecosystem, and less scrutiny of redlining and discrimination by banks.

The NPRM does not appear to clearly quantify or address the costs to, and impacts on, communities of the various changes proposed. This lack of analysis of community impacts makes it difficult for the public to comment meaningfully on the proposal and puts the burden on communities to identify and quantify the proposal’s impacts. More time is needed to conduct research and analysis to understand what the agencies’ proposed changes to the Community Reinvestment Act will actually mean for communities, including Native American and Tribal communities.

We note that in 2020, when the FDIC and the OCC similarly proposed a new CRA rule, the agencies agreed to extend the comment period.1

For these reasons, the undersigned community organizations urge the FDIC and the OCC to extend the comment period on this proposal to one-hundred twenty (120) days in total.

Thank you for your consideration of this request. Should you have any questions, please feel free to contact Kevin Stein at Rise Economy, at kstein@rise-economy.org or Kevin Hill at National Community Reinvestment Coalition at khill@ncrc.org.

Very Truly Yours,

Kevin Stein
Chief of Legal and Strategy Rise Economy

Kevin Hill
Senior Policy Advisor
National Community Reinvestment Coalition

 

1 https://www.occ.gov/news-issuances/news-releases/2020/nr-ia-2020-19.html

———

List of Endorsing Organizations

Access Plus Capital
Administration of Resources and Choices
Affordable Homeownership Foundation Inc
Affordable Housing Clearinghouse
African Diaspora Directorate
Alberta Bair Theater
Allensworth Progressive Association
AltCap
Americans for Financial Reform Education Fund Ampac Business Capital
ANHD
Appalachian Community Capital
Arbor Hill Development Corporation
Artist Space Trust
Asian Americans United
Asian Pacific Islander Small Business Collaborative
ASIAN, Inc.
AssistNA
Association for Enterprise Opportunity
Bascomb Real Estate Group
Beneficial State Bank
Beneficial State Foundation
Benito Juarez Foundation
Big Tent San Leandro
Bill Sorro Housing Program
Black Economic Council of Massachusetts
Blues City CRC
Bonnewit Development Services
Boston Impact Initiative
Boston Tenant Coalition
Brown Dog Apiary
Build Healthy Places
Burbank Housing
Ca CLT Network
CA Community-Based Development
Collective California Coalition for Community Investment
California Coalition for Rural Housing
California Coastal Rural Development Corporation
California Community Land Trust Network
California Housing Partnership
California Intertribal Alliances
CAMEO Network
Carole Rogers
CASA of Oregon
Casita Coalition
Catapult Greater Pittsburgh
CB Harreld Consulting
CDFI Friendly America
CDFI Friendly South Bend
Ceiba
Center for Community Progress
Center for Mortgage Access
Central Valley Women¬¥s Entrepreneur
Center Centre for Home Ownership
Centro de Vida Victoriosa Inc.
Certified Commercial Realty
Charity Cultural Services Center
Chattanooga Neighborhood Enterprise
Chicago Community Loan Fund
Chicago Lawyers’ Committee for Civil Rights
Chinatown Community Children’s Center
Chinatown Community Development Center
Chinese-American Planning Council
Citizen Potawatomi Community Development
Corporation City of Hartford
City of Little Rock
CLARIFI
Climate Reality Project – NJ
Coalition for an Equitable Economy
Coalition of California State Tribes
Coastal Bend Sierra Club group
CoBiz Richmond
Common Counsel Foundation
Commonspace CLT
Communitas Veterans Agency Inc
Community Alliance with Family Farmers
Community Development Network of Maryland
Community Economics, Inc.
Community Housing Council of Fresno
Community Housing Development Corporation
Community Services Employment Training
Congregations Organized for Prophetic Engagement, COPE
Consumer Action
Consumer Federation of America
Consumer Federation of California
Consumers for Auto Reliability and Safety Foundation
Crowdfund Better
CRT
Debthelper.com
Delaware Community Reinvestment Action Council Inc.
Designated Exceptional Service for Independence
Dominican University
DPRA Group.Inc
Dunn Police Athletic & Activities League, Inc.
E. Rene’ Soule’ & Associates
EastBay Housing Organizations
East Los Angeles Community Corporation
East Missouri Action Agency, Inc
Eastside Opportunity Ventures
Empire Justice Center Enterprise Development Fund
Enterprise Management Consulting LLC
Envision Realty, Inc.
Epic Community Impact Fund
ESHARA (Ethnic Self-Help Alliance for Refugee Assistance)
ESO Ventures
Esperanza Community Housing Corp
Esperanza Community Land Trust Exp
Fair Finance Watch
Fair Housing Advocates of Northern California
Fair Housing Center for Rights & Research
Faith and Community Empowerment (formerly KCCD)
Family Resources of New Orleans
Filipino Community Development Corporation (FCDC)
Finanta
First Community Capital FMK, llc
Foundation for Filipina Women‚Äôs Network
Frank Carvalho Consulting Services
Freedom Equity Inc.
Genesis Historymaker CDC
Genesis LA
GES Coalition
Global Detroit
Greater Philadelphia Hispanic Chamber of Commerce, President & CEO
Green West Strategies
Green+
Grounded Solutions Network
Growing Together
Guapaholics
Habitat for Humanity Pasadena
Habitat for Humanity St. Tammany West
Haven Services
Hawai’i Alliance for Community-Based Economic Development
Health in Partnership
Heartatwork LLC
Hip Hop Caucus
His Sanctuary Community Development Corporation
Homestead Resources
Hope and Action: An Economy for All
Hope Village Revitalization
Housing Action Illinois
Housing and Economic Rights Advocates
Housing and Family Services of Greater New York
Housing California
Housing Channel
Housing Justice Center
Housing Now!
Housing Opportunities Made Equal of Greater Cincinnati
Housing Opportunities of Fort Worth
Housing Oregon
Housing Rights Center
Human Relations Council
I Rise FL, inc.
ICON CDC
IFF
Imole Otito Community Service
Impact Clint
Inclusive Action for the City
Inclusivity Institute
Indianapolis Neighborhood Resource Center
Indigenous Futures Society
Inland Empire Prism Collective
Inland Equity Community Land Trust
Inland SoCal Housing Collective
Innovative Housing Opportunities, Inc.
Isles, Inc
Jacksonville Area Legal Aid
Jamaica Plain Neighborhood Development Corporation
James’ Solar
JEDI
Jewish Family Services of Washtenaw County
JOURNEY TO DEVELOPER INITIATIVE, INC.
Joy Community Association
Justice Informed
Keene Development
Kingdom Community Development Corporation
Knowledgepanel
KPT Consulting
LA Forward
Lacasa, Inc.
Lafayette Habitat for Humanity
Land + Liberty
Larger Aim
Latino Leadership Council
Latino Texas Policy Center
Legacy Landmark Holdings
Leviticus 25:23 Alternative Fund, Inc.
LHOME
Little Manila Rising
Little Tokyo Service Center
Living Cities, Inc.
Local First Arizona
Logan Heights Community Development Corporation
Los Angeles
LDC
LUCHA (Latin United Community Housing Association)
MAHA
Manilatown Heritage Foundation
Massachusetts Association of Community Development Corps (MACDC)
Mastin Real Estate Services
MAUC
Melon 29:7 SE
Michigan LLC
Metro Milwaukee Fair Housing Council
Microenterprise Collaborative of Inland Southern California Midland Community Development Corporation
MidPen Housing Corporation
Mission Economic Development Agency MNC
Monte Vista Care Home LLC
Monterey County Black Caucus
Mothers with DAR Fighting Human Trafficking
Multicultural Real Estate Alliance
My Way Home (DBA of VCCDC)
MyPath
NAACP Stockton – San Joaquin County Branch
NACDC Financial Services
NARRATUR STUDIO LLC
National Association for Latino Community Asset Builders (NALCAB)
National Coalition for Asian Pacific American Community Development (National CAPACD)
National Community Development Association
National Consumer Law Center (on behalf of its low-income clients)
National Fair Housing Alliance
National Housing Resource Center
National Low Income Housing Coalition
National Urban League
Natural Resources Defense Council (NRDC)
Neighborhood Concepts, Inc.
Neighborhood Development Alliance, Inc.
Neighborhood Housing Services Los Angeles County
Neighborhood Housing Services of New York City
Neighborhood Housing Services of the Inland Empire (NHSIE)
Neighborhood Housing Services Oklahoma
Neighborhood Improvement Association
Neighborhood Partnership Housing Services
NeighborWorks Laredo
New Community Federal Credit Union
New Economics for Women
New Hope Housing Inc.
New Jersey Citizen Action
New Way Homes
Nimiipuu Community Development Fund
Nixyaawii Community Financial Services
Northeast Community FCU
Northwest Center Chicago
Office of Community and Economic Development
Old North St. Louis Restoration Group
Open Communities
Operation HOPE
Operation Relief Center
Opportunity Resource Fund
Orange County Asian and Pacific Islander Community Alliance (OCAPICA)
Oregon Consumer Justice
PACE Finance Corporation
Pacific Community Ventures
Pacific Islander Community Partnership
Pacific Islander Health Board of WA
Paterson Housing Authority
PCR Business Finance
Pennsylvania CDFI Network
People’s Opportunity Fund
People’s Self-Help Housing
Philadelphia Association of Community Development Corporations
PHIL-WILL CONTRACTING
Piedmont Housing Alliance
Pima County Community Land Trust
Pittsburgh Community Reinvestment Group (PCRG)
Placer People of Faith Together
Pleasant Drive Animal Rescue
Prestamos CDFI
Private Law Office- Jan Perkins Law Office
Prosperity Indiana
PT Partners Public Counsel
Puerto Rico NHS Corp.
Quarles Realty Development Enterprise
RAIL CDC
RAISE Texas
RCAP Solutions, Inc.
RealTree Capital Advisors
Rebuilding Together
Redbud Financial Alternatives, Inc.
Reinvest Toledo
Renaissance Economic Development Corp.
Renaissance Entrepreneurship Center
Resilience OC
Revitalize Community Development Corporation
Riverworks Development Corporation
RMJAssociates
Rural Community Assistance Corporation (RCAC)
Rutgers CLiME
Sacramento Housing Alliance
San Francisco Community Land Trust
San Joaquin Valley Housing Collaborative
Sand Hills Urban Development Inc
Sandra Morey Company
Sawyer County Housing Authority Scale Link
SCANPH
Scientists for Social Progress
Self-Help Enterprises
Sierra Business Council
Sisters of Seton Hill
Small Business Majority
Smith Aquatic
Safety Service
Social Equity Empowerment Network NY
SOUTH ASIAN NETWORK, INC
Southeast Asian Community Center
Southern California Black Chamber of Commerce
SouthFair CDC
Southwest Fresno CDC
Springboard CDFI
St. Bartholomew Parish
St. Philip’s School & Community Center
Stanislaus Community Foundation
Stanislaus Equity Partners
Stark Mountain Woodworking Starting Over Inc
State of AZ
Stearns
Supportive Housing Alliance
Taala Fund
Tacoma-Pierce County Affordable Housing Consortium
Texans For Housing
Texas Appleseed
Texas Housing Conservancy
Thai Community Development Center
The Academy of Financial Education
The Black CREED Institute of America
The Cedric Group
The Central Valley Urban Institute
The Enterprise Center at PathStone
THE FAIR HOUSING COUNCIL OF SAN DIEGO
The Fair Housing Council of The Capital Region
The Greenlining Institute
The Housing Fund
The Olevia Community Development Corporation
The Public Interest Law Project
The Redress Movement
The Sacramento Environmental Justice Coalition
The Unity Council
Toledo Design Collective
Transparency Task Force
TREC Community Investors
Turtle Island Community Capital
Two Valleys Community Land Trust
U SNAP BAC NON PROFIT HOUSING CORPORATION
United Housing, Inc.
United South Broadway Corporation
United Way of San Diego County
Universal Housing Solutions CDC
UpSpring Associates
Uptima Entrepreneur Cooperative
Urban Habitat
Urban Land Conservancy
Urban Strategies, Inc. (USI)
Urban Sustainability Directors Network (USDN)
US Green Bank 50
Vacant and Abandoned Property Action Council
Vianey Gibbons Consulting
Waco Habitat for Humanity
Walker Montgomery C.D.C.
Washingtonians for Public Banking
WE ACT for Environmental Justice
West Community Economic Development Corporation
West Oakland Job Resource Center
Westside Neighbors United
Wildlings Conservatory
Women’s Economic Ventures
Women’s Resource Network (WRN)
Womxnwise
Working Solutions CDFI & Main Street Launch 1DROP

]]>
NCRC Mourns Loss of Board Vice Chair Irvin Henderson https://ncrc.org/ncrc-mourns-loss-of-board-vice-chair-irvin-henderson/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-mourns-loss-of-board-vice-chair-irvin-henderson Tue, 11 Aug 2026 17:07:45 +0000 https://ncrc.org/?p=291393 The National Community Reinvestment Coalition (NCRC) mourns the passing of Irvin Henderson, a devoted champion of NCRC’s mission who had been part of the organization since its founding in 1990 as a founding board member, served as one of NCRC’s first board chairs and most recently served as vice chair.

“We are deeply saddened by Irvin’s sudden passing,” said Jesse Van Tol, NCRC’s president and CEO. “As one of the founding board members of NCRC, he played a pivotal role in shaping our organization and was a tireless champion of our cause. For many of us, he was a friend and a trusted voice — someone who cared very deeply for his family, his colleagues and NCRC. He was a lion of the community development movement. May he rest in power. ”

“Irvin’s leadership was grounded in a belief that every community deserves the opportunity to thrive,” said Carol Johnson, NCRC’s board chair and president and CEO of Johnson Consulting Group. “As Board Chair, I was fortunate to have in Irvin not only a trusted colleague and Vice Chair, but someone whose history with NCRC reached all the way back to its founding. He understood where this organization came from, why this work matters and how much perseverance it takes to turn our values into meaningful change. Irvin brought that perspective to every conversation, always keeping the people and communities we serve at the center. The standard he set and the work he helped build will continue to guide us.”

“For almost two decades I’ve served with, listened to and admired Irvin Henderson—a friend, a mentor and someone who used his knowledge, his intellect, and his voice to speak on behalf of communities of people for whom he cared so deeply,” said Bob Dickerson, past NCRC board chair, current board member and executive director of the Birmingham Business Resource Center. “I recall with gratitude Irvin pulling me aside when I first joined the NCRC Board. He welcomed me warmly and offered to share his experience and insight, saying he wanted to help me make a greater contribution. That gesture reflected who he was at his core: generous with his time, intentional in his support of others, and committed to lifting those around him. Irvin was always prepared, always thoughtful, and always spoke with wisdom. He carried himself with a quiet integrity that never needed to be announced, only witnessed. Those who had the privilege of working alongside him will never forget the steadiness of his presence or the clarity of his voice when it mattered most. I am deeply grateful for the years I had to serve with him. Irvin’s legacy lives on in the communities he championed, the colleagues he guided, and the many lives he touched along the way. He will be deeply missed and long remembered.”

“Irv was many things to me and others…bright, funny, impactful, smart and a leader,” John Taylor, NCRC founder and longtime CEO. “I owe him a great deal and I will remember him for the rest of my life.” 

“Irvin was a passionate, committed, incredibly hard worker – and for me personally, a dedicated friend and mentor,” said Bethany Sanchez, NCRC board member and fair lending administrator for the Metropolitan Milwaukee Fair Housing Council. “Irv’s passing will hit NCRC leadership and members hard, leaving a hole in our hearts.”

“Nobody cared more about, or supported more, NCRC and its work than Irv,” said Kevin Stein, NCRC board member and chief of legal and strategy at Rise Economy. “He was gracious and respectful to all stakeholders in talking about communities, always inviting people in. And he also had strong values and spoke forcefully and compellingly about the dignity and opportunities that people and neighborhoods deserved. May his memory be a blessing to his family, and to all of us.”

“In 2012, Irv Henderson and I were part of a team pitching to the city of Raleigh, NC about how to redevelop and revitalize the historic John Chavis Memorial Park, initially created as the ‘Colored park’ serving only Black people in the 1930’s,” said Vernice Miller-Travis, NCRC board member and co-founder of We ACT for Environmental Justice. “We were zipping through our presentation when Irv recounted how he had learned how to swim as a child in the pool at the park. But as he got older, he was unable to earn his Boy Scout Eagle Scout Badge because he needed to be able to swim the length of an Olympic-size swimming pool, and the only pool available to him did not meet that criteria. As I looked around the room at City of Raleigh Department of Parks, Recreation, and Cultural Resources staff, I could see as Irv was recounting his childhood experience with segregation that ran right through that very park, that that was when we won the bid. Today, John Chavis Memorial Park has been completely reimagined, redesigned and revitalized via a $40 million capital investment by the City of Raleigh based upon the revised master plan that we created. It has also been added to the National Register of Historic Places. It is but one in a very long chain of examples of how Irv saw things others didn’t see, imagined what could be, and then went to work to make his vision a reality.” 

“As a new Board Member in 2019, I remember with great admiration and respect meeting and seeing Irvin Henderson in action at the Just Economy Conference where we were meeting with FHA Commissioner Brian Montgomery,” said Aaron Miripol, NCRC board member and president and CEO of Urban Land Conservancy. “Irvin’s passion for community came out loud and clear as he spoke to the commissioner on the challenges NCRC’s members were having with FHA financing. In addition, Irvin was kind enough to include me, the newbie to NCRC, in the conversation and asked me to share my Colorado experience with Commissioner Montgomery. That is what made Irvin so special, his incredible knowledge and experience as a community developer and NCRC Board member, layered with his ability to include, engage and educate all of us. His passing is a loss for all of us, and yet Irvin’s greatest gift to NCRC was not just his expertise, but his commitment to lifting others up—and that is the standard we must all now aspire to. The call to action for NCRC has never been greater, and Irvin’s influence on all of us is what must lead the day going forward. Thank you, Irvin!”

“I will never forget the things Irv worked with us on at NCRC, from the Historic Tax Credit to the fights with Capital One to carrying the message, again and again, to Capitol Hill,” said Matthew R. Lee, NCRC board member and executive director of Inner City Press. “Irv’s passing leaves a hole in our advocacy. We must all work hard to keep up the fight, now with CRA under attack from the OCC and FDIC. Do it for Irv…”

“I was constantly awed by Irvin’s unrelenting advocacy for economic justice, his poise and decorum, and his work ethic,” said Elisabeth Risch, NCRC board member and executive director of Housing Opportunities Made Equal of Greater Cincinnati (HOME). “He showed up for calls in airports, cars, always en route across the country in pursuit of making local communities better and more equitable. He was a power-broker with the interests of the underserved community front and center. He never let me forget that family was the most important. He always asked about my family, reminded me to take care of myself and my family. That balance of fierce advocacy and genuine care is what I’ll carry forward.

“Having been a lifelong member of NCRC, I always associated Irvin with this wonderful organization more so than anyone else,” said Roberto Barragan, NCRC board member and executive director of ICON CDC. “His dedication, optimism and tenacious defense of CRA  was a sight to behold. His ability to speak on any subject to any audience with understanding and insight was always awe-inspiring.  And to see over the years, his love for the organization was never diminished, and his willingness to fight was greater than ever.”

“It was an honor to know Irv. He could always start a conversation or take the lead in any conversation in a positive manner – Irv knew everything,” said Charles Harris, NCRC board member and executive director of Housing, Education and Economic Development. “He was a mentor to all of us, and I noticed that whenever we were in a committee meeting and the moderator was waiting for a response  [when the room was quiet] everybody waited for Irv to take the lead or answer the question. When I became a member of NCRC, he gave me a great welcome and we became good friends. Over the years, outside of us discussing CRA and economic justice, we talked about jazz and blues music. NCRC and the industry has lost a person with lots of knowledge and he will be sorely missed.”

“I will miss Irv’s tenacious approach to all that he encountered,” said Peter Hainley, NCRC board member and executive director of CASA of Oregon. “That gleam in his eye! A true warrior for economic justice, he will be sorely missed.” 

“Irv had a total and wonderful devotion to NCRC,” said Sharon Lee, NCRC board member and executive director of the Low Income Housing Institute. “I loved what he would say in our meetings. His excellent leadership propelled the movement forward!” 

“I am saddened of the loss of my teacher, who became my dear friend and mentor,” said Ernie Hogan, NCRC board member. “His passion for uplifting underserved communities through preservation, affordable housing and economic development spilled over all of us he touched! It was Irvin who showed me the value of CRA! How it connected our work of communities with the banking and finance world!  That is was worth fighting for its future. His work, his words, his friendships will not be forgotten as we all take what Irv has taught us forward!! I will miss my friend!”

Henderson was the principal of Henderson & Company, a consulting firm and development company with particular expertise in the areas of community development and historic preservation, and commercial, residential and enterprise development. He was a trustee of the National Trust of Historic Preservation for Henderson, NC, and he sat on many additional boards devoted to community development and preservation. 

NCRC invites all who knew Irvin to submit stories, photos and tributes to be shared with the family.

Photo: Irvin Henderson at the 2026 Just Economy Conference, April 14, 2026, in Washington, DC.

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Video: Your Membership, Your Benefits – A Closer Look at NCRC Membership – July 2026 https://ncrc.org/video-your-membership-your-benefits-a-closer-look-at-ncrc-membership-july-2026/?utm_source=rss&utm_medium=rss&utm_campaign=video-your-membership-your-benefits-a-closer-look-at-ncrc-membership-july-2026 https://ncrc.org/video-your-membership-your-benefits-a-closer-look-at-ncrc-membership-july-2026/#comments Mon, 03 Aug 2026 20:03:30 +0000 https://ncrc.org/?p=290746 Online Event Archive Recorded July 23, 2026

Are you making the most of your NCRC Membership?

Learn what resources, services, content and networking opportunities your membership includes and how being a NCRC member can help you in your fight for a #JustEconomy. NCRC staff share tips for making the most of your membership and provide a walk-through of NCRC’s newest member features.

 

Speakers

  • Caitie Rountree, Director of Membership and Events, NCRC
  • Diane Ashong, Membership Engagement Manager, NCRC
  • Ralph Cyrus, Membership Engagement Specialist, NCRC
  • Tara Flynn, Policy Director, NCRC
  • Jacelyn Matthews, Director of National Training Academy, NCRC

Transcript:

NCRC video transcripts are produced by a third-party transcription service and may contain errors. They are lightly edited for style and clarity.

Rountree 0:06
Well, welcome to this conversation on what it means to be an NCRC member. We’re excited to have you here. Whether you are a longtime member learning a little bit more about our membership benefits, a newer member, an organization exploring membership, or maybe you are a staff person at an organization that’s been a member for a long time, but you’ve never actually directly engaged with NCRC. Wherever you’re coming from today, we’re glad you’re here.

Just a little bit of housekeeping before we jump into our conversation today. This event, as all our events, whether virtual or in person, is subject to NCRC’s code of conduct. Please take a look at that if you need a refresher on like to engage in spaces respectfully. But high expectations of all of you. One note: we do not allow AI chatbots on the webinar. This webinar is being recorded, and the recording and slides will be shared afterwards. So our staff will be removing chatbots, but don’t worry; the content will be shared with all registrants afterwards. Please submit questions along the way in the Q and A button at the bottom of your screen. A small thing: if you have updated Zoom recently, you may look for that box and find that it has moved. If you don’t see it where you normally do, click on the more icon with the three dots and look for the Q and A box there. And we’ll answer some of those as we go along. And we’ll also pause along the way to answer verbally. And make sure to follow us on our social media accounts so that you can stay in the loop with new developments.

All right, I would love to introduce the rest of our speakers today, and before we get to that, I’ll I’ll tell you a little bit about NCRC as an organization. So we’re a national advocacy organization, a network of over 700 member organizations working to advance wealth equity by improving how capital flows into communities. We convene leaders just like you across sectors to advance policy change, expand opportunities, and strengthen a financial system that better serves communities and shares prosperity. We do that through three primary strategies: by boosting knowledge, by building capacity, and by bridging access. Together, these strategies help create an economy where communities have greater power to shape local growth, where families have a fair opportunity to build wealth, and financial institutions are more accountable to the people and communities that they serve. That’s the foundation that NCRC was built on. So the natural next question is, what does that mean for you, and why does it make sense to be a part of this coalition?

So NCRC combines advocacy, coalition building and accountability strategies to drive systemic change. As a national convener, we bring together community organizations, policymakers, financial institutions and corporate leaders to develop solutions that strengthen communities and expand opportunity. Our network-driven approach connects local experience, policy expertise and investment initiatives that ensure that communities have both a voice and a seat at the table. You’ve heard what NCRC is and what we do, but membership isn’t measured by a list of benefits. It’s measured by what those benefits actually make possible. So instead of giving you a catalog of services, I’d actually like to show you membership in action. We’re going to talk about a real member, anonymous, but I think you’ll be able to get a sense of the organization, a real challenge that they brought to us, and just one way that NCRC helped them achieve an outcome that they couldn’t have accomplished as easily on their own.

One of our members is a homeownership nonprofit in the Upper Midwest that operates a down payment assistance loan program. Like many community organizations, they were doing really important work, but they didn’t have an in-house research team. They wanted to better understand their program’s impact, where it was succeeding, where there were opportunities to improve, and how to communicate those findings to the partners and funders investing in the work. So they came to NCRC’s research team for help. Our researchers conducted a loan-level analysis and delivered a comprehensive impact report, complete with data visualizations, supporting analysis and practical insights they could immediately put to use. The result wasn’t just a polished report; it helped the organization better understand what was happening in their community, so they could strengthen their program and better meet local needs. It also gave them credible evidence to show partners and funders how investing in this work could improve the flow of capital in the community and expand opportunities for homeownership.

That’s what membership looks like across our network. Your organization doesn’t have to solve every challenge alone. Through the coalition, you gain access to research, to policy expertise, training, and relationships that help your organization better understand community needs, strengthen your work, and ultimately help communities shape how opportunity and investment flow where they’re needed most. So, if we can move to the next slide, I’m about to introduce you to a couple of different people who bring that same kind of support in very different ways. Tara from our policy team, and then Jacelyn from our National Training Academy. They’ll show you two more examples of how NCRC’s expert staff partners with members to strengthen our communities. So Tara, I’m going to turn it over to you.

Flynn 5:01
Great, hi everybody. I’m Tara Flynn. I’m NCRC’s policy director. Just for context, I started here about six months ago after a career in federal government as a consumer protection attorney at the FTC and the Consumer Financial Protection Bureau. Our policy team is small but mighty, and I should note that we work really closely with the research team that got such a nice shout-out just now, Caitie. You know they do fantastic work, and they provide essential data analysis for our policy work, and obviously provide that same assistance to members. So officially, the policy team is four people. We’re all up on the screen. Our fearless leader, Eden Forsythe, who heads up policy and research. Kevin Hill, who is a senior policy analyst, and he focuses a lot on Community Reinvestment Act-related issues. Manon Shah, he’s a policy analyst who focuses on CDFI and small business issues, and I focus on the intersection of fintech and banking. And lately, that has meant I’ve been focusing a lot on stablecoin and crypto. We, you know, I’ve said we specialize or focus on certain areas, but we are all available. If you ever need anything, you don’t need to know which one to talk to. We all talk to each other. So, what does this policy team do? Well, we provide strategic direction on policy research and advocacy for NCRC. That means you know we think about how we should deploy our resources, what issues we should prioritize, what we should engage on, and what we should respond to. We also analyze policies and proposals and translate them into hopefully practical guidance for members. That’s figuring out essentially how legislative and regulatory proposals impact our core issues, and I’ll talk a little bit more about that in a bit. And we also create a lot of educational content, webinars, things up on our website, and you know, comment letters, draft model comment letters, things like that that can help educate and provide assistance to our members.

We form strategies for our advocacy, and you know that again, we want to figure out how can we effectively impact the debate and hopefully impact the outcome. So we also try to bring members’ experience into policymaking, and one way we do that is connecting members with Capitol Hill staff. For example, in connection with our opposition to the digital asset market structure bill known as the Clarity Act, we requested meetings from the staffs of senators who had voted for the Genius Act, which is the bill that was passed last year about stablecoin. But the Clarity Act is a broader bill, and so we wanted to talk to senators before they voted on it in at the Senate Banking Committee. So one of our big concerns is whether stablecoin and crypto might cause the deposits to migrate out of banks, and then deposits wouldn’t be available for lending and investment in communities. So we made our request for these meetings. We got a couple meetings, and then we reached out. One was in Georgia, Senator Ossoff of Georgia, and Senator Gallego of Arizona. And then we got members. We asked members, and they graciously agreed to attend these meetings with us as constituents, and that really helped. Their participation and their sharing of their stories of how a lack of capital impacts their communities was really helpful, and I think strengthened our advocacy. So that’s just an example of the way that we try to do that, bring stories to Capitol Hill. And we also mobilize membership around our shared priorities, and you know try to identify opportunities to influence public policy. We’ll talk a bit more about it on a later slide, but there are lots of opportunities for NCRC members to influence public policy and our advocacy. So I have a quick example from this week. There was the House Financial Services Committee was considering a bill called the Main Street Access to Capital Bill, which had some good CDFI provisions in it, but mostly it was terrible. It was a deregulatory bill, so the vote was coming up fast. We had to mobilize quickly. We wrote a letter and we sent out a call to members to see if they would sign on. And even though we only had three hours to do it, we got 30 members to sign on. And then the ranking member of the House Financial Services Committee actually referenced the letter, and most importantly, that members from throughout the country had signed on to it. So mobilizing membership and using our collective voice is an important part of what we do.

So what are our priorities? So they’re written out here, and I think they’re probably, hopefully, shared priorities for you all too. We want to hold financial institutions accountable to communities, especially the communities that they serve. We want to strengthen and protect the Community Reinvestment Act and fair lending laws. Advance fair lending and combat discrimination in mortgage lending, appraisals, and insurance and access to housing. We want to expand affordable home ownership, rental housing, responsible credit for underserved communities, and increase investment in CDFIs, affordable housing, and community development.

So, how can we work together? Well, I already talked a little bit about comment letters. I gave the you know previous example, but that is one way that we are able to work together, have a collective voice. We often also provide draft comment letters or help member organizations with their comment letters about legislation, or actually, you know, regulation, which is another big area that we focus on. We hold a monthly call to keep members apprised of what our regulatory or legislative developments in that may actually impact our priority areas. So that’s something that’s a give and take and a conversation. And we also have Hill Day on there. During the Just Economy Conference, we dedicate a whole day to going to the Hill to share our stories and share our priorities with members of Congress and well, more likely their staffs. But it’s a great opportunity for us all to create and enhance our relationships with members of Congress and promote NCRC’s legislative priorities. And we coalition and connection formation-that’s super important. We all don’t all have the same issues that we value different issues differently, and so it’s important that when people have priority issues, that we can work, you know, get the group of people who are really interested in a particular issue together and share ideas. So we set up smaller groups, talk about issues. For example, we have a group that talks about 1071 business lending data collection. We have another one that someone suggested recently on leg-reg call about Small Business Administration loans and lending practices. These coalitions can also include work with state groups, several state groups where we’re trying to advance legislation. We had a very successful effort with advancing legislation in Illinois for a state CRA, working with the Illinois CRA Coalition to strengthen Illinois’s CRA law. And speaking of CRA, sort of going back to the you know how we can stay informed and mobilize our members. I wanted to do a quick shout-out for the fact that we are having a webinar next Wednesday at 330, and that is, you know, the NCRC’s president and CEO Jesse Van Tol and the policy team will be sharing our latest intel about proposed changes to the Community Reinvestment Act and how to work together to prevent it from being significantly weakened. So that’s just an example of I think of several of these things that we’ve talked about. But providing ways to stay informed, mobilizing our membership, and I think it’s a great example. And I hope any of you who are interested do attend. I think I’ve covered everything. I hope that I gave you a little bit of a flavor of the kind of policy work we do, and you know how we can work together to try to advance our priorities. So, if you have any questions, please contact me. I shared that picture because that was right before I testified before Congress. Very exciting day for me.

Rountree 13:59
We all cheered really loud for Tara. Yeah, thank you so much, Tara, for sharing and for your continued advocacy on behalf of and with our members. So research helps our members understand what’s happening in their communities. Our policy team helps shape the systems that affect those communities. But lasting change also depends on the people doing the work every day, that’s where our National Training Academy comes in. Jacelyn and her team equip practitioners with the knowledge, skills, and technical assistance they need to translate ideas into action and create stronger outcomes in the communities that they serve. So, Jacelyn, I’m going to turn it over to you to introduce your team and talk about how y’all work with NCRC members,

Matthews 14:41
Thanks, Caitie, and thank you all for being with us this afternoon to learn more about the benefits of membership. As Caitie mentioned, I’m the director of the National Training Academy here at NCRC. My name is Jacelyn Matthews, and on my team is Doug Mollet, who is our program manager, Sally Sim, who is another program manager, and then Simon Wang, who is our project specialist. I will say that Doug and Simon are leading our work when it comes to economic mobility, and then Sally works really closely on our housing counseling trainings.

So just to kind of give you an idea of who we are and what we do as NTA, the National Training Academy here. We really are the professional development and capacity-building arm for NCRC. So we work on equipping nonprofit organizations, housing counselors, as I mentioned, financial counselors, workforce development professionals, and community practitioners with the tools they need to really strengthen their organizations and better serve their communities. We want to make sure people feel really equipped to do the work they do, so any way that we can hone or enhance those skills, we are here to do so through the trainings that we offer. So it’s whether through our trainings, whether it’s like technical assistance that we offer, peer learning cohorts, and specialized initiatives, our goal really is to help organizations build capacity and create lasting community impact.

Um, so they already switched over to the slide that talks about the work that we do and the type of topics that we cover through our programming. So as you can see, we’re offering live webinars and virtual trainings. We don’t want a webinar just to be a webinar. We don’t want you to spend 90 minutes of your day just to kind of have information kind of force-fed to you. We really want it to be a deeper dive on a topic that is of interest to you. So we do like to get feedback from our community about what are some of the things that they’re seeing in the field that they want to learn a little bit more about. We try to be as responsive as possible in what we offer. We do offer multi-day, in-person trainings, usually just on one topic, where again we’re trying to drill down and give you really like the meat of the topic, so that you feel better prepared to do the work that you are already doing a great job at. But how can we help to hone some of those skills? As I mentioned, place-based learning experiences, professional development for individuals and teams. Again, if you’re wanting to grow your team and build on their tools, we want to make sure we’re able to do that as well. Technical assistance and implementation support, specialized workforce and economic mobility initiatives, and as you can see here, we cover a range of topics. This is not an exhaustive list; it’s just an example of some of the things that we cover. But wanted to give you an idea of what we do.

I did want to highlight some of the work that our economic mobility team has been working on with our SNAP E&T. So SNAP E&T is employment and training. They’re focused on that. So this initiative helps NCRC, NCRC is helping actually workforce development organizations to understand, launch, and strengthen SNAP employment and training programs that connect individuals receiving SNAP benefits with education, skills training, employment opportunities and supportive services. So NTA provides technical assistance and toolkits statewide, learning cohorts and peer learning opportunities that help organizations navigate program requirements and become successful third-party providers. So this work expands organizations’ ability to secure additional resources for their organization, while increasing economic mobility for communities that they serve. And so, we’ve seen some of that take place in Kentucky, for example. We were able to get a number of organizations to be able to get this additional SNAP E&T funding, and that’s something that we have really prided ourselves on what we’ve been able to do, and if you’re wanting more information about that, that information I think is going to be dropped in the chat, so you can kind of get a better sense of the SAP E&T work.

I also want to mention before we move on to the next one. So when it comes to our professional development for individuals and teams, just to give you an idea of what we do there as a member, if you are reaching out because you have some changes on your staff, or there’s some key items and things that you want them to learn and grow in, we have been able to send out an instructor that can actually lead trainings for you in the organization within your within your organization or within your your center or your offices. So it’s not that you have to bring everyone over to where we are to learn said topic. If it is an in-person training, it’s not that you can only bring one or two people and have to bring back the information. This is something that you can actually reach out to us and say, like, hey, we would like someone that can bring this information to our office so that everybody can hear it in real time and be able to respond and ask questions, etc. So that is a benefit as well.

As a member of NCRC, how you can leverage the work with NTA. So again, there’s access to discounted member pricing on trains and events. Right now, there is a cost for all of our trainings, but the great thing is that members receive either free or heavily discounted access to said trainings. You’re able to attend member-exclusive webinars, develop new and existing staff through professional development, as I mentioned before, earn continual education credits when available, staying informed about emerging policies, regulations, and best practices, and I won’t read all of these here to you, but I think that what I want to highlight is that we also work really closely with other departments across the organization. So if they’re wanting to put on webinars to showcase subject matter expertise internally about the work that they’re doing, we work with them to create those topics as well. So we are not just focused on housing counseling and economic mobility, but there’s opportunities for you to have a better understanding of the work that’s happening across the organization through some of the webinars that we do hold as well.

And so, I do want to make sure that I make mention of if you are interested, particularly when it comes to housing counseling topics. Part of the great thing about what we offer is that you’re able to get all of the prep that you need to either become a housing counseling agency, to be certified as a HUD-certified housing counselor, or even to become a HECCOM-certified housing counselor, do offer those trainings as well, so that people are able to get what they need. Whether that is as a virtual training, we had an in-person training in Milwaukee on HECCOM just last month, or if it is something that we’re able to offer, so that if you’re not able to actually join for the virtual training that’s happening when it comes to HECCOM or housing counseling, that there is something that’s self-paced, right? So that you’re able to do it on your time and then be able to come back and ask questions and you know receive support on those things as well. So I do think that what we have to offer, one, we are getting some of the best trainers in the business, right? So that you are again information that’s on the cutting edge of what’s out there. Nothing’s dated. We try to make sure that we are always giving you something that’s new, exciting, and fresh because we know that things are constantly changing, right? In the work that you do, and so how can we make sure that we are consistently relevant in what we have to offer?

And so those are some of the things that we do offer. If you ever have questions about topics that we offer or ideas about topics, also are really open to hearing that as well from our members to make sure again that we are providing things that are relevant to the work that you’re currently doing and things that you’re wanting to learn and grow in. With that being said, I’ll turn it back over to Caitie.

Rountree 22:06
Thanks so much, Jacelyn, and I’ll make a direct plug here. If you have not done a training with NCRC yet, I would really strongly recommend that you start with CRA content that our training academy offers. What you’ll find at NCRC is that while we work on a variety of issues, not all of them directly tied to CRA, understanding how NCRC engages and thinks about the Community Reinvestment Act serves as a really good foundation and entry point for a lot of the ways that we work with our members and with financial institutions, and so that is a great start here really, before engaging in other trainings, policy work, research, it’ll just give you the lens to see a lot of the other work that we do with our members. So, if you’re not sure where to start, that’s where you start. So, I’m gonna turn it over in a minute to talk more about some of the specifics of membership. But wanted to pause for a handful of questions here for Tara or Jacelyn about the way our policy teams and our training staff work to support members. And just as a reminder, this feels like a good point to remind folks that we will be sharing the recording and the slides, and our membership team is also happy to follow up with additional questions and support following this webinar.

The first question that I’d like to turn over to Jacelyn and then Tara, because it actually I think touches on both of their support to members, is a question about advocacy training for nonprofits. So for organizations that are interested in support for to do advocacy at the local, state, and federal level, how do we support members in that work? Jacelyn, I’m going to start with you, and then actually, Tara, there might be additional ways of support that you want to highlight as well. So, Jacelyn.

Matthaws 24:00
Sure. So first, I will say that when it comes to advocacy, if you’re wanting to learn how to actually go about doing that, we have wanted to start trying to offer more training on those topics. So, actually, how do you actually go about doing advocacy work? We’ve done something. We’re starting out with our community investment institute, which is really trying to deep dive into a couple of different things when it comes to membership. But that’s one of the things that we’ve been talking about: is how do we actually provide additional training and resources for those who are wanting to learn about what advocacy is? And then, for example, we’ve done recently the training before Hill Day this year. We did a storytelling workshop so that people can feel more connected to their story and feeling really confident about their story when they’re going to actually speak to their state or federal legislator. And so it’s something that we have seen as something that is important for us to do. Really working on curriculum that really meets the need in the moment as well. Don’t want it to be a flyby night. Hey, we put something together, but want to be really intentional about it. And so, it is something that we are working to build out and really be able to showcase soon. And I’ll leave it to Tara if she has something additional that she would like to share there.

Flynn 25:15
Hi. Yeah. I guess I’d just say that often in terms of how to advocate regarding a particular issue, we do that through our smaller working groups or through, you know, the development of materials that we share with members when we’re working on a campaign. So, for example, I mentioned what was you know there are some developments regarding the Community Reinvestment Act, perhaps some re-examining anticipated by the regulators, and so we are in the throes of thinking through what kind of materials and educational and training materials we can put together so that folks, NCRC members, can help, you know we can help mobilize, and folks will mobilize and use those resources to you know tell the story of how the CRA is important to you know every organization. I don’t know if that addresses the question, but I think that it’s more campaign focused in terms of what sort of resources we developed on the policy team.

Rountree 26:20
That’s perfect, Tara. And just to restate something you said, answering another question, just specifically around template comment letters in a very similar fashion. NCRC produces both comment letters that we are submitting and inviting our members to sign on to, and as a particular campaign warrants, we’ll provide template language for our members to then adapt and use to be able to submit their own original comment letter. Yeah, I just wanted to bump that up because I think that’s also very, very helpful. There will be other opportunities to answer questions. So if you have more questions, put them in the chat. I’m going to turn it over now to our membership engagement specialist to talk a little bit about member eligibility, how to manage your membership, etc. Ralph, I will turn it over to you.

Cryus 27:05
Good afternoon, everyone. I’m Ralph Cyrus, the membership engagement specialist for NCRC, along with my colleague Diana Ashong, who’s the membership engagement manager. We are sort of the first point of contact, one-stop shop for members and prospects who are interested in getting to know about our resources and wanting to know how to how to get involved. We’re more than happy to help direct your membership journey.

So, what we’re going to do first is just go through overview of the membership webpage. You can visit it yourself at ncrc.org/membership and get to get started on at least the first point of contact when it comes to knowing more about what how to who’s eligible for membership and what resources are available. So first, this is our homepage. You would click the top where it says membership. It’ll take you directly to our membership page where you can join immediately. From there, you can from the membership page you can join immediately. You’ll see a list of benefits that are available to new members, whether it’s signing up for different resources or just getting something that’s on the website. If you ever have a question, feel free to fill out that contact us form at the top of the page, and then there you’ll have a benefits list that shows some of the opportunities and resources that are available for members. We also have a map that shows where all of our members are throughout the country. We’re going to review the member map a little bit later, so we’ll get back to that. And if you’re already ready to sign up, you can choose the membership tier that best reflects your organization. If you’re a nonprofit, you would choose the option that reflects your organizational budget, and you could sign up right there. We also have tiers for local and state government agencies, as well as research and educational institutions, as well. And then at the bottom of that page, we have a bunch of frequently asked questions about membership. How do I join? How do I access my account? What are the costs? What are the other benefits? That listing right there is pretty good because you have clickable links that you can use to explore the rest of our of our website, the the rest of our website as well. Some other questions that may be asked is how do I get reminders for renewal? Just as a heads up, renewal starts from your day of signing up. So, say you signed up for membership today, you will get a your renewal date would be this time next year. Just worry. You don’t. All you have to worry about is an annual renewal renewalship. So feel free to look through our frequently asked questions for any resolutions. And one thing we do want members to do is to give us an updated list of contact information, so you can either adjust. Listed on your member hub profile, or you can fill out this demographic form that we will share. That will let you know about who in your organization we should be contacting, a bit about your work, where you’re located, and things that you feel we should know about your organization. And we will be sure to update that and make sure that other staff members are aware of that information as well. Now we’re going to take a look at our member map that I’m really excited to show. I love sharing it with people. Anytime people want to know who our members are of the 700-member network throughout the country, can all you can always check out the member map on the membership page. When you’re reviewing it, you can click on any particular state and see how many members we have and where are they. We have members throughout the country and multiple levels of density. We even have members in Puerto Rico. We were recently on a meeting with them, learning about their great work.

We’ll use Jackson, Mississippi, as an example. Basically, you can zoom in and see all of the members there. And when you click on their name, either directly on the map or through that list on the side, it’ll take you directly to their website. We’re going to use the Housing, Education, and Economic Development team as an example, led by the great Charles Harris. You can also search in that profile for city and have it search through to see what members are available there, and if you ever want to get in contact with any of your fellow members, you feel free to reach out to the membership team. We’re happy to set up that connective tissue, or you can reach out directly from their websites as well.

And lastly, we’re going to show you what the member hub profile provides for you. It’s the member hub is a one-stop shop where you can add members, add team members to your subscription. You can update the pro the newsletter profiles that are available to you. You can see what your current team subscription is. Get a an invoice downloaded to you. You can all also sub make submissions yourself. So we’ll just take a quick look through what the member hub provides. So when you sign into your account, you’ll see up top the member. You should see my account. You can go into your settings, go to subscriptions, choose your subscription. If you copy that link right there and share with other staff, they’ll be able to create accounts under their email addresses for the organization subscription. You can also add – if you are the group manager, you can add or subtract staff as there’s turnover in your organization. You can also download an invoice directly from there for any of your financial records. And now we’re going to see what the member hub looks like.

One of the first things you can do on the member hub is go to update your newsletter subscriptions. If there are, if you’re not getting enough information from NCRC, or if you’re getting too much, you can add or or you could select or unselect the subscriptions that you’re getting. Discuss the topic of interest that are interesting to you, and you’ll you’ll get our our slate of emails.

We have a variety of research projects, blog reports. Some are a series like the Mortgage Market Series that is available for members, and then we have a calendar of up upcoming events, typically a summit conference, training courses, and then what we also have is what we call the field notes. So you can provide a story of your organization, some of your great work, and the field notes submission and our communications team will work with you to make a field notes member profile out of that, and a lot of members have said how amazing it is to have their work platform there. So if you have anything interesting that you’ve been working on, you want to share with us, please feel free to submit field notes, and we would love to platform it. So that’s just a little bit of what’s available on the member hub. I encourage everyone, when you have time, to just go ahead and do a scroll through our website. When you log into the member hub, see what resources are available. If anything is confusing, feel free to reach out to membership. You can email us at membership@ncrc.org to get involved.

Now, if you’re ready to commit today, I would encourage you to visit our website or scan that QR code to go to the membership page. Feel free to also reach out to us to schedule a call. We’ll kind of walk through that list of benefits and see which ones stand out for you, or we’ll discuss tools or aspects of NCRC that you’re interested in as well. And you don’t have to. You can be a current member, you can be a former member, you can be somebody who’s just learning, hearing about NCRC, and you want to know more. We’re more than happy to talk to you about your work and how NCRC can be a part of that. And now I will I will turn back to Caitie to finish us out.

Rountree 35:45
Thanks so much, Ralph. Really, the member map where we’re able to see where y’all are working all across the country, it is so cool, and so glad to be able to use that as a way to help y’all connect to each other more easily. One, just a I’ll do a double click on something that Ralph mentioned in the member hub. You can customize newsletters you receive from us. If there is one email that you read from NCRC every week, I suggest that you make it the member update that goes out on Wednesday mornings. We use this as a digest and highlights, so it’s not very long, but it will summarize the most important things that we think that members should be aware of that week, where you can see upcoming trainings and events, registration and information about those, opportunities to participate in our policy work, comment letters, breaking news that’s important related to our advocacy work. It’s where applications for funding are highlighted. Many times, those get their own dedicated emails with more information. But that Wednesday morning member update email should give you the the Cliff Notes guide to everything that’s happening to NCRC in that particular week. So that’s one to make sure that you look at every week. And if you have multiple staff who you think may benefit from engaging with NCRC, make sure that their accounts are set up so that they’re receiving that as well.

We’ve got just a couple more minutes here for some additional questions. One thing just related to the member hub question, I think Jocelyn answered directly, but I think it’s worth saying out loud. One of my dreams as a backend person is that eventually we will have single sign-in for all the different things that we offer to our members. But at this point in time, you need a different account to be able to log into the member hub, and a different account to log into our training portal. So, if you’re trying to log in one place, information, password, etc. from another, that might be why you’re having trouble. Either the training academy or the membership team would be happy to help sort you out. Just a heads up that those are different accounts, unfortunately.

Checking to see if there are any other questions that I can answer, folks, before we wrap. But I think this has been just a really informative conversation. Thank our my fellow colleagues for their presentations and information, and thank all of you. I just want to leave you with one final thought before we close. NCRC offers research, policy expertise, training, all these different resources to strengthen your organization’s work. But the reality is that being a member of NCRC is actually about something even bigger than that. It’s an invitation to join more than 700 organizations that are working together to improve how capital flows into communities, to expand opportunity and advance wealth equity. That’s not something that NCRC is doing for our members. It’s something that we’re doing with our members, and it takes all of us working together to do that. So we’re incredibly grateful for the work that you’re doing in your communities and for the work that you’re doing with us. We really truly believe that in order to solve the enormous challenges that this country faces, we’re going to need to do it in collaboration with one another. So we hope that you’ll join us. Grateful for your participation. Yeah, and look forward to helping to build a stronger movement for community development and wealth equity with you.

 

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NCRC 2025 Impact Report https://ncrc.org/impact/?utm_source=rss&utm_medium=rss&utm_campaign=impact Fri, 26 Jun 2026 15:13:49 +0000 https://ncrc.org/?page_id=285522

SCROLL DOWN TO REVEAL

2025
NCRC IMPACT

Boosting Communities • Building Foundations • Bridging the Divide

The NCRC Mission

The National Community Reinvestment Coalition (NCRC) is a nationwide network of over 700 organizations and champions working for a Just Economy, where all Americans can build wealth and provide for their families with stability and dignity.

Our members include community developers, grassroots advocates, mission lenders and nonprofit and local government leaders representing urban, suburban and rural communities across the country. NCRC is built on a simple insight: addressing wealth inequality requires reversing decades of disinvestment in people and in places. The places where people live drive access to capital, housing, jobs and pathways to upward mobility.

We mobilize communities, policymakers and financial institutions to ensure public and private investment strengthens local economies and expands opportunity where it has long been denied.

From Our Leaders

carol

We’re pleased to share highlights from NCRC’s 2025 Impact Report. In a time of ongoing uncertainty, NCRC remains focused on what matters most; working in partnership with communities and leveraging research, advocacy, convenings and investments to advance a Just Economy as both a national priority and a lived local reality.

In solidarity,
Jesse Van Tol
President & CEO

As I step into my role as NCRC’s Board Chair, I am deeply inspired by the progress reflected in this impact report. NCRC’s commitment to building pathways to wealth creation for underserved communities is a testament to the power of collective action and moral purpose; carried forward by the legacy of Bob Dickerson, whose leadership has left a lasting mark on this organization and the communities we serve. Together, we will keep fighting for a financial system where every American has the opportunity to build wealth and live well.

Carol Johnson

In solidarity,
Carol Johnson
Board Chair, NCRC

As the Interim Executive Director of the NCRC Community Development Fund, I am honored to build upon the strong foundation that has been established here. NCRC CDF’s work providing loans for small businesses and other community development needs in low- and moderate-income communities is central to NCRC’s broader mission of making a Just Economy a national priority and a local reality. The progress reflected in this report is a testament to the dedication of this team and the communities we serve.

With appreciation,
Gregory Dyson
Chief Operating Officer, NCRC & Interim Executive Director NCRC CDF

Numbers At A Glance

Members

0

across the nation

Grants

$ 0 M

to members

Loans

$ 0 M

in lending from the CDF

Engaged 140 entrepreneurs and partnered with CDFIs, banks and other financial professionals to provide direct guidance and support.

Training

0

Over 1,000 training hours with over 8,000 attendees covering a variety of CRA, Community Development and Housing Counseling topics.

Community Benefit Agreements

$ 0 B

in commitments to low- and moderate-income communities secured through partnerships with financial institutions and communities.

Network Map

763 member organizations in 43 states and DC and Puerto Rico.

Up to 9

10-19

20-39

40-70

NCRC Network Map
Housing Counseling Network

Nearly $600,000 awarded to 24 agencies across 16 states – helping over 10,000 households

Community Benefit Agreements

Locations based on where we have active agreements.

Boosting Knowledge

for Economic Justice

Providing insights through research, publications and events to inform economic justice and community development strategies.

Boosting Visibility via Research

2,173 total academic citations through 2025

At NCRC, we aim to uplift the knowledge necessary to tackle the hardships faced by underserved communities. Since 2021, NCRC’s Historic Redlining mapping application has been downloaded 2,624 times and cited in 34 peer-reviewed studies. This data contributed to a $25 million dollar agreement to address redlining in Philadelphia.

18,757 downloads and cited in six studies

Our HMDA Mortgage Loan Database, launched in 2024, has been downloaded 18,757 times and cited in six studies. It has provided standardization tools for researchers nationwide to examine redlining’s long-term effects on health outcomes, wealth accumulation and neighborhood conditions.

Boosting Awareness through Media

450,000 Impressions across our social platforms

500+ Media Mentions

New York Times   -   Bloomberg   -  American Banker   -  Banking Dive   -   Reuters   -  New York Times   -  Bloomberg   -  American Banker   -  Banking Dive   -   Reuters   -  

34 Regulatory Comment Letters

We regularly comment on regulatory actions that impact fair lending and fair housing enforcement. From calling out bank charter applications and mergers to supporting CRA, HMDA, and consumer protections, we hold federal agencies accountable.

Field Notes

We’re always looking for new ways to celebrate the vital work of our coalition members, as their efforts are at the heart of everything we do.

In 2025, 37 member organizations from across the US have been featured through the program, bringing their stories to light in a way that reflects the true depth of our collective impact. Here are a few of our favorites!

Boosting Knowledge Through Sharing

Just Economy Conference:
Nearly 1,200 attendees, Over 46 breakout and lightning sessions

NCRC’s Just Economy Conference has become a must-attend annual event for community, business, foundation, policy and government leaders who want all Americans to build wealth and live well. With nearly 1,200 attendees from across the nation and a variety of  breakout sessions, a wealth of knowledge was shared on fair lending practices, financial technology innovation, housing equity work and much more.

Featured Speakers

Keeanga-Yamahtta Taylor

Pulitzer Prize Finalist; Hughes-Rogers Professor of African American Studies at Princeton University

Adreinne Harris

Adrienne Harris

Superintendent, New York State Department of Financial Services

Alonzo Waheed photo

Alonzo Waheed Sr.

Program Director, Equity and Transformation

Dr. Tiffany Crutcher photo

Dr. Tiffany Crutcher

Black Wall Street Descendant and Executive Director, Terence Crutcher Foundation

Marc Morial photo

Marc Morial

President, National Urban League

Brant Standridge photo

Brant Standridge

President, Consumer and Regional Banking, Huntington National Bank

Sonya Harper

Sonya Harper

State Representative, Illinois

Maxine Waters

Maxine Waters

Congresswoman U.S. House of Representatives, California

Just Economy Leadership Summit

160 community and industry leaders from across the country attended NCRC’s Nashville Summit to develop strategic solutions in response to unprecedented federal funding cuts, with a focus on housing, small business, and workforce development. For more information, read the Nashville Summit Report Series.

Building Capacity

for Economic Justice

Equipping local leaders with the tools, training and support needed to expand economic opportunities in their communities.

Building Member Power

$1.7 million in
grants to members

Building Capacity Through Training

Fellowship of Equitable Development

Of the 25 student fellows placed with NCRC members; 50% remain in the community development field, 25% in leadership positions, fostering the next generation of leadership in economic justice.

[The fellowship] has provided a rare opportunity to work at the intersection of research, community engagement and applied policy in a way that felt both rigorous and grounded in real community needs,” Issac Yeboah, a fellow at Wacif/ACC. “I am treated as a collaborator rather than just a trainee, which allowed me to contribute substantively, exercise independent judgment, and take ownership of complex components of the work; I would strongly recommend the fellowship to future participants seeking meaningful, applied learning opportunities.

Housing Counseling Network

Nearly $600,000 awarded to 24 agencies across 16 states to support critical wealth-building and housing stability services.

Field Empowerment Fund

Disbursed $1.34 million to 59 housing counseling agencies; providing essential funding and critical knowledge to ensure counselors can support local families in achieving and maintaining homeownership.

National Training Academy

Over 8,000 attendees across live, recorded and in-person training opportunities.

400 courses totaling over 600 instructional hours was provided through NTA on community development, housing counseling, place-based strategies and more.

70% of respondents reported increased confidence in their skills, 80% expressed overall satisfaction and 90% would recommend NTA training to a colleague.

Bridging Investment

for Economic Justice

Supporting accountability and engagement practices that help direct capital toward community-identified needs.

Bridging Capital Access

This year, our CDFI programming expanded in ways that reflect where the gaps in small business financing actually are. Two new funds came online, with our technical assistance offerings continuing to grow in reach and scope.

Media Resilience Fund:

  • In 2025, we provided $75,000 in funding to help sustain local news.
  • Through our Media Resilience Fund, developed alongside URL Media and Rebuild Local News and supported by the Press Forward’s national local news initiative, we’re working with local news organizations to strengthen their revenue models and operational sustainability. Strong communities need strong local reporting, and that reporting needs real institutional support to survive.

Economic Prosperity Fund:

  • In 2025, we deployed over $750,000 to Muslim entrepreneurs for Sharia-compliant lending products, as one of only three CDFIs in the country offering this kind of product.
  • With few CDFIs having made strides towards addressing this lending gap, we launched the Economic Prosperity Fund, a Sharia-compliant lending product built specifically for this community. For Muslim entrepreneurs, it opens a door that most lenders haven’t bothered to unlock.

Empowering Entrepreneurs Through Knowledge and Capital

This year, the NCRC CDF delivered more than 1,900 hours of technical assistance support across 21 workshops, 3 events and 11 group sessions, with over 1,087 total attendees across our business support programs.

Through NCRC, we gained access to small business development training and 1:1 counseling regarding grants and resources which helped us strengthen our business model. The support gave us the tools to navigate as a woman led minority owned business in Washington, DC, refine our operations and expand our reach to underserved markets.
Kenya Jenkins
Lillian’s Southern Box Catering, LLC

Bridging the Gaps

Community Benefit Agreements

Through partnerships with financial institutions and communities, supported $29.1 billion in commitments to low- and moderate-income (LMI) communities, expanding lending, investment, and philanthropic resources for underserved borrowers and neighborhoods.

Bridging Community Engagement through Banks

For community benefit agreements, we recruited 277 member organizations across 20 states to participate in 23 listening sessions with financial institutions. This demonstrates NCRC’s commitment to assisting community leaders by ensuring they have a seat at the table and a direct opportunity to influence decision makers.

Bridging Institutional Accountability

Hill Day

On Capitol Hill, NCRC’s advocacy grew louder and more effective. Last year’s Hill Day brought 125 members to Washington, reflecting a movement of community leaders unwilling to stand down.

CFPB Lawsuit

In late 2025, NCRC filed a lawsuit challenging the director of the Office of Management and Budget Russell Vought’s move to cut off funding to the Consumer Financial Protection Bureau (CFPB). The CFPB exists to protect consumers, thus gutting its budget is a way of disabling it without going through the harder work of eliminating it legislatively.

Bridging to Tomorrow:
2026 Priorities, Gratitude and Next Steps

The work ahead is clear, even when the landscape isn’t. In 2026, NCRC will keep pushing on the issues that have always defined this organization: stronger Community Benefits Agreements, deeper investment in small businesses and a regulatory environment that holds financial institutions to their promises.

We’ll expand our housing services, deepen our local coalition building, grow the Community Investment Institute and continue the legal and advocacy work that keeps consumer protections intact. We’ve set ambitious priorities because the need demands it and we’re committed to delivering on them.

None of the work that we can do can happen without your continuous support. We are grateful to the foundations, institutions and individual donors who fund this work and trust NCRC to deploy these resources where they matter most. That trust is not something we take lightly.

The most effective thing NCRC does is connect people who care about fair, equitable development with the institutions and policymakers who need to hear from them the most. If you want to be part of what comes next, consider supporting NCRC’s work or joining our Just Economy coalition.

A Just Economy doesn't Create itself.
Let's Boost, Build and Bridge this reality together.

Board of Directors

carol-johnson

Carol Johnson, Chair

City of Austin’s inaugural Civil Rights Office 

Henderson

Irvin Henderson, Vice Chair

National Trust for Historic Preservation

elisabeth-risch

Elisabeth Risch, Vice Chair

Housing Opportunities Made Equal (HOME)

Ernest E Hogan

Ernest Hogan, Treasurer

Pittsburgh Community Reinvestment Group

aaron-miripol

Aaron Miripol

Urban Land Conservancy

arden-shank

Arden Shank 

South Bend Heritage Foundation

Bethany Sanchez

Bethany Sanchez

Metropolitan Milwaukee Fair Housing Council

Cornell Crews

Community Reinvestment Alliance of South Florida

Charles Harris

Charles Harris 

Housing Education & Economic Development 

Dave Castillo board member

Dave Castillo

Native Community Capital

kevin-stein

Kevin Stein

Rise Economy

Matt Hull

Matt Hull

Texas Association of Community Development Corporations  

Matthew Lee

Matthew Lee 

Inner City Press 

Moises Loza 

Formerly, Housing Assistance Council 

peter-hainley

Peter Hainley

CASA of Oregon

bob-dickerson

Robert Dickerson, Jr.

Birmingham Business Resource Center 

Roberto Barragan Board Member

Roberto Barragan

Initiating Change in Our Neighborhoods Community Development Corporation

Sharron Lee Headshot

Sharon H. Lee 

Low Income Housing Institute

board member Steven Glaude

Stephen Glaude

Coalition for Non-Profit Housing and Economic Development (CNHED)

Vernice Miller-Travis headshot

Vernice Miller-Travis

WE ACT for Environmental Justice

Top Funders in 2025

Truist Bank

JP Morgan Chase

Bank of America

Goldman Sachs

Wells Fargo

PNC

First Citizens Bank and Trust Company

U.S. Bank

Huntington Bank

Morgan Stanley

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NCRC Comment On FDIC GENIUS Act Rulemaking https://ncrc.org/ncrc-urges-fdic-to-address-risk-of-deposit-flight-in-genius-act-rulemaking/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-urges-fdic-to-address-risk-of-deposit-flight-in-genius-act-rulemaking Tue, 09 Jun 2026 17:13:00 +0000 https://ncrc.org/?p=289023

June 9, 2026

[Via: email to Comments@fdic.gov through FDIC Website at https://www.fdic.gov/federal-register-publications)]

Travis Hill, Chairman
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington, DC 20429

Attn: Comments- RIN 3064—AG19

Re: GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions Notice of Proposed Rulemaking [RIN 3064—AG19]

Dear Chairman Hill:

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the notice of proposed rulemaking (NPRM) issued by the Federal Deposit Insurance Corporation (FDIC) regarding implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) requirements and standards for FDIC-supervised stablecoin issuers and institutions.[1]

NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality. 

NCRC urges the FDIC to: (1) address the risk of deposit flight and its impact to community investment and lending; (2) ensure regulatory definitions are consistent in the FDIC GENIUS Act final rule and with the various other GENIUS Act implementing rules and any subsequent legislation to avoid consumer protection issues; (3) seek input from other regulators and re-evaluate its technology neutral approach to deposit insurance because of the potential systemic and other risks associated with blockchain technology.

1 Yield provisions and presumption do not go far enough to prevent deposit flight.[2]

The GENIUS Act prohibits permitted payment stablecoin issuers from paying “the holder of any payment stable coin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin.”[3] The prohibition in the statute is limited to issuers, not other players in the stablecoin ecosystem, namely, cryptocurrency exchanges through which issuers currently indirectly pay yield to holders. For example, exchanges can hold stablecoin on the blockchain on behalf of a retail holder. Some issuers pass interest earned on the reserves it holds to the exchange, which the exchange then uses to pay the retail holder yield.[4] Exchanges may also pay yield to holders through other means, as well.

The FDIC GENIUS Act NPRM prohibits the “the paying of interest or yield simply for holding using or retaining a payment stablecoin, including through arrangements with affiliates or related third parties that effectively provide such yield.”[5] Activity-based rewards and yield would be allowed under this framework but it attempts to limit issuers from circumventing the prohibition through setting up arrangements with third parties and affiliates. Those efforts, unfortunately, are unlikely to be enough to prevent deposit flight — the movement of funds by households and businesses from bank deposit accounts to stablecoins.

Bank deposits fund bank lending activities and community investment and development. The incentivizing of use of stablecoins and the resulting deposit flight will seriously impair banks’ lending capabilities and ability to invest in their communities. According to the American Bankers Association, this is especially true of smaller community banks.[6] It notes that when community banks lose deposits, they must replace the funding, “often through higher-cost wholesale borrowing” and “the increased funding costs translate into less lending and higher borrowing costs for households and small businesses.”[7]

The US Treasury’s Borrowing and Advisory Committee (TBAC) estimated that as much as $6.6 trillion in deposits could move from the traditional finance sector into the stablecoin market.[8] The Independent Community Bankers Association (ICBA) predicts that the stablecoin market will “grow to $5 trillion, draining $1.3 trillion in deposits from community banks” resulting in a drop of $850 billion in community bank lending.[9] It estimates that community banks make approximately 60% of all small business loans and 80% of agricultural loans nationally.[10] 

Banks operate within a broader public policy framework designed to ensure that federally supported financial institutions help meet household, small business, and community credit needs. Stablecoin issuers may increasingly compete with banks for customer funds while operating under a vastly different regulatory framework. The FDIC should consider whether large-scale migration of funds into stablecoin ecosystems could weaken the flow of capital into communities that depend on traditional lending institutions. For example, deposits held in insured depository institutions help support mortgage lending, small business lending, agricultural lending, branch networks, low-cost transaction accounts, and community development finance. When funds migrate into stablecoin ecosystems that do not carry comparable community reinvestment obligations, underserved communities may lose access to the credit and banking infrastructure that federal banking policy is supposed to preserve. NCRC has long advocated for requiring stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities.[11] It would allow for a more level playing field between banks and stablecoin issuers.

The GENIUS Act’s narrow prohibition of the payment of stablecoin yield raises significant deposit flight concerns that the FDIC GENIUS Act NPRM’s expansion to include affiliates and related third parties does not address.

2. Definitions need to be consistent between and among the rulemakings and legislation to avoid incongruous treatment and consumer protection issues.[12]

Because the current legislative and regulatory framework for the stablecoin and cryptocurrency market is in flux and evolving, it creates the potential for differing definitions and consumer protection implications. The GENIUS Act requires regulators including the Treasury Department, the Office of the Comptroller of the Currency (OCC), Federal Reserve, and the National Credit Union Administration (NCUA), as well as the FDIC, to issue implementing regulations.[13] Several proposed rulemakings are in process, including this one, while others have closed. For example, the comment period for the OCC’s proposed implementing regulation closed in May. In addition to these regulatory efforts, Congress is currently considering a digital asset market structure bill, the Clarity Act, which could expand on the GENIUS Act framework.  

Given the complexity of the anticipated regulatory structure for the digital asset market and the interconnectedness of the US banking system, it is crucially important that definitions between and among the rulemakings and legislation be consistent. A lack of consistency in these definitions can result in inconsistent treatment of consumers because rights and responsibilities are tied to these definitions. For example, the OCC GENIUS Act NPRM defines the term “customer” as “a person that purchased (through any consideration) the products or services of person.[14] The FDIC GENIUS Act NPRM defines customer more narrowly in the context of issuance as “a person that purchases (through any consideration) the products or services of a PPPSI [permitted payment stablecoin issuer] directly from the PPSI.”[15] This definition excludes secondary market holders, end-users obtaining stablecoins via intermediaries, and wallet users with no direct interaction with issuers.

But, elsewhere in the proposed rule, the FDIC defines customer more inclusively in connection with the role of custodians to be “a person for whom or on whose behalf a custodian receives, acquires, or holds payment stablecoin reserves, payment stablecoins used as collateral, private keys, cash, and other property received in the course of the provision of custody services for such assets.”[16]

Rights and responsibilities flow from the FDIC’s definitions of customer and implicate things like redemption rights and disclosures. The contextual definitions of customer in the FDIC proposed rule may result in inconsistent treatment of like actors. A holder of a stablecoin that purchased it directly from an issuer would be a customer under both FDIC customer definitions; but if the holder purchased it from an exchange, it would only be a customer in connection with custody services. Inconsistent definitions means that two people holding the same stablecoin would have different rights depending on whether they bought directly from the issuer, through an exchange, or through a wallet. This is not merely a drafting problem – it has serious implications for the protections afforded stablecoin users and holders – and thus is a consumer-protection problem.

Creating uniformity within the FDIC’s proposed rule is only half the battle –different definitions for the same terms in other GENIUS Act implementing rules have the potential to create coordination challenges and divergent outcomes, including the incongruous results caused by which regulators’ rules apply. 

3. Technology neutral approach to deposit insurance raises serious risks to financial system and consumers.[17]

In response to a series of banking failures, Congress, as part of the Banking Act of 1933, created the FDIC.[18] Part of the FDIC’s mission is to maintain stability and public confidence in the banking system by insuring deposits. Deposit insurance was created by the Banking Act of 1933 as a means of preventing bank runs – whereby depositors seek to withdraw funds en masse, and cause banks to fail because they lack the liquidity to pay out all depositors.[19]

The FDIC GENIUS Act NPRM proposes to “clarify” that the FDI Act’s definition of a deposit is “technology neutral,” meaning tokenized deposits are treated the same as other forms of deposits including in connection with deposit insurance coverage.[20] Currently, the FDIC insures deposits up to $250,000 per depositor per ownership category.[21] The proposed change would impact all FDIC insured accounts held at institutions including those supervised by other Prudential regulators, such as the OCC. However, the proposal is silent about any coordination with other regulators.

This so-called clarification introduces a level of uncertainty to something that has been in existence – and worked well – for over 90 years. The 24/7 nature of blockchain technologies and speed of blockchain transactions has the potential to increase the risk of bank runs – tokenized deposits can move more quickly, and banks may not be able or have the liquidity to respond. Increased bank runs could place stress on the deposit insurance system. It is also possible that tokenized deposits will move outside of the banking network into other cryptocurrency exchanges or platforms. It is unclear what the implications are for banks and the deposit insurance system when tokenized deposits travel in that more fluid, less regulated environment. Potentially, shocks to exchanges or platforms in the digital marketplace could cause systemic risks to the banking system. Also, although tokenized deposits may act similarly to stablecoins, they likely would have more favorable treatment because as deposits, they would be eligible for deposit insurance. Where the same or similar activities or products receive different regulatory treatment, regulatory arbitrage and consumer confusion thrives.

FDIC should not assume that the same legal label means the same practical risk. In light of recent market developments, such as the proposal by some of the largest US banks to create their own tokenized deposit network, it would be prudent to gather more information before finalizing this part of the proposed rule.[22] NCRC encourages the FDIC to refrain from finalizing its proposal regarding the treatment of tokenized deposits and re-evaluate it after receiving input from other Prudential regulators regarding the potential risks to the deposit insurance and banking systems.

Conclusion

NCRC urges the FDIC to:

  1. address the risk of deposit flight and its impact on community investment and lending;
  2. ensure regulatory definitions are consistent in the FDIC GENIUS Act final rule and with the various other GENIUS Act implementing rules and any subsequent legislation to avoid consumer protection issues;
  3. re-evaluate its technology neutral approach to deposit insurance after receiving input from other regulators, because of the potential systemic and other risks associated with blockchain technology.

Thank you for the opportunity to offer our input on the FDIC GENIUS Act NPRM. If you have any questions, please contact me at jvantol@ncrc.org, or Tara Flynn at tflynn@ncrc.org.

Thank you for your consideration.

Sincerely, 
Jesse Van Tol,
President and CEO, NCRC  

 

 

[1] FDIC, Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions,” Notice of Proposed Rulemaking, 91 Fed. Reg. 18,534 (Apr. 10, 2026) [hereinafter FDIC GENIUS Act NPRM].

[2] See Questions 21-24, FDIC GENIUS Act NPRM at 18540.

[3] GENIUS Act § 4(a)(11); FDIC GENIUS Act NPRM at § 350.3(b)(4).

[4] Cong. Rsch. Serv., The Stablecoin Yield Debate (Mar. 2026), https://www.congress.gov/crs-product/IF13174.

[5] Staff Memo to FDIC Bd. of Dirs., Re: Notice of Proposed Rulemaking on GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions 2 (Apr. 7, 2026) [hereinafter Staff Memo].

[6] Sayee Srinivasan and Yikai Wang, The CEA Studied the Wrong Question on Stablecoin ‘Yield’ and Community Banks, ABA Banking J. (Apr. 13, 2026), https://bankingjournal.aba.com.

[7] Id.

[8] U.S. Dep’t of the Treasury, Treasury Borrowing Advisory Committee (Apr. 30, 2025), https://home.treasury.gov/system/files/221/TBACCharge2Q22025.pdf.

[9] Indep. Cmty. Bankers of Am., Stablecoins, Master Accounts, and National Trust Charters: Community Bankers Urge a Pause on Policies for Unaccountable Entities 4 (May 6, 2026), www.icba.org.

[10] Indep. Cmty. Bankers of Am., About Community Banking, www.icba.org.

[11] See Bakari Levy and Kevin Hill, The Need for Community Development Accountability for Stablecoin Issuers, NCRC (Jul. 14, 2025), https://ncrc.org.

[12] See Questions 1 and 3, FDIC GENIUS Act NPRM, at 18537.

[13] 12 USC § 5901 et. seq.

[14] 91 Fed. Reg. 10,202, 10,205 (emphasis added).

[15] FDIC GENIUS Act NPRM at 18535 (emphasis added) (limiting the application of the definition to part 350, subpart A.)

[16] FDIC GENIUS Act NPRM at 18556 (emphasis added) (limiting the application of the definition to part 350, subpart B).

[17] See Questions 131-139, FDIC GENIUS Act NPRM at 18561.

[18] GovFacts, Is Your Monday Safe: How Banking Deregulation Affects You (Dec. 5, 2025), https://govfacts.org.  

[19] Id.

[20] Staff Memo at 6.

[21] FDIC GENIUS Act NPRM at 1855.

[22] Gina Heeb and Vicky Ge Huang, JPMorgan, Citi and Big Banks Plan New Tokenized Deposit System to Answer Crypto, MSN (June 4, 2026), www.msn.com.

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When the Feds Step Back on Fair Housing, Can States Step Up? https://ncrc.org/when-the-feds-step-back-on-fair-housing-can-states-step-up/?utm_source=rss&utm_medium=rss&utm_campaign=when-the-feds-step-back-on-fair-housing-can-states-step-up Tue, 02 Jun 2026 16:04:11 +0000 https://ncrc.org/?p=288860 May 5, 2026, ShelterForce, When The Feds Step Back On Fair Housing, Can States Step Up?

At the beginning of the Trump administration’s second term, the regulators in charge of implementing the CRA—the Federal Deposit Insurance Corporation, Federal Reserve Board, and the Office of the Comptroller of the Currency—came under new leadership and in July 2025 they issued a proposal to rescind the 2023 revisions. The agencies were still reviewing comments on that proposal when this article went to press. 

States, however, can pass their own CRA laws: seven states and Washington, D.C., already have, and others are considering doing so. “As we see the federal government repeal previous rules or extend times between examinations, states can push back on that,” says Kevin Hill, senior policy advisor at the National Community Reinvestment Coalition (NCRC). One plus of state CRA laws, Hill adds, is that in addition to state-chartered banks, they can—and often do—cover credit unions and mortgage companies, which the federal CRA statute doesn’t. 

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NCRC Urges Senate Banking Committee to Vote No on Digital Asset Market Structure Bill https://ncrc.org/ncrc-urges-senate-banking-committee-to-vote-no-on-digital-asset-market-structure-bill/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-urges-senate-banking-committee-to-vote-no-on-digital-asset-market-structure-bill Tue, 26 May 2026 20:35:06 +0000 https://ncrc.org/?p=287902

May 8, 2026

Senator Elizabeth Warren, Ranking Member
Committee on Senate Banking, Housing, and Urban Affairs
United States Senate
Washington, DC 20510

Dear Senator Warren and Minority Members of the Senate Banking Committee:

NCRC writes to urge you to vote no on any digital asset market structure bill at markup unless the committee-reported legislation includes strong, enforceable ethics and conflicts-of-interest provisions, meaningful protections against deposit flight, and clear safeguards against illicit finance, fraud, and consumer harm.

NCRC especially opposes any market structure legislation that does not address the serious risks created by the digital asset market to low- and moderate-income (LMI) households and communities and the stability of our financial system, including the risks of:

  • deposit flight from traditional banks to stablecoin companies;
  • a resulting decline in lending and community development financing;
  • conflicts of interest; and
  • systemic fraudulent activity.

NCRC is a coalition of 700+ grassroots organizations that create opportunities to build wealth in underserved communities through affordable housing development, small business support, and workforce training. We work with banking institutions to fulfill their obligations to the Community Reinvestment Act (CRA), which requires reinvestment of deposits in LMI communities through lending, bank branch openings, and financing of needed community development projects.

As you prepare for the likely markup, we ask that you keep in mind the following:

1.  Markup draft must include effective conflicts of interest and ethics provisions that are available to the public for review and comment in advance of the markup.

The Committee should reject any argument that ethics provisions should be deferred and not included in the markup draft because they are outside the Committee’s jurisdiction. The legislation under consideration would define the legal structure of digital asset markets, assign regulatory authority, create exemptions and obligations, and determine who may participate in these markets under federal law. Effective controls, including those governing conflicts of interest and ethics, are essential for the development of the overall market structure.

At a minimum, effective provisions would prohibit covered officials (including the president, vice president, members of Congress, senior administration officials, federal employees, and their immediate family members) from engaging in specified activities regarding digital assets, stablecoins coins, tokens, trading platforms, decentralized finance (DeFi) protocols, or other cryptocurrency related ventures. The prohibited activities should include issuing, sponsoring, endorsing, promoting, materially supporting, or benefiting in any way from those products or platforms. The provisions should include effective enforcement mechanisms and require immediate divestment of covered officials engaged in prohibited activities.

2.  Current yield compromise language will not prevent deposit flight.

As you know, in January, the Committee postponed the mark-up of the crypto market structure bill to allow for the development of a compromise regarding the bill’s treatment of yield payments. The GENIUS Act prohibits permitted payment stable coin issuers from paying “the holder of any payment stable coin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin.”[1] The prohibition in the GENIUS Act is limited to issuers, not other players in the stablecoin ecosystem, namely, cryptocurrency exchanges and wallets that pay yield or rewards to holders.

News reports indicate that there is a proposed compromise regarding the treatment of yield, but it remains inadequate to address the risk of deposit flight (see below) because its exceptions swallow the rule. The proposal prohibits rewards offered “in a manner that is economically or functionally equivalent to payment of interest or yield on an interest-bearing bank account.”[2] This creates a loophole that would allow third parties (like exchanges and wallets) to pay interest or yield to stablecoin users for participation in the third parties’ membership programs – “so long as the payments are not calculated or distributed like banks’ payment or distribution of interest or yield.”[3] But, it also apparently according to reports, allows “rewards” to be calculated by reference to duration, balance, and tenure[4] – which is exactly how yield and interest payments on bank account deposits are calculated. These exceptions undercut the so-called yield prohibition compromise, rendering it ineffective.

3.  Resulting deposit flight will mean less community development and an unequal playing field for banks that will hurt LMI communities.

If enacted, the yield compromise will encourage deposit flight, namely the movement of funds by households and businesses from bank deposit accounts to stablecoins. Bank deposits fund bank lending activities and community investment and development. Incentivizing the use and holding of stablecoins will result in deposit flight and seriously impair banks’ lending capabilities and ability to invest in their communities. According to the American Bankers Association, this is especially true of smaller community banks.[5] It notes that when community banks lose deposits, they must replace the funding, “often through higher-cost wholesale borrowing” and “the increased funding costs translate into less lending and higher borrowing costs for households and small businesses.”[6]

The US Treasury’s Borrowing and Advisory Committee (TBAC) estimated that as much as $6.6 trillion in deposits could move from the traditional finance sector into the stablecoin market.[7] The Independent Community Bankers Association (ICBA) predicts that the stablecoin market will “grow to $5 trillion, draining $1.3 trillion in deposits from community banks” resulting in drop of $850 billion in community bank lending.[8] It estimates that community banks make approximately 60% of all small business loans and 80% of agricultural loans nationally.[9]

Banks operate within a broader public policy framework designed to ensure that federally supported financial institutions help meet household, small business, and community credit needs. Stablecoin issuers may increasingly compete with banks for customer funds while operating under a very different regulatory framework.

NCRC has long advocated for requiring stablecoin companies to reinvest a portion of their proceeds into community development projects in underserved communities,[10] and encourages the Committee to include such a requirement in the market structure bill. It will create a more level playing field between banks and cryptocurrency companies and help ensure that communities continue to have the resources necessary for their continued growth and needs.

4.  DeFi provisions create a loophole for illicit finance and systemic risks.

NCRC is concerned with how the January draft of the market structure bill requires a voluntary review of DeFi trading protocols. If that provision remains, it will create anti-money laundering and consumer protection potential blind spots. Many DeFi ecosystems still have companies and people who design, market, and profit from the product—through front-end websites and apps, governance control, token issuances, developer teams, or affiliated market-makers. If the bill does not clearly assign responsibility to these participants, it risks building a pathway for bad actors to move money, evade sanctions, and launder money while leaving regulators and law enforcement in the dark. A market structure framework should not reward opacity and regulatory gamesmanship that let sophisticated firms operate without the basic obligations that apply everywhere else in finance.

These gaps will also hit LMI communities first and hardest. When platforms are not required to implement meaningful safeguards, communities see more fraud, hacking losses, and scam-driven “investment” pitches. These predatory schemes are often amplified through social media and targeted at households with less room to absorb losses. NCRC supports innovation, but innovation must come with clear accountability and transparency that includes anti–money laundering controls and consumer protections where DeFi meets the real economy. These protections should include preserving the ability of state securities regulators and state consumer protection agencies, as well as the Consumer Financial Protection Bureau, to act to prevent and redress consumer and investor harms. If Congress creates a new crypto rulebook, it must not contain loopholes that weaken financial integrity or shift the costs of misconduct onto consumers and communities.

Thank you for considering our views on this important matter. If you have any questions, please contact NCRC’s Policy Director Tara Flynn at tflynn@ncrc.org.

Sincerely,

National Community Reinvestment Coalition

 

[1] GENIUS Act § 4(a)(11).
[2] Report: Senators Reach Deal on Stablecoin Yield, ABA BANKING J. (May 4, 2026), https://bankingjournal.aba.com/2026/05/report-senators-reach-deal-on-stablecoin-yield/ (quoting Punchbowl News).
[3] Banking Trades Statement on Crypto Market Structure Yield Language, AM. BANKERS ASS’N (May 4, 2026), https://www.aba.com/about-us/press-room/press-releases/banking-trades-statement-on-crypto-market-structure-yield-language.
[4] Report: Senators Reach Deal on Stablecoin Yield, ABA Banking J. (May 4, 2026), https://bankingjournal.aba.com/2026/05/report-senators-reach-deal-on-stablecoin-yield/.
[5] Sayee Srinivasan and Yikai Wang, The CEA Studied the Wrong Question on Stablecoin ‘Yield’ and Community Banks, ABA BANKING J. (Apr. 13, 2026), https://bankingjournal.aba.com.
[6] Id.
[7] U.S. DEP’T OF THE TREASURY, TREASURY BORROWING ADVISORY COMMITTEE PRESENTATION (Apr. 30, 2025), https://home.treasury.gov/system/files/221/TBACCharge2Q22025.pdf.
[8] Indep. Cmty. Bankers of Am., Stablecoins, Master Accounts, and National Trust Charters: Community Bankers Urge a Pause on Policies for Unaccountable Entities 4 (May 6, 2026), www.icba.org.
[9] Indep. Cmty. Bankers of Am., About Community Banking, www.icba.org.
[10] See Bakari Levy and Kevin Hill, The Need for Community Development Accountability for Stablecoin Issuers, NCRC (Jul. 14, 2025), https://ncrc.org.

 

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NCRC and First Financial Bank Announce $170 Million in Community Development Goals for Chicago and Northeast Ohio https://ncrc.org/ncrc-and-first-financial-bank-announce-170-million-in-community-development-goals-for-chicago-and-northeast-ohio/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-and-first-financial-bank-announce-170-million-in-community-development-goals-for-chicago-and-northeast-ohio Tue, 05 May 2026 16:09:46 +0000 https://ncrc.org/?p=286649 The National Community Reinvestment Coalition (NCRC) and First Financial Bank (Nasdaq: FFBC), which is expanding its presence in Chicago and Northeast Ohio with the opening of its first retail locations in both areas, have collaborated to develop commitments totaling $170 million for low- and moderate-income (LMI) clients and census tracts in these areas. These goals build upon First Financial’s existing five-year $2.4 billion Community Benefits Agreement (CBA) for its total service area, which continues through 2028.

“First Financial has once again demonstrated what it looks like to be a true community partner,” said Jesse Van Tol, president and CEO of NCRC. “These addendums reflect a serious commitment to ensuring that as First Financial grows in Ohio and into the Chicagoland area, the communities in those new markets — particularly those that have been historically underserved — will benefit from that growth in concrete, meaningful ways.”

“At First Financial we truly believe that we are improving lives through our commitment to helping our clients and communities thrive,” said Archie Brown, president and CEO of First Financial. “We are enthusiastic in extending the reach and positive impact of our CBA so that we can become a trusted financial partner for the new neighbors and communities we now serve.”

A detailed summary of the plan can be found below. Highlights of the plan for Chicago include:

  • $10 million in mortgage lending through the use of products providing greater access to LMI communities and borrowers, providing access to community development mortgage loan officers and making available small-dollar mortgages and home improvement loans,
  • $9 million in small business lending in LMI communities through support of small business development corporations and business incubators and through the issuance of microloans,
  • $45 million in community development lending and investments in affordable housing, community services, revitalization and stabilization, and projects that create permanent jobs, which benefit LMI areas,
  • $1 million in philanthropy, targeting donations to organizations that create and preserve affordable housing and workforce development, plus those that provide housing counseling and promote financial and economic inclusion,
  • $75,000 in marketing and communications to benefit clients and communities in LMI and majority-minority census tracts.

Highlights for Northeast Ohio under the amended CBA include:

  • $9 million in mortgage lending through the use of products providing greater access to LMI communities and borrowers, an intentional effort in rural communities, providing access to community development mortgage loan officers and making available small-dollar mortgages and home improvement loans,
  • $50 million in small business lending in LMI communities through support of small business development corporations and business incubators and through the issuance of microloans,
  • $45 million in community development lending and investments in affordable housing, community services, revitalization and stabilization, and projects that create permanent jobs, which benefit LMI areas,
  • $750,000 in philanthropy, targeting donations to organizations that create and preserve affordable housing and workforce development, plus those that provide housing counseling and promote financial and economic inclusion,
  • $60,000 in marketing and communications to benefit clients and communities in LMI and majority-minority census tracts.
  • First Financial has also committed to open a new branch located in an LMI area to better serve the community.

“We are bringing the same community-first approach to Chicago and Northeast Ohio that has been the hallmark of First Financial Bank for years,” said Roddell McCullough, chief corporate responsibility officer for First Financial. “This is an ambitious plan, and we’re excited to be collaborating with our community partners to bring these ideas to life.” 

Since 2016, NCRC has facilitated more than 30 community benefits plans with bank groups that committed more than $600 billion for mortgage, small business and community development lending, investments and philanthropy in LMI and under-resourced communities.

The following NCRC member organizations signed on to the plan:

Benjamin Rose
Chicago Community Loan Fund
Community Shelter Board
Freedom Equity Inc.
Homes on the Hill CDC
Housing Action Illinois
Housing Opportunities Made Equal (HOME)
Indianapolis Neighborhood Housing Partnership
Legal Aid of Southeast and Central Ohio
Miles Heights Development Corporation
Ohio CDC Association
Our Home Family Resource Center
The Cedric Group/Norwood Together
The Housing Partnership, Inc.
Woodstock Insitute

“As a First Financial Bank Advisory Board member, I have witnessed the bank’s commitment and transparency in meeting its CBA goals to better the communities it serves,” said Kevin Draiss, director of Our Home, Inc.

“This agreement reflects what community-informed investment should look like—targeted, accountable and built for impact,” said Meredith Whitehead, CEO and executive director of The Cedric Group/Norwood Together.

“We are pleased to see First Financial collaborate with NCRC to develop a comprehensive plan for community development,” said Stephan Torsell, executive director of Homes on the Hill CDC. “The process of developing the agreement provided an additional opportunity for additional considerations from First Financial through their conversations and negotiations with NCRC and member organizations. We look forward to working with First Financial to improve our communities.”

Summary of the Community Benefits Plan Addenda Between The National Community Reinvestment Coalition and First Financial Bank

Through two acquisition-linked addendums extending its Community Benefits Plan to 2028, First Financial Bank has committed $169,885,000 to underserved borrowers and communities — $104,810,000 reflecting its new Ohio footprint (Westfield acquisition) and $65,075,000 reflecting its new Chicagoland presence (BankFinancial acquisition). 

Westfield Addendum — $104,810,000

The Westfield addendum reflects First Financial Bank’s new footprint in Ohio following the Westfield acquisition, adding to the final three years of the existing CBP term through 2028.

Mortgage Lending to LMI Communities and Borrowers

Commitment: $9,000,000

FFB commits to retaining at least one Community Development Mortgage Loan Originator (CD MLO) in the Westfield footprint.

Small Business Lending

Commitment: $50,000,000

This commitment represents a 29% increase over Westfield historic production. 

Community Development Lending and Investment (CDLI)

Commitment: $45,000,000

FFB commits to at least one Low Income Housing Tax Credit (LIHTC) deal between $4–8 million.

CRA Focused Philanthropy

Commitment: $750,000

FFB will continue the commitment of Westfield Bank to support the Summit/Medina County United Way with the establishment of a First Financial Bank Family Support Center and ongoing support of their Financial Empowerment Center.

Marketing

Commitment: $60,000

Other Market Commitments

  • FFB will open a new branch in an LMI census tract within Westfield’s legacy footprint to better serve the community. FFB will solicit community input as part of the site selection process for the new LMI branch.
  • FFB will implement First Financial Bank’s formal volunteer and employee giving programs with the Westfield associates to positively impact LMI individuals and communities.

BankFinancial Addendum — $65,075,000

The BankFinancial addendum reflects First Financial Bank’s new footprint in the Chicagoland area following the BankFinancial acquisition, adding to the final three years of the existing CBP term through 2028.

Mortgage Lending to the Underserved

Commitment: $10,000,000

This merger will increase mortgage lending access in the Chicagoland area after BankFinancial exited retail mortgage lending in 2017. This proposal is based on loan production beginning in 2027, with two Community Development MLOs each producing $2 million in loan production, improving to $3 million each in 2028.

FFB has hired a recruiting firm to identify and attract candidates for the two open Community Development MLO roles and commits to maintaining two CD MLOs in the BankFinancial footprint throughout the agreement.

Small Business Lending

Commitment: $9,000,000

This commitment represents a 38% increase over the BankFinancial historic production.

Community Development Lending and Investment (CDLI)

Commitment: $45,000,000

This commitment is based on BankFinancial asset size in comparison to FFB.

CRA Focused Philanthropy

Commitment: $1,000,000

Marketing

Commitment: $75,000

Other Market Commitments

  • FFB will implement First Financial Bank’s formal volunteer and employee giving programs with the BankFinancial associates to positively impact LMI individuals and communities.
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NCRC Comment to OCC re GENIUS Act NPRM https://ncrc.org/ncrc-comment-to-occ-re-genius-act-nprm/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-comment-to-occ-re-genius-act-nprm Fri, 01 May 2026 21:02:38 +0000 https://ncrc.org/?p=286467

May 1, 2026

Jonathan V. Gould
Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th Street SW
Washington, DC 20219

Via: Federal eRulemaking Portal — Regulations.gov

Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency [Docket ID OCC-2025-0372]

Dear Comptroller Gould:

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the notice of proposed rulemaking (NPRM) issued by the Office of the Comptroller of Currency (OCC) regarding implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).[1]

NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality. 

As a threshold matter, given the current uncertainties regarding the cryptocurrency and stablecoin market structure, NCRC believes it is premature to finalize this rule. Many issues remain in flux and unresolved and the OCC should not finalize the rule until subsequent legislation addresses those issues. Despite this uncertainty, NCRC requests that the OCC address the following pressing concerns raised by the OCC GENIUS Act NPRM:

  • The potential for increased deposit flight risks related to the yield provisions and the reserve requirements;
  • The potential for bank runs and systemic risk to the banking system;
  • A lack of clarity regarding redemption and disclosure regimes given the role of exchanges and third party intermediaries; and
  • The need for a charge-back type system that imposes obligations on issuers to investigate assertions by stablecoin customers of fraud and fraudulent inducement and make them whole.
  1. The evolving legislative and regulatory environment is too uncertain to finalize this rule; the OCC should allow more time for commenting.

The regulatory and legislative framework for stablecoins and digital assets remains in flux. As the OCC notes, its GENIUS Act NPRM is just “one piece of the GENIUS Act’s implementing regulations.”[2] Several other agencies have issued or are issuing NPRMs to implement other portions of the GENIUS Act, including the Department of Treasury (Treasury) and the Federal Deposit Insurance Corporation.[3] Notably, the NPRM issued by Treasury proposes that when evaluating the regulatory framework of a state to determine whether it is substantially similar to the Federal regulatory framework, the “OCC’s interpretations and regulations  . . . should be the baseline for comparison[.]”[4] In addition, while this rulemaking is pending, Congress is determining how to further legislate the digital asset market – the House has passed the Clarity Act (HR 3633) bill, the Senate Agricultural Committee has voted out of Committee the Digital Commodity Intermediaries Act (S. 3755) bill, and the Senate Banking Committee is considering the Responsible Financial Innovation Act bill. Some areas covered by these bills overlap with this NPRM. Considering the fluid nature of the regulatory and legislative environment, the OCC should extend the comment period for the GENIUS Act NPRM to allow commenters the opportunity to comment on and the OCC to regulate a more static situation armed with more concrete information.

  1. Yield provisions and presumption do not go far enough to prevent deposit flight.[5]

Payment of yield on stablecoin balances is a prime example of an unresolved issue. The GENIUS Act prohibits permitted payment stable coin issuers[6] from paying “the holder of any payment stable coin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin.”[7] The prohibition in the statute is limited to issuers, not other players in the stablecoin ecosystem, namely, cryptocurrency exchanges through which issuers currently indirectly pay yield to holders. For example, exchanges can hold stablecoin on the blockchain on behalf of a retail holder. Some issuers pass interest earned on the reserves it holds to the exchange, which the exchange then uses to pay the retail holder yield.[8] Exchanges may also pay yield to holders through other means, as well.

The OCC GENIUS Act NPRM does not sufficiently address the issue of indirect payment of yield. It proposes to establish a rebuttable presumption that payment of interest or yield occurs if the issuer has an arrangement to pay interest or yield to a holder “solely in connection with the holding, use, or retention” of its stablecoin. The presumption covers affiliates and related third parties of the issuer but defines those terms narrowly.[9] A related third party, for example, includes any person paying interest or yield as a service to the issuer.[10] For the presumption to apply, there must be (1) an agreement between issuer and the related third party or affiliate for the issuer to pay the third party/affiliate yield or interest and (2) an agreement between the third party/affiliate to pay holders of the issuer’s stablecoin interest or yield.[11] While the definitions are broader than those in the GENIUS Act, they do not go far enough to prevent the payment of yield to stablecoin holders. Yield that indirectly flows to holders through exchanges and third party intermediaries is not addressed and thus creates a loophole that issuers can exploit.[12] If issuers provide interest or other payments to an exchange but do not otherwise formally contract with the exchange to provide the yield to its stablecoin holders, the issuer will avoid coverage of the prohibition.

The OCC NPRM should define “holder” – it currently does not,[13] nor does the GENIUS Act – to include individuals and entities that possess stablecoins, including exchanges and other similar companies.[14] Doing so would clarify that issuers should not pay yield to any type of holder of its stablecoins, including exchanges. If exchanges do not receive yield or payments from issuers, then exchanges would have less ability to pass it along to holders. Taking this step would reduce the potential for deposit flight.

Congress is currently debating this issue of yield payments to stablecoin holders because allowing such yield payments –from issuers or third parties– will likely result in “deposit flight,” namely the movement of funds by households and business from bank deposit accounts to stablecoins. Bank deposits fund bank lending activities and community investment and development. The incentivizing of stablecoins and the resulting deposit flight thus will seriously impair banks’ lending capabilities and ability to invest in their communities. According to the American Bankers Association, this is especially true of smaller community banks.[15] It notes that when community banks lose deposits, they must replace the funding, “often through higher-cost wholesale borrowing” and “the increased funding costs translate into less lending and higher borrowing costs for households and small businesses.”[16]

Banks operate within a broader public policy framework designed to ensure that federally supported financial institutions help meet household, small business, and community credit needs. Stablecoin issuers may increasingly compete with banks for customer funds while operating under a very different regulatory framework. OCC should consider whether large-scale migration of funds into stablecoin ecosystems could weaken the flow of capital into communities that depend on traditional lending institutions.

A recent report indicated that stablecoins could divert around $500 billion of potential deposits from US banks by the end of 2028.[17] As a result, communities will lose billions of dollars of needed community and economic development projects and initiatives. In 2023 alone, banks originated over $126 billion in loans that meet the Community Reinvestment Act[18] (CRA) definition of community development for low- to moderate income communities and households.[19]

NCRC has long advocated for requiring stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities.[20] It would allow for a more level playing field between banks and stablecoin issuers (including national trust bank holders). Regulators regularly supervise traditional banks for their compliance with the CRA. If subject to similar requirements, regulators could also hold stablecoin firms accountable for meeting their community investment obligations. Given that no market structure legislation is final, there is still time for Congress to impose such a requirement. For example, stablecoin issuers could direct a portion of the interest they accrue on reserve deposits to community reinvestment, rather than flowing the interest back to issuers or to exchanges or other stablecoin holders.

The GENIUS Act’s narrow prohibition on the payment of stablecoin yield raises significant deposit flight concerns that the OCC GENIUS Act NPRM’s clarifications about affiliates and related third parties do not address. The rebuttable presumption does not go far enough to address indirect payment of yield by stablecoin issuers through exchanges. Including exchanges and similar third parties in the definition of holder would be an important step in the right direction. However, the OCC should not finalize its regulatory regime until Congress resolves the yield issue in market structure legislation.

  1. Reserve Requirements Raise Deposit Flight and other Risks.[21]

The GENIUS Act requires issuers to keep assets in reserves that are roughly equal to the outstanding value of its stablecoin in circulation.[22] The premise is that these assets must be easily liquidated to meet holder redemption requests. The OCC GENIUS Act NPRM sets out what types of assets are eligible to be reserves, as well as diversification and deposit concentration requirements.[23] The OCC GENIUS Act NPRM allows a variety of types of assets to act as reserves, including cash deposits,[24] Treasury bills (with a maturity date of less than 93 days)[25] and tokenized assets.[26]

The NPRM sets out two options regarding the diversification of requirements – the first allows flexibility using what it calls a principles-based approach[27] with a safe harbor (Option A) and the second sets forth mandatory requirements (Option B).[28] The mandatory and safe harbor requirements are identical. For example, under both the safe harbor and the mandatory requirements at least 10% of the reserves must be held as deposits at an insured depository institution, credit union or Federal Reserve Bank, with no more than half of those assets at a single institution.[29] NCRC prefers mandatory requirements to less measurable standards but cautions that inclusion and overconcentration of these asset types may further contribute to deposit flight.

With respect to cash deposits, we are concerned that the reserve requirements will encourage the channeling of deposits away from community and smaller banks to larger “too big to fail” banks or custodial banks as reserves.[30] And that this will create another path for the deposit flight from community and smaller banks and their losing deposits that fund their community investments and lending.

If reserve accounts include an over-concentration of Treasury bills, large sums of money will move outside the banking system entirely, not just deposits.[31] But those sums will be federally guaranteed by the full faith and credit of the US government for the value at maturity.[32] In contrast, FDIC-insured deposits are insured up to $250,000. This difference may create the impression that stablecoins are safer than deposit accounts and further encourage deposit flight.

The inclusion of tokenized assets, although generally authorized by GENIUS Act,[33] as an eligible asset type also raises concerns. If the goal of having stable reserves is to ensure the easy redemption of stablecoins, it is not clear how having tokenized assets in reserves will advance that goal. Blockchain technologies are often subject to exploitation and there is no guarantee of protection of tokenized reserve assets from such exploitation. Their value is often volatile and if there is underlying market stress in the digital market, it may impact the value and liquidity of the tokenized assets. Allowing tokenized assets adds uncertainty and instability to the reserves.

The role of custodians of reserves is also concerning. First, the NPRM allows issuers to hold their own reserve assets.[34] NPRM Question 47 asks whether the OCC should expressly require that a certain percentage of reserve assets be held in the custody of an affiliate or a third party.[35] NCRC strongly believes that the majority of an issuer’s reserve assets should be held by unaffiliated third parties, as opposed to the issuer or its affiliates, including when the issuer holds a national trust bank charter. If the issuer is experiencing financial stress, it is likely to spread to its entire business, including its affiliates. Even if the reserves are appropriately segregated, issuers and affiliates may have operational limitations caused by their financial stress. NPRM Question 172 asks whether the OCC should only allow permitted issuers to issue a single type or brand of stablecoin to ensure the legal separateness of reserve assets backing a stablecoin issuer’s stablecoin.[36] NCRC agrees that limiting stablecoin issuers to a single type or brand of stablecoin will help ensure legal separateness – and adequacy – of reserves.[37]  

Second, the OCC NPRM affirmatively allows a practice by custodians that has been problematic in other contexts – the use of omnibus accounts by reserve custodians.[38] In addition to this provision being at odds with other provisions that attempt to ensure segregation of accounts, the recent example of the bankruptcy of Synapse Financial Technologies, demonstrates the challenges of such arrangements. Synapse was a “banking as a service” business providing online banking services to consumers through its partnerships with FDIC-regulated banks. The banks held the consumers’ funds commingled or omnibus accounts.[39] When Synapse went bankrupt, its records or ledger mapping individual consumer’s account funds to the commingled bank accounts were inadequate and over 100,000 consumers lost access to their funds. No one could identify who owned which assets.[40] The Consumer Financial Protection Bureau sued and settled with Synapse in the bankruptcy proceeding, allowing it to use its Civil Money Penalty Fund to provide relief to injured consumers.[41]

The Synapse collapse is a cautionary tale that supports not allowing omnibus accounts in the context of stablecoin reserves– the issue for Synapse resulted from minor discrepancies based on timing differences between bank settlement and ledger updates that were compounded based on the scale of the transactions.[42] Absent government action, thousands of consumers would have not been made whole. With stablecoins, the volatility of digital assets and their impact on the financial market may exacerbate the differences between reserves and ledgers. The commingling of assets in omnibus accounts puts redemption by holders at risk. Even though the GENIUS Act grants stablecoin holders “super priority” interest in reserves in the event of bankruptcy, because the reserves are not part of the bankruptcy estate, the bankruptcy trustee cannot use reserves to pay for administrative expenses related to the bankruptcy.[43] So, if there are inadequate assets in the bankruptcy estate to pay for the administrative costs associated with parsing commingled reserves, holders may be out of luck. There may not be sufficient funds available to establish what portion of the reserves are owed to whom. This dynamic increases the likelihood that government intervention will be necessary in the case of bankruptcy involving custodians with omnibus reserve accounts. Accordingly, the OCC should not allow custodians to hold omnibus reserve accounts.[44]

  1. Redemption and the Risk of Bank Runs[45]

The OCC NPRM requires timely redemption of stablecoins, generally within two days of a valid request.[46] However, it also provides for extensions of the time frame, for example to 7 days where holders seek in excess of 10% of the outstanding value of an issuer’s stablecoin within 24 hours.[47] When there is market volatility or bank stress, the faulty perception that stablecoin reserves mean holders can redeem their funds at any time may cause consumers to think stablecoins are safer than deposits and result in further deposit flight.. Alternatively, if there is instability or uncertainty in the stablecoin market, large numbers of holders may seek redemption from issuers in a short period of time. As a result, issuers may quickly withdraw large deposit balances from banks outside regular banking hours and overwhelm the banks’ capacity and liquidity. This could cause banks to have to quickly liquidate assets, possibly causing systemic stress.

Given the potential risks to safety and soundness and financial stability, the OCC should imposed variable redemption timeframes depending on circumstances but also require notifications and involvement of the OCC as set forth in proposed 15.12(c).[48]

  1. Lack of direct relationship between issuers and holders poses challenges for effectiveness of redemption and disclosure requirements.[49]

As discussed above, many holders of stablecoin obtain them through exchanges and other intermediaries. As a result, there is no direct relationship between issuers and many holders. This renders the mandatory initial and redemption disclosure regime outlined in the OCC NPRM ineffective. For example, it requires certain information be disclosed in customer agreements, such as: (i) the name of the issuer; (ii) that the issuer is obligated to convert, redeem, or repurchase the payment stablecoin for a fixed amount of monetary value; (ii) information about the composition of reserves; (iv) all fees associated with purchasing and redeeming stablecoins.[50] It also requires issuers to disclose this information on the issuer’s website and provide updates to customers. There is no obligation for exchanges or other third parties that sell the issuer’s stablecoin to make these disclosures to customers nor that the third parties direct customers to the issuer’s website. Moreover, it remains unclear how the OCC will confirm that the appropriate disclosures are made to the universe of holders of an issuer’s stablecoin.

Similarly, given this lack of direct connection between issuers and holders who purchase stablecoins through third parties or exchanges, it is not clear how such holders will receive the required disclosures regarding redemption rights.[51] The OCC GENIUS Act NPRM requires public disclosure but does not define how the issuer is to publicly disclose this information to holders who purchase through exchanges. Some issuers only “issue” stablecoin to a subset of customers and contractually limit redemption rights to that subset of consumers.[52] This practice raises the question of whether, if the OCC implements the NPRM, issuers can continue to limit their redemption and reserve responsibilities through contract.

Question 106 highlights this tension by asking “[t]o whom should issuers have the responsibility to deliver disclosures regarding changes in fees?” It then asks whether it should include all “all payment stablecoin holders (e.g., retail holders who purchased from an exchange or secondary market) or should it be a narrower subset of holders (e.g., only holders who purchased directly from the payment stablecoin issuer)?”[53] We strongly encourage the OCC to require that the issuer to be responsible for ensuring all stablecoin holders receive all of the appropriate disclosures, regardless of how the holder obtained the stablecoin.

  1.  OCC should address fraud concerns by establishing a framework that provides for restitution for victims of stablecoin fraud.[54]

Stablecoins are promoted as a payment mechanism, however currently, there is no way to reverse a blockchain transaction.[55] While legitimate merchants may applaud the lack of chargebacks and the related reduction in their costs, the lack of a mechanism for users to reverse a stablecoin transaction creates an enormous consumer protection issue that scammers exploit and stablecoin issuers potentially benefit from.

Recent reports indicate that stablecoins accounted for the majority of “illicit crypto” transactions in 2024 and 2025 resulting in billions of dollars tied to fraud, scams, and sanctions.[56] One big issue is fraudulently induced stablecoin transactions related to romance, investment, and other frauds and scams (“fraudulent inducement”).[57] For example, fraudulent inducement can occur when a when a consumer sends payment because of an imposter scam, fake investment platform, fake merchant, romance scam, or a fraudulent token is presented as authentic. Although many issuers and exchanges can freeze suspicious transactions, according to recent reports, they do not do so regularly and in some cases do not return the funds to the victims and instead continue to collect interest on the underlying assets.[58]

The OCC should address these fraud concerns in the context of this rulemaking.[59] One option is to adopt protections similar to the unauthorized credit card transaction provisions in Regulation Z which implements the Truth in Lending Act.[60] Once a customer raises an issue regarding an unauthorized transfer – be it a counterfeit token transfer, wallet compromise, private-key theft, malware attack, spoofed address transfer, etc. – or a fraudulently induced transfer, the customer’s liability should be capped. Under Regulation Z, that cap is $50.[61] And, like with Regulation Z, the issuer should be under a duty to investigate the claim, with the burden on the issuer and any other parties that acted as intermediaries to establish the customer authorized the transaction and it was not fraudulently induced. If unable to establish that, the issuer must reimburse the customer up to the cap. Doing so may incentivize issuers to develop technologies that can assist in reversing transactions.

In particular, the OCC should create protections to address fraudulent inducement, so the loss presumptively sits with the stablecoin firm ecosystem unless the firm proves it deployed effective fraud controls such as transaction specific warnings that require consumer acknowledgment. Including protections similar to chargebacks and card-network dispute rights for victims of fraudulent inducement of stablecoin transactions would level the playing field between payment systems.

Without a liability framework for payment stablecoins that is on par with other federal financial consumer fraud protections, stablecoin firms will enjoy a profound and unearned competitive advantage over traditional credit and debit card issuers — who must absorb fraud losses under Regulation Z (and the Electronic Fund Transfer Act and Regulation E)[62] — creating a powerful race to the bottom that redirects consumers toward less-protected payment instruments and undermines long-established  consumer safeguards. The OCC must ensure that fraud-loss allocation rules apply equally across functionally equivalent payment products; allowing stablecoin issuers to offload fraud risk onto consumers while card issuers cannot amounts to a regulatory subsidy that distorts competition and leaves consumers exposed.

Conclusion

The hundreds of questions posed in the GENIUS Act NPRM demonstrate the complexity of the issues associated with stablecoins. Without comprehensive additional legislation to address the significant risk of deposit flight, impact on community investment and lending, and massive consumer fraud losses with no liability backstop, it is premature for the OCC to finalize its proposed rule. We urge the OCC to wait to finalize the rule until the regulatory landscape is clearer. Moreover, when finalizing the Rule, we request that the OCC fully address the potential for deposit flight, bank runs and the systemic risks to the banking system, the role of exchanges and third parties as they relate to disclosures and redemption requests, and fraudulent activities directed to stablecoin customers.

Thank you for the opportunity to offer our input on the OCC GENIUS Act NPRM. If you have any questions, please contact me at jvantol@ncrc.org, or Tara Flynn at tflynn@ncrc.org.

Thank you for your consideration.

Sincerely, 
Jesse Van Tol  
NCRC President and CEO   

 


[1] Office of the Comptroller of Currency, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency Notice of Proposed Rulemaking (Feb. 25, 2026) [hereinafter OCC GENIUS Act NPRM].

[2]  OCC GENIUS Act NPRM 91 Fed. Reg. 10202, 10203 (Mar. 2, 2026).

[3] Several trade associations have requested that the agencies proposing these rulemakings extend the deadlines for public comments for 60 days after the issuance of the final rule by the OCC because they are dependent on the OCC’s Genuis Act NPRM. See Letter from Am. Bankers Ass’n, Bank Pol’y Inst., Consumer Bankers Ass’n & Indep. Cmty. Bankers of Am. to Various Agencies (Apr. 21, 2026).

[4] Department of Treasury Notice of Proposed Rulemaking at 8 (April 3, 2026) (hereinafter Treasury NPRM].

[5] See OCC GENIUS Act NPRM Questions 22;35-39.

[6] OCC GENIUS Act NPRM § 15.30 sets out the approval process for stablecoin issuers. Section 13.30(b)(3) contains circular definitions of when an application is substantially complete (e.g., it “is considered substantially complete as of the date the OCC receives the information required for the application to be substantially complete.”). It is unclear whether the OCC must affirmatively determine the application is substantially complete before the NPMR treats it as such. This is concerning because the NPRM provides that a “substantially complete application is deemed approved by the OCC as of the 120th day after the substantially complete application is received,” unless denied by the OCC. We urge the OCC to not allow for automatic approval of issuer applications in the absence of an affirmative decision by the OCC of not only the completeness of the application but also its sufficiency to meet the regulatory standards.

[7] GENIUS Act § 4(a)(11).

[8] Cong. Rsch. Serv., The Stablecoin Yield Debate (Mar. 2026), https://www.congress.gov/crs-product/IF13174.

[9] OPM GENIUS Act NPRM § 15.10(c)(4).

[10] OCC GENIUS Act NPRM § 15.10 (c)(4)(ii).

[11] OCC GENIUS Act NPRM § 15.10(c)(4)(i).

[12] See OCC GENIUS Act NPRM Questions 35-39.

[13] OCC GENIUS Act NPRM Question 22.

[14] See Cong. Rsch. Serv., The Stablecoin Yield Debate (Mar. 2026), https://www.congress.gov/crs-product/IF13174.

[15] Sayee Srinivasan and Yikai Wang, The CEA Studied the Wrong Question on Stablecoin ‘Yield’ and Community Banks, ABA Banking J. (Apr. 13, 2026), https://bankingjournal.aba.com.

[16] Id.

[17] Hannah Long, U.S. Banks May Lose $500 Billion to Stablecoins by 2028, Standard Chartered Warns, Reuters (Jan. 27, 2026), https://www.reuters.com.

[18] 12 U.S.C § 2901 et seq.

[19] Fed. Fin. Inst. Exam Council, Findings from 2023 Data Fact Sheet (Nov. 12, 2025), https://www.ffiec.gov/data/cra/findings-from-2023-data-fact-sheet.

[20] See Bakari Levy and Kevin Hill, The Need for Community Development Accountability for Stablecoin Issuers, NCRC (Jul. 14, 2025), https://ncrc.org.

 

[21] See generally OCC GENIUS Act NPRM Questions 44-99; 149-176; 201.

[22] 12 U.S.C. § 5903(a)(1).

[23] OCC GENIUS Act NPRM § 15.11.

[24] OCC GENIUS Act NPRM § 15.11(b)(2).

[25]  OCC GENIUS Act NPRM § 15.11(b)(3).

[26]  OCC GENIUS Act NPRM § 15.11(b)(8).

[27] OCC GENIUS Act NPRM Question 57.

[28]  OCC GENIUS Act NPRM § 15.11(c) Options A and B.

[29]  OCC GENIUS Act NPRM § 15.11(c) (2)(i) Option A; (c)(2)(i) Option B.

[30] ABA Banking Journal, CEA Studied the Wrong Question on Stablecoin “Yield” and Community Banks (Apr. 13, 2026), https://bankingjournal.aba.com.

 

[31] BH, How T-Bill Issuance Forces Fed Money Printing and Impacts Crypto, CoinPaprika (Nov. 25, 2025), https://coinpaprika.com.

[32] Are Treasury Bills Insured? FDIC vs. Government Backing, LegalClarity (Apr. 1, 2026), https://legalclarity.org.

[33] 12 U.S.C. § 5903(a)(1)(A)(viii).

[34] OCC GENIUS Act NPRM § 15.20, definition of covered custodian.

[35] OCC GENIUS Act NPRM Question 47.

[36] OCC GENIUS Act NRPM Question 172.

[37] NCRC also agrees that paying fees from reserve assets would be inconsistent with requirement for issuers to maintain identifiable reserve assets backing outstanding issuance value, see OCC GENIUS Act NPRM Question 99, and thus the rule should prohibit the charging of general corporate expenses against reserve assets.

[38] OCC GENIUS Act NPRM § 15.22; Question 158.

[39] ABA Banking Journal, FINRA Files Enforcement Action Against Former Synapse Officers over Alleged Supervisory Failures (Oct. 1, 2025), https://bankingjournal.aba.com.

[40] Jelle Van Schaick, The Hidden Cost of Pooled Accounts for Platforms, FinExtra (Feb. 8, 2026), https://www.finextra.com.

[41] Consumer Fin. Prot. Bureau, Enforcement Actions: Synapse Financial Technologies, https://www.consumerfinance.gov/enforcement/actions/synapse-financial-technologies-inc/.

[42] Jelle Van Schaick, The Hidden Cost of Pooled Accounts for Platforms, FinExtra (Feb. 8, 2026), https://www.finextra.com.

[43]12 U.S.C. § 5910; See also Morgan, Lewis & Bockius LLP, The Proposed GENIUS Act Raises Concerns over Insolvency Provisions (July 2, 2025).

[44] OCC GENIUS Act NPRM Question 207 (Should the OCC adopt any new rules or change any existing rules to implement the insolvency provisions of the GENIUS Act?).

[45] See generally OCC GENIUS Act NPRM Questions 100-108; 201.

[46] OCC GENIUS Act NPRM § 15.12(b)(1)(i); Question 100 (How should any definition of “timely appropriately balance consideration of price stability and run risk?”).

[47] OCC GENIUS Act NPRM § 15.12(c).

[48] See OCC GENIUS Act NPRM Question 102 (Should the OCC consider a longer redemption period timely in times of stress?).

[49] See generally OCC GENIUS Act NPRM Questions 105-108.

[50] OCC GENIUS Act NPRM § 15.12(d)(4). With respect to redemption fees, we would encourage the OCC to impose limits on such fees so that they must be reasonable, subject to a regulatory cap, and not modified unilaterally by issuers. See OCC GENIUS Act NPRM Question 104.

[51] OCC GENIUS Act NPRM § 15.12(a).

[52] Christopher K. Odinet, Andrea Tosato & Yesha Yadav, The Moneyness of Stablecoins, Yale L.J. (forthcoming 2026) at 36.

[53] OCC GENIUS Act NPRM Question 106.

[54] OCC GENIUS Act NPRM Question 210.

[55] Plasma, Do Stablecoin Payments Have Chargebacks (Nov. 16, 2025), https://www.plasma.to/learn/stablecoin-chargebacks.

[56] Olivier Acuna, International Finance Watchdog Warns Stablecoins are Increasingly Used in Sanctions Evasion and Money laundering, Coindesk (Mar. 3, 2026), https://www.coindesk.com.

[57] Julia Voo, Stablecoin Rails and the Limits of Financial Power, Int’l Inst. for Strategic Stud. (Mar. 5, 2026), https://www.iiss.org.

[58] Allison Morrow, Stablecoin Law Allows Crypto Firms to Profit from Fraud, Prosecutors Say, CNN (Feb. 2, 2026), https://www.cnn.com.

[59] OCC GENIUS Act NPRM Question 210 asks: “Should the OCC include consumer protection-related compliance risk management principles-based requirements and standards in § 15.13? And if so, are there specific standards the OCC should institute?”

[60] 12 U.S.C. § 1026.12(b).

[61] 12 U.S.C. § 1026.12(b)(ii).

[62] 15 U.S. C. § 1693 et seq.; 12 C.F.R. Part 1005.

]]>
NCRC’s Comment on the OCC’s Proposed Strategic Plan Guidance https://ncrc.org/ncrcs-comment-on-the-occs-proposed-strategic-plan-guidance/?utm_source=rss&utm_medium=rss&utm_campaign=ncrcs-comment-on-the-occs-proposed-strategic-plan-guidance Sun, 22 Feb 2026 20:42:56 +0000 https://ncrc.org/?p=281750

February 20, 2026

Office of the Comptroller of the Currency

(submitted through Regulations.gov)

RE: Docket ID OCC-2025-0669 – NCRC Comment on proposed strategic plan guidance

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the Office of the Comptroller of the Currency’s (OCC) proposed guidance regarding the strategic plan process for community banks. The OCC must provide significantly more detail on how it determined the proposed elective goals for community development financing. Our analysis of publicly available CRA performance evaluation data indicates that the proposed goals would lower regulatory expectations and risk a significant decline in community development loans and investments if the goals are not raised. The proposed guidance also misses an opportunity to provide common sense updates to how the public participates in the development of strategic plans.

NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality.

This comment is organized into three sections: goal setting, data collection, and public participation. To summarize our feedback and recommendations:

  • the proposed elective goals do not compare well to previous performance levels and will lower regulatory expectations of satisfactory and outstanding community development performance if they are not raised,
  • banks must provide previous performance levels when drafting strategic plan goals in order to put proposed goals in context,
  • the OCC should not move forward with accepting lower investment goals if at least half of the investments meet vaguely defined levels of high impact,
  • impact factors previously identified by the agencies in the 2023 CRA rule could help with the development of goals for high impact activities,
  • goals should increase over time to account for growth,
  • easily surpassed goals should be raised,
  • banks must not be allowed to dictate how multiple goals will be weighed,
  • small business and small farm data reporting requirements can not be waived through guidance, and
  • the OCC should post draft strategic plans online and encourage banks to post draft plans online during comment periods to improve the public’s ability to comment on draft strategic plans.

Goal Setting

Proposed Elective Goals Lower Regulatory Expectations of Satisfactory and Outstanding Community Development Performance

            The guidance includes potential elective goals for the level of community development financing that the OCC would consider as Satisfactory or Outstanding performance.[1] The goals provide specific ratios of community development loans or investments compared to assets or tier one capital, including that the OCC would consider 0.12% to 0.24% of assets devoted to combined community development loans and investments per year as Satisfactory based on the size and complexity of the bank.[2] The OCC has provided little detail on how the goals were determined but states that the proposed goals are based on “performance levels that the agency historically has expected of community banks with ‘Satisfactory’ or ‘Outstanding’ ratings” based on both previously approved strategic plans as well as ‘community banks’ CRA performance under the otherwise applicable performance tests and standards.” NCRC’s analysis of this same historical performance indicates that the current proposed goals are setting expectations far too low.[3]

            The Federal Reserve released data from CRA performance evaluations published from 2005 to 2020 in order to facilitate analysis of proposals to revise and update the CRA’s implementing regulations.[4] These Federal Reserve data sets are the most comprehensive public database of CRA performance evaluations, and include information that can be used to analyze the OCC’s proposed elective goals such as previous amounts of community development loans and investments reported by bank and assessment area, the time frame of the community development evaluation period, and asset sizes of the bank evaluated.

Historical median percentage of community development loans

 The chart above shows that the historical median percentage of community development loans or investments outperform most of the OCC’s proposed elective goals.[5] The median for combined community development loans and investments per year was 0.70% of assets for OCC regulated banks with $30 billion or less in assets, and 0.64% for banks with $1 billion or less in assets, from 2016 through 2020. This performance is significantly higher than the OCC’s proposed 0.12% to 0.24% for Satisfactory performance, and even higher than the 0.20% to 0.40% suggested for Outstanding ratings.[6] These medians are also a conservative estimate of previous performance as the Federal Reserve’s data set does not include data on community development loans and investments made outside of assessment areas.

NCRC estimates that if the OCC’s proposed elective goals were already in place, community development loans and investments would have decreased by nearly $100 million a year from 2016 through 2020 if just 10% of OCC-regulated banks near median performance dropped down to 0.24% of assets.[7] Significantly more community development financing would be at risk if more banks decide to opt into strategic plans using the OCC’s currently proposed goals.

Banks that do not pursue strategic plans may also point to this guidance to justify decreasing their community development financing. The OCC notes that “the elective goals should not be considered benchmarks for ‘Satisfactory’ or ‘Outstanding’ CRA performance outside the simplified strategic plan process.” However, if the proposed goals are significantly under current performance levels, as our analysis indicates, it risks turning the strategic plan option into a way for banks to decrease their CRA activity while still receiving passing CRA ratings. Furthermore, despite the OCC’s qualifications that the proposed goals should only be used in the development of strategic plans, we have already observed one instance of a legal advisor highlighting the proposed goals as indicative of how banks should analyze their levels of community development financing – regardless of whether they do strategic plans or are even OCC regulated.[8]

      The OCC must provide the data and methodology used to determine the proposed elective goals, and our analysis indicates they should be raised to prevent a decrease in needed community development financing. NCRC agrees that clarity around how much community development is expected is helpful for banks as they consider strategic plans and set their own internal performance benchmarks. However, these must be carefully constructed based on previous performance levels to avoid any long-term reductions in community development financing. 

In addition, the proposed Simplified Strategic Plan Form should require banks to include their past performance in reference to the metrics of all goals – community development, retail lending, and services –  in order to put proposed goals in context. For example, if a bank offers a combined annual community development loan and investment goal equivalent to 0.24% of assets – then the bank should provide their current ratio of community development loans and investments per year compared to assets. This will help the OCC implement its stated expectation that the strategic plan process will not be used to justify reductions in CRA-qualifying activity.[9]

High Impact Activities

The OCC is offering to accept lower community investment goals as long as “50 percent of the activity would be allocated to high impact activities, such as donations or complex or innovative investments.”[10] For example, the OCC suggests that as little as 0.04% of assets per year dedicated to community investments could merit a ‘Satisfactory’ rating as long as at least half of the activity was high impact, with 0.08% expected if less than half is high impact, and 0.24% if less than half is high impact and the bank does not offer a community development lending goal.[11]

This approach confuses more than it clarifies. For instance, using the metrics from the example above, a larger community bank would typically be expected to devote .08% or .24% of assets to community development investments per year, why then would the OCC be satisfied if only .02% (half of .04%) had high impact?  How was the 50% high impact threshold arrived at, and how does that compare to previous levels of high impact CRA activity? How is the OCC defining high impact?

The quality and quantity of a bank’s community development activities are equally important when reviewing CRA performance. We reject the idea that less CRA activity is acceptable if it meets undefined levels of impact, and consequently, less impactful activities are also acceptable if the bank does more of them. NCRC recommends that the OCC remove this portion of the proposed elective goals.

The OCC also requests input on whether they should offer an “elective goal based on the percentage of qualified investments that are highly impactful, such as grants or donations?”[12] This could be helpful, but the OCC must provide more detail on what is considered “highly impactful”. The 2023 CRA rule created twelve different factors that examiners would use to evaluate the impact of a bank’s community development activities, including activities to benefit persistent poverty counties, census tracts with poverty rates over 40%, and Native Land Areas.[13]

Instead of creating a generic high impact goal, the OCC should instead offer elective goals for each of the twelve different factors previously identified by the OCC and the other agencies in charge of implementing the CRA. Banks could then draft goals related to which of those impact factors are relevant to their assessment areas. For example, a bank with census tracts with poverty rates over 40% in their assessment area could create a goal related to lending or community development activities that would benefit those tracts. As with all goals, NCRC strongly recommends that banks be required to provide their previous performance to allow reviewers of the strategic plan to put proposed goals in context. NCRC would also support an elective goal specifically for CRA-eligible grants or donations, which was one of the factors identified in the 2023 rule.

Increasing Goals

The OCC asks for input on whether it’s “appropriate to increase the performance expectations for community banks’ annual interim measurable goals over time?”[14] We support the OCC’s stated expectation that a bank will “annually increase the dollar-denominated thresholds in its interim goals to account for a bank’s expected growth and the resultant increase in capacity.”[15] Furthermore, if a bank significantly surpasses an annual goal in the first year of a multi-year strategic plan, it indicates that the goal was set too low and there should be a recalibration of the goals for the remaining years of the strategic plan using the plan amendment process already provided in the strategic plan regulations.[16]

Weighing Goals

            Finally, the OCC requests input on whether it should “include the option for banks to specify a methodology for weighting measurable goals included in the proposed strategic plan” in instances where a strategic plan includes multiple goals or assessment areas.[17] This approach gives too much leeway for banks to determine how their CRA performance is evaluated. Instead the OCC should clarify the methodology it will use to weigh multiple goals. The OCC has suggested using “deposit market share, lending market share, or a combination of the two” as possible weighing methodologies.[18] Our recommendation would be for the OCC to clarify that it will use a combination of deposit and lending market shares, and not give banks the option to determine how their performance will be weighed across multiple goals or assessment areas.

No Waivers for Small Business or Small Farm Data Collection

            The OCC is proposing to waive small business or small farm data collection requirements on a case-by-case basis.[19] This is unsuitable for regulatory guidance because it directly contradicts current strategic plan regulations that specifically describe how “approval of a plan does not affect the bank’s or savings association’s obligation, if any, to report data as required by § 25.42.”.[20] Section 25.42 requires all banks, except small banks, to collect small business or small farm data, and the OCC must not allow through this guidance the possibility of a waiver from these requirements.

Public Participation

            The process for the public to provide comments on draft strategic plans is woefully out of date. The 1995 CRA regulations require banks to informally seek public input during the drafting of a strategic plan and to post notices of draft plans in at least one newspaper in their assessment areas for a 30-day comment period, as well as making the plan available in branches.[21] In practice, these notices are largely placed in trade papers that are not widely read by the public and nonprofit organizations active in community development, resulting in minimal opportunities for stakeholders to weigh in on how banks will serve their communities.

            It’s concerning and inconsistent that the OCC is considering options that make it easier for banks to submit strategic plans online, such as web based forms, without applying the same considerations to public input.[22] To correct for this, the OCC could post draft plans on its website and revise the proposed guidance to encourage banks to also post draft strategic plans online to better facilitate public participation. This would not contradict current strategic plan regulations that require strategic plans to be placed in “ in at least one newspaper” in each assessment area as plans could be posted online in addition to newspapers, and the regulatory language establishes a minimum of at least one newspaper but does not restrict further steps to solicit public input.[23] Without improvements to facilitate public input, increased use of the strategic plan option poses a serious risk of restricting opportunities for meaningful participation in the CRA process.

Comments on CRA exams typically raise performance issues or highlight community needs that are currently being underserved. The purpose of commenting is to encourage a bank to devote more resources to aspects of their performance, or consider additional priorities for their community development portfolio. However, the public’s ability to influence a bank’s CRA performance is limited while the bank is operating under a strategic plan. The bank has essentially worked out with its regulator what they need to accomplish to receive a passing rating, increasing the importance of providing a meaningful opportunity for the public to weigh in on plans before they are finalized. If this guidance is approved without improvements, the anticipated increase in the adoption of strategic plans risks relegating local community development practitioners, elected representatives, and other stakeholders to bystander roles, as banks lock in their CRA priorities and commitments for up to five years with little public input.

Conclusion       

The proposed elective goals must be revised in order to prevent significant reductions in community development financing, and the OCC should use this guidance to recommend banks post draft strategic plans online, as well as posting on the OCC website, in order to modernize the public comment process.

 Thank you for considering our views on this important matter. If you have any questions, please contact me at khill@ncrc.org.

Sincerely,
Kevin Hill
Senior Policy Advisor
National Community Reinvestment Coalition


[1] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59762-59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[2] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[3] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59748-59749 . https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[4] The Federal Reserve’s CRA data tables are available for download at https://www.federalreserve.gov/consumerscommunities/data_tables.htm. Information about the data tables, including the number of performance evaluations reviewed and sampling methodology can be found in the “User Guide – CRA Analytics Data Tables” available online a

t https://www.federalreserve.gov/consumerscommunities/files/cra-final-rule-data-tables-user-guide.pdf.

[5] Based on NCRC’s analysis of the Federal Reserve’s merged data table. We first combined the community development loan and investment data from all of a bank’s reported assessment areas during a single performance evaluation and created a ratio of the total community development loans or investments per year compared to asset size, and then removed performance evaluations where there appear to be issues in the reported data. Specifically we removed all exams with no community development loan and investment data, as well as exams where the ratio of combined average community development loans and investments per year was greater than 10% or less than 0%. After removing these outliers, our sample included 239 OCC bank performance evaluations from 2016 through 2020 involving banks with assets greater than $30 billion, and 131 under $1 billion.

[6] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[7] To prepare this estimate, we used the Federal Reserve’s merged data table to identify OCC published CRA performance evaluations from 2016 through 2020 reviewing banks at $30 billion in assets or less. We included all exams in the Federal Reserve’s merged data table with any reported community development loan and investment data and ratios of annual combined community development loans and investments compared to assets of less than 10% and greater than 0%. After removing these outliers, we sorted the 239 exams based on their ratio of combined average community development loans and investments per year compared to assets. We used that to calculate the median of .70% for OCC regulated banks with assets of $30 billion or less with CRA performance evaluations released from 2016 through 2020. To prepare the reduction estimate we then organized the 120 banks above .70% into deciles and compared the actual amount of community development loans and investments per year reported in their CRA performance evaluation to the level of community development loans and investments expected if the bank achieved .24% of assets devoted to community development loans and investments per year for banks in the lowest decile. This determined that combined community development loans and investments would have decreased by $94.7 million per year from 2016 through 2020 if those lowest decile banks had achieved .24% of assets devoted to community development financing as compared to their actual levels.

[8] “To be sure, the agency does state that the elective goals are deigned for use in the simplified strategic plan process for community banks only and that the elective goals should not be considered as benchmarks for “Satisfactory” or “Outstanding” CRA performance outside the simplified strategic plan process. But at the same time, the agency states, “the OCC is proposing elective goals that are consistent with the performance measures and performance levels that the agency historically has expected of community banks with ‘Satisfactory’ or ‘Outstanding’ ratings”.

I know this, as we advise our clients about their CRA performance we intend to reference the OCC’s proposed measures and performance levels for “Satisfactory” and “Outstanding” community development performance ratings. This is particularly true in light of the agency’s admission that the proposed standards and ratings reflect their historical experience.”

Important Lessons in OCC Simplified Strategic Plan Proposal for all ISB’s and Large Banks. JD Supra. January 28, 2026. https://www.jdsupra.com/legalnews/important-lessons-in-occ-simplified-9260357/

[9] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59748. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[10] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Pages 59752 – 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[11] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59763. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[12] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[13] Federal Register / Vol. 89, No. 22 / Thursday, February 1, 2024 / Rules and Regulations. Page 6714. https://www.govinfo.gov/content/pkg/FR-2024-02-01/pdf/FR-2024-02-01.pdf

[14] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59751. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[15] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59748. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[16] Title 12 Chapter I Part 25 Subpart B § 25.27 (h)

[17] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[18] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59753. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[19] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59761. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[20] Title 12 Chapter I Part 25 Subpart B § 25.27 (b)

[21] Federal Register / Vol. 60, No. 86 / Thursday, May 4, 1995. Page 22182. https://www.govinfo.gov/content/pkg/FR-1995-05-04/pdf/95-10503.pdf

[22] Federal Register / Vol. 90, No. 243 / Monday, December 22, 2025 / Proposed Rules. Page 59755. https://www.govinfo.gov/content/pkg/FR-2025-12-22/pdf/2025-23547.pdf

[23] Title 12 Chapter I Part 25 Subpart B § 25.27 (d) (2)

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