Search Results for “timantha goff” – NCRC https://ncrc.org National Community Reinvestment Coalition Thu, 11 Dec 2025 16:42:50 +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 “timantha goff” – NCRC https://ncrc.org 32 32 How misuse of the trust bank charter model will lead to more financial woes for communities https://ncrc.org/how-misuse-of-the-trust-bank-charter-model-will-lead-to-more-financial-woes-for-communities/?utm_source=rss&utm_medium=rss&utm_campaign=how-misuse-of-the-trust-bank-charter-model-will-lead-to-more-financial-woes-for-communities Thu, 11 Dec 2025 16:42:50 +0000 https://ncrc.org/?p=275175 The nation’s largest crypto firms are looking to consolidate their power to the detriment of their customers and communities already lacking vital consumer protections and economic development opportunities.

As more and more digital currency companies are vying for financial legitimacy by becoming a national trust bank via the Office of the Comptroller of the Currency (OCC), a growing chorus of organizations are raising concerns about what will likely manifest into more financial issues for low- to moderate-income (LMI) Americans.

NCRC has recently formally opposed several national trust bank charter applications from stablecoin and cryptocurrency firms due to their often unregulated and exploitative operations and the larger implications on community development. Other financial institutions and financial reform organizations across the spectrum (from traditional banking institutions to consumer rights advocates to locally owned and operated community banks) have also sounded the alarm on the dangers this could pose to communities as well. 

What is a national trust bank charter?

A bank charter is a business license for an institution looking to provide bank-like services. Companies wanting to engage in banking activity may obtain a bank charter at either the state or federal level via a banking regulatory body. 

There are multiple different types of bank charters, some of which convey more regulatory accountability than others. The type that cryptocurrency firms are seeking – known as a national trust bank charter – comes with less stringent oversight and fewer public protections than a layperson might expect from something with the word “bank” in its name.

“National trust banks are not subject to the full set of regulations that are generally applicable to commercial banks,” the Congressional Research Service wrote in a 2022 analysis.

Stablecoin and cryptocurrency companies’ newfound interest  

Currently, cryptocurrency companies and other nonbank financial institutions have to utilize third party intermediaries to manage their investments, protect their assets and accomplish other fiduciary activities given that they don’t have the regulatory permissions to do so on their own. However, gaining national trust bank status would provide sought-after legitimacy as well as allow “[t]he players who voluntarily step into regulation, get the proper licenses and build the right structure… [to] be the ones institutional capital flocks to,” as crypto analyst Patrick Thompson puts it.

Congress gave the OCC the federal authority to grant national trust bank charters in the National Bank Act of 1863-64, with the understanding that the resulting trust companies would focus on fiduciary activities—such as acting as a trustee or executor—as well as asset custody. The law intentionally separated such activities from traditional banking functions like taking deposits or making loans. 

Two recent changes have resulted in a surge in national trust bank charter applications from stablecoin companies. First, a 2021 change in the OCC’s trust bank charter creation policy called Interpretive Letter #1176 provided an operational requirement loophole by taking the position that a national trust bank may engage in any permissible activities of a trust company, not just fiduciary duties. This includes non-fiduciary custody of assets, which is critical for stablecoin issuers and crypto custodians. 

Second, in July 2025, Congress passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), which explicitly authorizes nonbank payment stablecoin issuers to operate under federal oversight and recognizes OCC-chartered trust banks as an eligible structure for compliance purposes. 

Previously, cryptocurrencies were considered securities that were regulated by the US Securities and Exchange Commission (SEC). By removing legal uncertainty around stablecoin issuance and expanding OCC authority to include these issuers, the GENIUS Act creates a pathway for crypto companies to apply for a national bank charter. However, as emphasized in recent comment letters submitted by NCRC, the Independent Community Bankers Association, the Bank Policy Institute and Americans for Financial Reform, it is questionable whether OCC has the authority to grant a national trust bank charter to stablecoin issuers: 

“Congressional intent, plain reading of the statute, and current regulations only grant the [OCC] authority to grant national trust bank charters to institutions that perform these narrow fiduciary activities and only these narrow fiduciary activities.” In contrast, crypto companies applying for the national trust bank charter propose to engage in activities that go beyond fiduciary activities, including processing payments and issuing private stablecoin currencies. 

The negative impacts on vulnerable communities

Multiple cryptocurrency companies that have filed for national trust bank charters, such as Circle, Coinbase, Ripple and Crypto.com have long track records of unethical business practices that should give the OCC serious pause in allowing them more freedom to operate in the financial services space. There are a whole host of consequences to the exploitation of the national trust bank charter model not only for national and global financial markets, but for communities already dealing with compounding financial pressures.

Lost reinvestment opportunities back into communities

National trust banks are not subject to the Community Reinvestment Act (CRA), meaning that they would gain the reputational and operational benefits of this new designation but shoulder none of the corresponding community development requirements to serve the credit needs of LMI communities. 

“Banks power the economy by turning deposits into loans,” wrote Weston Loyd, vice president, head of media relations and third party engagement with the Consumer Bankers Association (CBA). “Incentivizing a shift from bank deposits and money market funds to stablecoins would end up increasing lending costs and reducing loans to businesses and consumer households.”

As noted in multiple comment letters from NCRC, “This diversion of capital away from entities with a community reinvestment obligation represents a fundamental departure from the principle that federally chartered institutions should serve public purposes, not merely private profit.”

Since customers of stablecoin companies tend to keep those funds in that form instead of depositing them and these nonbanks aren’t required to keep deposits received within the US banking system, vital funding for community and economic development opportunities would be diverted from CRA-regulated traditional banking institutions.

“The [trust bank charter] applicants propose to engage in activities such as managing stablecoin reserves, facilitating payments and taking deposits. These activities closely mirror core banking functions,” according to the Bank Policy Institute (BPI).  “[Y]et the applicants would avoid obtaining deposit insurance, nor would they be subject to consolidated supervision and consumer protections and other safeguards required of full-service national banks and their parent companies.”

Will create more structural risks to financial systems

Given the volatile, unpredictable nature of digital assets, this regulatory grey zone that stablecoin companies seek to inhabit only leaves more room for risky behavior to the detriment of consumers and the larger financial system.

“Recent failures of major crypto-platforms demonstrate the risk of wholesale loss of customer assets absent deposit insurance and resolution mechanisms,” according to Michael Emancipator, senior vice president and regulatory counsel with Independent Community Bankers of America (ICBA). “A charter that legitimizes such activities without equivalent safeguards exacerbates systemic vulnerability for all participants in the financial system.”

These concerns have united traditional banking institutions in formally opposing the expansion of national trust banking charters to stablecoin firms. “If the Applicants are successfully able to establish themselves as national trust banks that do not primarily provide fiduciary services, but instead provide traditional banking services like payments,” a July 2025 joint comment letter to the OCC by America’s Credit Unions, ICBA, CBA, the National Bankers Association and the American Bankers Association said, “then… other companies will follow, presenting material risk to the U.S. banking and financial system.”

No obligation to avoid deceptive practices in setting fees

The OCC’s current National Bank Charges regulation gives national banks – including trust banks – the authority to establish and charge non-interest fees and charges to its customers. Noticeably absent from this regulation is any requirement to consider consumer impact when setting fees and charges. 

The National Bank Charges regulation does not prohibit unfair, deceptive or abusive acts and practices, leaving consumers vulnerable to extractive and hidden fees with no recourse or without any meaningful consequences for trust banks. This regulatory gap is especially troubling in the context of several recent stablecoin company trust bank charter applicants, who have a history of regulatory violations and enforcement actions. Some of these issues are outlined in NCRC’s recent comment letters on the topic.

Lack of adequate regulatory requirements and internal controls will allow fraud to grow

The regulatory framework that cryptocurrency firms and stablecoin entities are currently governed by is already sorely lacking when it comes to preventing fraudulent activities against consumers. Several of these same companies looking to attain national trust bank charter status have been rife with fraud and cybercrime claims. 

The sector’s money laundering problems have continued despite pledges to shape up, according to new reporting from the International Consortium of Investigative Journalists. Additionally, stablecoin now accounts for 63% of all illicit crypto transactions.

The Financial Action Task Force (FATF), a global finance crime watchdog group, has cautioned that the growing rate of illicit financial activities happening on the crypto industry’s watch is something that could have far-ranging impacts. “With virtual assets inherently borderless, regulatory failures in one jurisdiction can have global consequences,” said the FATF in a recent Reuters article.

Mounting fraud losses and the growing use of private stablecoins as the currency of choice for fraudsters and money launderers is a universal concern that NCRC has highlighted in several comment letters and that other industry trade groups, like ICBA and BPI, have raised issues with as well.

The importance of community development requirements for nonbanks 

Being granted a national trust bank charter has historically been a privilege bestowed on financial entities operating at the highest standards and in the best interests of its stakeholders and the public. Given that stablecoin and cryptocurrency institutions would be permitted new capabilities to take deposits and issue currency akin to traditional banking institutions, it would stand to reason that they should also be held accountable to the same federal regulatory and community reinvestment standards as well. 

“Applying community development obligations to nonbank stablecoin issuers would likely drive billions of dollars into needed community and economic development projects and initiatives,” wrote Kevin Hill, NCRC’s senior policy advisor. “In 2023 alone, banks originated over $127 billion in loans that met the CRA’s definition of community development for LMI communities and households.”

The Community Reinvestment Act mandates that traditional banking institutions equitably serve the credit needs of all communities in this country. If cryptocurrency exchanges and stablecoin issuers want to reap the full monetary and societal benefits of becoming a national trust bank, then they need to reinvest into the communities that they will be extracting value from.

 

Timantha Goff is the Managing Editor & Writer for NCRC’s Communications team.

Photo credit: Traxer via Upsplash.

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With the Stroke of a Pen: The Devastating Impacts of Executive Orders on Community & Economic Development Nonprofits https://ncrc.org/with-the-stroke-of-a-pen-the-devastating-impacts-of-executive-orders-on-community-economic-development-nonprofits/?utm_source=rss&utm_medium=rss&utm_campaign=with-the-stroke-of-a-pen-the-devastating-impacts-of-executive-orders-on-community-economic-development-nonprofits Mon, 08 Dec 2025 14:35:43 +0000 https://ncrc.org/?p=273643

With the Stroke of a Pen:

The Devastating Impacts of Executive Orders on Community & Economic Development Nonprofits

December 2025

Timantha Goff, Managing Editor and Writer
Jad Edlebi, GIS Data Engineer

Key Takeaways

1

Nonprofit-driven economic development projects are being halted as a consequence of executive orders targeting the sector. Survey respondents report not only difficulties in planning future programming but disruption to projects that were already underway.

2

Uncertainty and fear are disrupting day-to-day operations at nonprofit organizations as the direct impact of executive orders is compounded by a retreating philanthropic sector.

3

Immigrants, refugees and minority entrepreneurs are being hit hardest by the combined direct and indirect effects of executive orders aimed at undermining nonprofit community and economic development work.

Introduction

The community and economic development (CED) nonprofit sector has played a pivotal role in the struggle for civil and human rights across a variety of CED policy areas in this country for decades. The vast majority of the monumental advances American society has made have had some sort of connection to passionate leaders, advocates, policy experts, attorneys, researchers and community activists directly working in, or in partnerships with, nonprofits. Additionally, CED nonprofit organizations operating at the national, state and hyperlocal levels have been a vital resource for meeting the material needs of Americans across a variety of socioeconomic and political spectrums.

However, the Trump Administration’s recent efforts to undermine the reach, efficacy and overall existence of these organizations have led to questions and concerns about the fate of these important institutions. The weaponization of executive orders has been an especially lethal tool for causing the maximum amount of difficulties for CED nonprofit organizations while circumventing accountability for the harm being done to the people CED nonprofits serve. CED nonprofits across the country are facing an existential crisis that has never been seen before in the sector’s history.

This qualitative research brief will highlight the effects on CED nonprofits of the myriad of executive orders (EOs) President Trump has issued that have unfairly placed our nation’s CED nonprofits in the crosshairs of the Administration’s frighteningly retrograde agenda. The brief also provides next steps for all of our nation’s most influential stakeholders in combatting this all-out assault on the CED nonprofit sector.

Methodology

Participants

The National Community Reinvestment Coalition (NCRC) is a member organization with a variety of entities working on behalf of economic justice programs and initiatives, in particular community-based nonprofit organizations. Speaking with some of the nonprofit members of NCRC seemed to be the most logical choice as the convenience sample group for this study.

Outside of ensuring that all of the participants were actual CED nonprofit organizations and that they were current members of NCRC, there wasn’t any other concrete selection criteria. We sought to include the most diverse range of backgrounds possible to provide the most nuanced perspective on the impacts of the Trump Administration’s executive orders. Survey respondents were informed that their responses would be shared anonymously.

Data Collection

The survey administration and response collection process took place in May and June 2025. For the month of May, the survey was administered via weekly NCRC member-only newsletters with a deadline of the end of that month for their completion. Towards the end of May, the survey was disseminated via NCRC’s social media channels.

For the month of June, the remainder of the 40 survey responses were collected via 1-on-1 phone calls made to nonprofit NCRC member organizations based on a list compiled by NCRC’s Membership team.

The survey was subsequently closed for submissions at the end of this second survey administration period. All gathered responses were again vetted to ensure that all survey respondents were in fact NCRC members and classified as nonprofit organizations.

Analysis Approach

To effectively compare recurring themes across the survey responses given, this study uses a thematic analysis framework to identify key findings. We used the free, open-source qualitative analysis software Taguette to analyze responses given for the following four core survey questions:

  • Which Trump Administration executive orders (EOs) have caused a disruption in the services your organization/company/institution provides to community members and other stakeholders? (It’s okay if you don’t know the exact name but please try to provide as much detail as possible)
  • What short term impacts have these executive orders had on your clients/community members/stakeholders?
  • What have been the effects of the Trump Administration’s executive orders on the operational, financial and/or programmatic health of your organization/company/institution?
  • Do you have any other thoughts you’d like to share?

The responses to the first survey question were coded via noteworthy terms and phrases around initiatives, agencies and programming targets that could then be linked to the appropriate executive order. The overlapping themes that are explored and interpreted in the Key Findings and Further Discussion sections below were directly informed by the qualitative coding of words, phrases and sentences from across all four core survey questions.

The survey responses were combed through a total of three times to ensure that any and every perspective given was accounted for in the final qualitative analysis. In order to maintain confidentiality, access to the responses was restricted to the investigator and survey collector, and responses were discarded once the analysis was complete.

Key Findings

Below is a comprehensive treemap detailing the executive orders that were mentioned by survey respondents as having caused their organizations and the communities they served the most issues, along with some of their own perspectives on the damage each executive order has wrought via their provisions:

The size of each respective EO block is representative of the overall number of mentions it received throughout all of the survey question responses. Lastly, while the EO that appears the most (EO-RFPR) was technically not an official executive order, it was a monumental executive action done via memo that had a massive presence in the survey responses and thus was incorporated into the treemap.

Below are the major recurring themes pulled from the survey responses that were collected in order of the number of mentions each received. One of the main takeaways from the survey responses was the intersecting and overarching impacts of various executive orders mentioned that compounded into multiple issues for the work and lives of CED nonprofit organizational staff and the communities that they serve.

Additionally, the majority of survey respondents have either experienced some sort of direct impact from the federal grant funding cuts, pauses and disruptions imposed by the executive orders or reported collateral fallout from the executive orders.

Service disruption and program cancellation

Survey respondents frequently reported having to halt new programs or planned projects or eliminating some programs altogether as executive actions led to federal funding commitments being rescinded. This has effectively led to fewer clients being able to take advantage of the services these nonprofits have been providing to communities in need for years:

“This loss has stalled critical projects that would have provided housing stability and economic opportunity in historically excluded neighborhoods.”

Several of the CED nonprofits surveyed have had to become more nimble when it comes to how their new programming will look given the new budget constraints. One respondent said that they have “had to stop everything to develop risk and contingency plans” due to the executive orders effectively ending their programming by withdrawing its funding.

The mental and emotional toll of the EOs

Fear, anxiety, helplessness and uncertainty stemming from the onset of the executive orders appeared in the majority of survey responses. In particular, the mental and emotional stress that comes with not being able to properly plan for the financial and operational future of their organizations was top of mind for multiple respondents as well:

“Our biggest disruption is uncertainty… Right now we are a financially viable organization but are largely funded by government contracts and grants. It is difficult to make decisions when we are not sure what the next couple years will look like.”

“We just want to know where we stand so we can plan for the future again.”

These detrimental effects have caused a variety of adverse effects for clients and community members. However, several survey respondents that are in leadership roles at their organizations conveyed concern about the overall wellbeing for members of their staff given the uncertainty of their own livelihoods being at stake as well:

“One of the greatest impacts has been on the mental health of our entire team. No one should have to live with this fear.”

Effects on immigrant and refugee populations

The federal funding cuts have had major implications for CED nonprofit organizations providing services to members of the immigrant community. Multiple respondents reported their programs are going underutilized as clients stop participating:

“Some delayed or withdrew from applying for loans, attending workshops or seeking technical assistance out of fear of exposure, legal repercussions or the possibility of jeopardizing their residency status.”

Undocumented clients are deciding to forgo important services and opportunities in order to keep themselves and their families safe from possible apprehension efforts from the US Immigration and Customs Enforcement (ICE) agency. Multiple survey respondents said that the looming threat of undergoing deportation proceedings is making their clients wary of taking the chance of public exposure by accessing nonprofits’ services:

“Many of the undocumented residents we have historically served are going without critical resources as they are in fear of ICE detainment at food banks, local shelters and other spaces offering needed resources and services.”

“Many of the workers for the rehab project are no longer coming to the job in fear of ICE therefore causing even more delays.”

Reductions in staff and hiring freezes

The federal funding cuts have led many CED nonprofits to make difficult decisions on how best to stay afloat financially, leading many to cut vital staff positions. This will inevitably lead to even less services and programming being rendered to the most vulnerable communities:

“This was a 50% cut to our grant funding and resulted in us having to lay off some longstanding members of our team.”

“We’ve had to lay off staff… Therefore, we are even more overworked.”

It has also had a ripple effect on CED nonprofit organizations that have been providing financial support to smaller community-based initiatives. One survey respondent said that “Our members are being impacted financially. Many are laying off staff.”

Client financial instability

The financial struggles facing clients of the CED nonprofits surveyed showed up often across multiple survey responses. This further illustrates the complexity of the effects of the EOs in foreseen and unforeseen ways for the communities CED nonprofits serve:

“By increasing tariffs on lumber and steel and virtually all building materials, the cost to build affordable housing for rent is going up so the price to build will also rise making safe, affordable housing increasingly more difficult.”

“Cost of living increases [are] raising the number of families with expenses higher than [their] income. [The] fear of job loss is slowly turning [in]to reality for many with the expectation that unemployment will increase.”

Several survey respondents mentioned concerns that clients would have to look for alternative ways to make ends meet given federal social safety net cuts that could lead them into an insurmountable debt cycle:

“Many individuals became more susceptible to predatory lenders, leading to financial setbacks.”

Funding changes at the philanthropic level

Philanthropic institutions, one of the largest financial backers of the CED nonprofit sector, have had to make hard decisions around how they will operate in a federal environment newly hostile towards any social justice-oriented work. Unfortunately, nonprofits have been left confused and worried about where this leaves them in the long run while the philanthropic sector figures out next steps for itself:

“The combination of shrinking federal dollars and tighter geographic preferences in philanthropy is putting additional strain on community-based nonprofits like ours that serve broader areas.”

“What's also troubling is that the foundations and corporations don't seem to be stepping up like [with] the response in the early COVID days. It feels like most are taking a pause, doing strategic planning, assessing needs and largely just sitting on the sidelines.”

The debilitating uncertainty of the federal executive orders has caused continued confusion and hesitation for philanthropic organizations as much as the nonprofits they provide funding:

“One of our most reliable funders has shifted to supporting only nonprofits in its home region and many others are overwhelmed with requests.”

“[The] philanthropic community seem[ing] to be at a standstill trying to figure out how to counter [the] dramatic assault on community investment.”

Effects on BIPOC entrepreneurs and developers

Several of the survey respondents mentioned executive orders that directly targeted small business development and community development funding programs for historically underrepresented groups as a point of contention:

“There were significant proposed cuts and regulatory changes to federal programs supporting small businesses, particularly those benefiting women, minorities, and low-income individuals:”

“The uncertainty surrounding small business and community development funding also disrupted planning for some of our strategic partners. [It] made it more difficult for our stakeholders to confidently allocate resources to minority and low-income entrepreneurs during this period.”

Black and minority developers who already had to deal with a lack of funding opportunities before the federal funding crisis are now at risk of not seeing their equitable housing projects come to fruition for communities most in need of affordable housing:

“These funds were critical to enabling Black and minority developers to access capital for housing construction in underinvested communities.”

Closing of operations/unsure operational future

The federal funding cuts created by the executive orders have left several CED nonprofit organizations surveyed questioning whether they can continue to operate given the lack of funding options available to replace the grant funding that was lost and no way to guarantee they can bounce back from the current funding cuts:

“These abrupt interruptions to funding and programming have compromised our current operations and our ability to support the economic vitality of our region.”

“I am extremely concerned that [the] organization will have to close their doors or stay open and be impotent.”

A few of the CED nonprofits surveyed said that they will have to close their doors since the federal funding that was rescinded was crucial for the operational sustainability and the financial health of the organization:

“This affects our operational and financial status going forward. We will probably have to shut our doors in less than 12 months.”

Effects on rural communities

Several survey respondents worried that rural communities that have already received the short end of the stick when it comes to community and economic development opportunities will now be at risk of having none whatsoever:

“Economic development in rural and urban areas are at risk.”

“I fear for our rural members.”

A few CED nonprofits that provide services to rural communities have had to scale back or end the programming altogether:

“We no longer provide resident services to low income families across the state, particularly in rural areas.”

Further Discussion

Areas for additional research opportunities

Outside of a few academic studies highlighting some of the impacts of federal attacks on refugee resettlement programs during President Trump’s first term, there currently aren’t  any studies around the impacts of the executive orders signed during this current term. The Administration’s more targeted attacks on specific nonprofit organizations and the ripple effects this will have in future years for underserved communities is a topic that is worthy of future research.

There are several additional possibilities for future areas of research when it comes to properly tracking the impacts of the federal executive orders on CED nonprofits and affected nonprofit organizations writ large. Researchers should consider examining the long-term operational and financial outcomes for impacted CED nonprofits, the long-term adverse effects on the larger service areas and client communities where impacted CED nonprofits provide programming and services, whether meaningful funding adjustments were made by the philanthropic and private sectors as well as state/local government entities and the resulting trends on EO-impacted CED nonprofits.

The need for independent tracking of EO outcomes

The institutions that would normally be expected to track these sorts of outcomes (i.e. federal agencies, watchdog journalism publications, think tanks at colleges and universities, etc.) are all facing their own existential crises due to the direct legal, legislative, judicial and executive challenges of this current administration. Therefore, the need for independently funded, open-source mechanisms for nonprofit organizations, the various stakeholders advocating on their behalf and the general public to track the concrete outcomes of these EOs for accountability reasons is paramount.

However, there are multiple public interest law firms with online executive order trackers, with the National Council of Nonprofits creating the most comprehensive overview of the executive orders affecting nonprofit organizations along with several helpful resources for nonprofits on how to navigate these uncertain times and stay afloat. Ensuring the accuracy of the internal data and mechanisms for tracking all financial, operational and programmatic outcomes will become even more important, not only in proving the importance of the work but in procuring additional funding and better supporting policy and advocacy efforts.

Additionally, academic institutions that are in a better position financially to challenge these disruptive federal actions would be best positioned to track these outcomes. This data tracking work is vital in holding executive and federal legislative players accountable for the inevitable fallout of these executive orders on CED nonprofit organizations and impacted communities as well. Lastly, finding funding sources that are either nonpartisan in nature or that have a firm commitment to the ethical ethos of the work of our nation’s CED nonprofits would provide the best permanent funding streams for this accountability work.

Next Steps

Given the volatile and unpredictable nature of the federal executive orders in conjunction with other ongoing legal, legislative and regulatory challenges to CED nonprofit organizations, it is imperative that all stakeholders work in a collaborative and strategic manner to ensure our nation’s nonprofits are properly supported through this difficult period.

Policymakers at the state, county and municipal levels should be focusing on creating legal and legislative safeguards against the attacks on CED nonprofits at a statewide level. Additionally, providing more funding to nonprofits operating in their respective jurisdictions that are providing vital services would be extremely beneficial.

The philanthropic sector (especially those operating at the national level) needs to find ways to support the work of CED nonprofits at a higher capacity regardless of geographic determinations or possible fears of attacks themselves. The social and economic capital that the philanthropic sector possesses needs to be utilized to its maximum potential, not reduced to a point where CED nonprofit organizations are left vulnerable to the whims of a chaotic federal administration.

Industry leaders across all sectors should bolster workforce development opportunities in historically underrepresented communities along with strengthening public-private-nonprofit partnerships to further the reach of CED nonprofits’ work given the budgetary constraints many nonprofits are facing.

CED nonprofit organizations should still vigorously advocate at all governmental levels for continued funding in addition to the policy and advocacy efforts they are still able to take part in despite the new restrictions. Detailed below is some additional advocacy guidance that could help CED nonprofits make some positive gains in the hostile federal environment:

Cultivate unlikely partnerships

This current political climate calls for the creation of alliances with historically unlikely allies, including previously adversarial entities who also share similar pain points with where things are going in this country at a federal level. Superficial disagreements and coalition rifts are a dangerous distraction from the arduous road ahead, and mending them is of the utmost importance.

Focus on state & local advocacy efforts

Honing in on possible legal and legislative wins at the state, county and municipal levels will be necessary to continue the momentum for CED nonprofits during such difficult times. Placing additional emphasis on community organizing efforts across socioeconomic and political lines could help bolster the reach of state and local advocacy efforts, given the far-reaching impacts of these EOs across communities.

Strengthen narrative strategies

Actors in this space need to form a cross-sector and multi-stakeholder narrative strategy to undergird their ongoing advocacy efforts. There are copious amounts of disinformation about community and economic development in the public sphere, which must be combatted collaboratively. Alignment on a coalition-wide policy and advocacy communications strategy with clear, actionable and nuanced approaches to audience outreach is paramount as well.

Conclusion

The executive orders being wielded against organizational agents of societal change in the most destructive ways could have long-lasting impacts on the economic stability of communities across this country. The coordinated chaos is damaging organizations of all sizes and across a wide array of programmatic focus areas. As one survey respondent poignantly stated, “We are not all the same, but we each hold a vital place in the larger system—like bearings in a wheel. If one is missing or forced out of alignment, the entire mechanism begins to fail. And right now, our country is struggling under the weight of that imbalance.”

Given this, it will require a more bold and strategic response unlike anything the CED nonprofit sector and its stakeholders have ever been asked to undertake before. It is not the time for muted, purely pragmatic approaches to a system that no longer values those previously shared moral and ethical underpinnings of governance.

The literal lives and livelihoods of entire communities in this country are at stake. We must act with urgency and resilience to form a true buffer against the relentless federal attacks on justice, equity, freedom and economic mobility. We must all send a very clear message that CED nonprofit organizations attempting to provide communities with the tools and resources to realize their full potential and lead fulfilling lives should be commended and supported, not punished and disempowered.

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Funding Futures: Scale Link’s New Secondary Market for CDFI Loans is Strengthening Underserved Small Businesses https://ncrc.org/funding-futures-scale-links-new-secondary-market-for-cdfi-loans-is-strengthening-underserved-small-businesses/?utm_source=rss&utm_medium=rss&utm_campaign=funding-futures-scale-links-new-secondary-market-for-cdfi-loans-is-strengthening-underserved-small-businesses Mon, 01 Dec 2025 15:00:52 +0000 https://ncrc.org/?p=271001 Locally-owned small businesses are almost universally admired. Yet, in a banking industry where bigger is seen as better, warm words rarely translate into hard cash.

Small businesses have become a viable pathway towards economic mobility for entrepreneurs and the cornerstone of community development revitalization efforts in historically underinvested communities. However, minority-owned businesses have had to overcome multiple barriers when it comes to securing the necessary capital to establish and scale their businesses.

“These businesses tend to be in formerly redlined areas where traditional banking and lending institutions don’t have many branches, making traditional loan products and services inaccessible,” said Manan Shah, policy advisor at NCRC. “Accessing low-interest, flexible capital to launch and sustain their businesses over a longer period has been a huge challenge.”

Given that the vast majority of these businesses often seek out smaller loan amounts (less than $100,000), traditional banking institutions tend to see little reward from the increased financial risk attached to them. Community financial development institutions (CDFIs) are often the only option for BIPOC and women-run small businesses to obtain this much-needed financing – although CDFIs have their own funding limitations as well.

“CDFIs operate like small businesses themselves so they encounter similar capacity issues that their clients are dealing with,” said Shah. “With recent political attacks on the CDFI ecosystem, like the mass layoffs at the Treasury’s CDFI Fund, existing capacity issues will get worse.”

To help capacity-constrained CDFI capital move faster and smoother, Scale Link created a secondary market business model where they purchase small-dollar loans from CDFIs, bundle the micro-loans to make them more convenient for banks to buy and then route that revenue back to the CDFIs. Scale Link’s system also generates additional donated funds from the banks that further supports the overall funding stream given to small business CDFI borrowers.

This model allows historically underserved CDFIs to receive the funding they need to support small businesses while allowing banks to meet their Community Reinvestment Act (CRA) requirements towards serving all communities more equitably.   

“One thing that was important to us in the creation of Scale Link was ensuring that our success was based on our ability to deliver value to our partners,” said Jonathan Brereton, CEO of Scale Link (which is itself a CDFI). “We raised money to launch and… for new projects along the way, but we were very intentional about not raising ongoing operating subsid[ies]. We did not want to compete with our CDFI partners for scarce resources.”

The key component of the success of Scale Link’s small-dollar CDFI loan origination program has been their intentionality around meeting a real gap in loan servicing, creating a solution that met the needs of all stakeholders and incorporating their feedback at every step of the creation and implementation process. 

“At the end of the day though, it is a question of talking to the users of the product, designing with them in mind and then keeping that dialogue open,” said Brereton. “If we are insistent on creating products that must pay for themselves, the greatest indicator is going to be if people continue to pay for it.”

Scale Link, alongside its cross-sector partners, have found a sustainable and innovative way to build economic security for communities, addressed a business challenge for CDFIs and established an avenue for traditional banking institutions to engage in more equitable lending practices. Effective collaboration between banks, CDFIs and financially underserved communities has long been critical to closing the nation’s widening wealth gaps. But it’s especially urgent now, as federal cuts undermine CDFIs and small business development programs.

Timantha Goff is the Managing Editor for NCRC’s Communications team.

Photo caption: Eric Chung of Scale Link beneficiary 3-3-3 Food Truck (photo courtesy of Brenton Gieser of Opportunity Fund).

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Reclaiming Tribal Lands Through Innovative Economic Development Efforts https://ncrc.org/reclaiming-tribal-lands-through-innovative-economic-development-efforts/?utm_source=rss&utm_medium=rss&utm_campaign=reclaiming-tribal-lands-through-innovative-economic-development-efforts Tue, 10 Jun 2025 13:32:33 +0000 https://ncrc.org/?p=256310 The lack of affordable housing and other structural barriers to homeownership are a nationwide problem. Yet, for Native communities living on tribal lands, those dynamics become an even more complicated challenge to overcome. They are often overlooked by traditional state, local, regional and federal housing assistance programs and minimized as constituents given their unique sovereign legal status.

While there are several federal laws aimed at increasing financial equity for Native communities, the lack of trust Native communities understandably have about the federal government’s troubling history with tribes leads to skepticism and underutilization of federally-sponsored housing programs. 

“Due to the unique land status of tribal reservations and trust lands, financing options for home purchases are severely limited. This situation is exacerbated by the absence of tribal lending laws, including lending codes, land use ordinances, building codes and a court system capable of effectively adjudicating these laws,” said Matthew Lewis, the executive director of Four Directions Development Corporation in Maine. “Tribal nations that have implemented such laws face additional challenges due to their complex trust relationships with federal agencies. Only after addressing these challenges can a homeownership process that resembles traditional norms begin.” 

The multiple financial barriers Native communities face make it hard to participate in one of the major generators of economic stability in this country: homeownership. A number of Native community development financial institutions (CFDIs) are working to bridge the financial divide between tribal communities, private sector home financing providers and public sector governmental agencies.

“Native business owners and Tribal nations experience a whole spectrum of barriers when it comes to accessing banking services and financial tools,” said Casey Pearlman, executive director of the Affiliated Tribes of Northwest Indians Economic Development Corporation. “Materially, Tribes can be geographically far from banking services with some of the Tribes that my organization serves reporting a one-hour drive from even the nearest ATM.” 

Private lenders are effectively leaving aspiring homeowners living on tribal lands with no option other than mobile homes (labeled “manufactured housing” in official data), a depreciating form of housing with much higher interest rates. “Zero of the three largest mortgage lenders in the country participate in the Department of Housing and Urban Development’s (HUD) Section 184 program of absolute loan guarantees on mortgages made in tribal areas,” NCRC reported in the 2023 study Redlining the Reservation: The Brutal Cost of Financial Services Inaccessibility in Native Communities, “[with] just 2,200 loans having been made under that program each year on average, across the entire nation.”     

Taking a more proactive approach to removing financial barriers for those hoping to achieve housing stability of tribal lands is an important next step. CDFIs, policymakers and banks looking to solve these problems must also be mindful of the unique legal requirements and stipulations around building housing on tribal lands. 

There are several ways that these barriers could be removed for aspiring homebuyers and current homeowners, according to Mac McNeil, executive director of NCRC’s Community Development Fund (NCRC CDF). “If we want to solve the capital access problems impairing local economic growth on tribal lands,” McNeil said, “we need to streamline the Bureau of Indian Affairs (BIA) lease and mortgage approval processes, support expanded use of Title Status Reports (TSRs), help tribes build capacity for land records management, promote leasehold mortgage models and lender familiarity with trust land lending.”

McNeil’s team at NCRC CDF works with hundreds of CDFIs across the country, bringing vital resources, organizational training and funding opportunities towards furthering their reach in underserved communities. NCRC’s CDF team recommends several tangible ways stakeholders can provide support to Native CDFIs:

  • Supporting Tribal CDFIs by investing in, or partnering with them, to leverage their localized trust and expertise in housing finance.
  • Promoting financial education by scaling culturally appropriate homebuyer education programs on credit, mortgages and land rights.
  • Align housing efforts with Indigenous stewardship values by incorporating green and sustainable housing standards into sustainable building practices and energy-efficient housing developments.
  • Funding housing and redevelopment planning by offering grants or technical support for predevelopment work (e.g., land surveys, environmental reviews, architectural plans).

It is crucial that economic justice advocates, policymakers at all levels, housing developers and mortgage lending institutions come together to produce new and sustainable solutions for providing more access to capital for home buying and affordable housing for Native communities on tribal lands. 

“At the end of the day, building the administrative and legal infrastructure and developing the relationships…. to support the work being done by Native CDFIs and other Native-led non-profits on the ground is what is needed,” said Dave Castillo, the executive director of Native Community Capital and a member of the NCRC Board. 

“There is no silver bullet,” Castillo said. “Just the hard work we all need to engage in and commit to.”

 

Timantha Goff is the Managing Editor for NCRC’s Communications team.

Photo courtesy of the Navajo Nation (NN)’s Office of the President of several Native CDFI practitioners meeting with NN President Dr. Buu Nygren.

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“Opportunity Zones” for Whom? Lack of Equitable Development Outcomes Highlights Need for Reforms to Key Program https://ncrc.org/opportunity-zones-for-whom-lack-of-equitable-development-outcomes-highlights-need-for-reforms-to-key-program/?utm_source=rss&utm_medium=rss&utm_campaign=opportunity-zones-for-whom-lack-of-equitable-development-outcomes-highlights-need-for-reforms-to-key-program Thu, 22 May 2025 18:10:00 +0000 https://ncrc.org/?p=254076 In most American communities, one will see sleek, newly constructed luxury apartments, a variety of trendy eateries, carefully manicured shrubbery and the new well-to-do residents seemingly without a care in the world on one block. Then, one will see the bleak, dilapidated buildings, gaudy fast-food restaurants, tree-barren landscapes and the established residents that are struggling to meet their daily basic needs often mere blocks away. This is the disturbing reality that has sadly become the norm across most cities, towns and municipalities in this country.

The Opportunity Zones (OZs) that were created via the Tax Cuts and Jobs Act of 2017 with the intention of closing the economic gap between these communities are inadvertently accomplishing quite the opposite effect. Instead of capital flowing to the most economically disadvantaged neighborhoods, it has flowed to the most commercially viable of the OZs, further fueling the dynamic of gentrification. Instead of fostering economic opportunity for historically marginalized people, it is facilitating profit opportunities for developers, while economically distressed communities continue to suffer.

The proposed “skinny” federal budget would effectively gut federal financing for CDFIs, HUD housing programs and community development block grants in the new budget – in essence all the programs that support community development in the United States. Opportunity Zones could possibly become the biggest federal effort to improve investment in low- and moderate-income neighborhoods. This makes getting the Opportunity Zone 2.0 provisions right crucial for both urban and rural areas that are economically struggling.

The overarching goal of OZs was to provide additional financial incentives for private developers to produce more community economic development projects and initiatives in low- to moderate-income census tracts. The governors of each state were tasked with deciding which census tracts could be classified as an OZ area, determined via certain guidelines. 

“All low-to-moderate-income (LMI) census tracts were eligible for designation as an Opportunity Zone. Tracts are LMI if they have a median family income which is no more than 80% of the surrounding area’s median income. If the census tract had a poverty rate over 20% it would also qualify as eligible for this designation,” wrote Jason Richardson, senior director of research for NCRC, in a 2020 article.

The program has attracted $100 billion in investments over the past 5 years, but the impact in terms of improved lives has been questionable. Additionally, problems with the OZ program became clear after only a few years into its creation, with disparities in investment and growing rates of gentrification affecting the original (and primarily majority-minority) inhabitants in the majority of OZ and OZ-adjacent census tracts.

“Often, the people who lived [in these communities], overwhelmingly people of color, were not benefiting from the investment that flowed there,” as Richardson and his co-authors wrote in NCRC’s 2020 report Gentrification and Displacement. “As the Philadelphia Federal Reserve found, renters are more vulnerable to displacement as their communities gentrify, and unlike owners, they reap none of the rewards that rising home prices and rents can bestow.”

The individuals experiencing the largest financial gains from these development projects are the private developers themselves. There is also substantial evidence that the majority of the projects private developers take part in in OZs more than likely would have taken place regardless, with the tax incentives only sweetening the proverbial pot.

As the National Bureau of Economic Research’s 2024 book The Economics of Place-Based Policies outlined, “The structure of the OZ incentive particularly lends itself to developing real estate projects in growing areas. With a real estate project, much of the taxable return to the investor comes in the form of capital gains, as depreciation and interest deductions usually offset much of the annual rental income and the underlying asset is long-lived and will often generate a capital gain when sold. The larger the capital gain, the larger the after-tax benefit for an OZ investor.”

While some proponents argue that the tax provisions of the OZ program are revenue-neutral echoing the disputed claim that income tax cuts for the rich inevitably pay for themselves, historical evidence suggests otherwise. In practice, the OZ program offers substantial tax benefits to investors by shielding their capital gains, effectively allowing those gains to be deferred, reduced, or, in some cases, eliminated entirely. 

These benefits for the wealthy are conferred with minimal measured benefit to the residents of low- to moderate-income communities which the OZ program was intended to target. The price paid in lower tax revenues directly contributes to an increased federal budget deficit. To date, the OZs have merely been another mechanism for the upward redistribution of wealth.

The most glaring finding in recent studies on OZs is that the economic development within the zones is primarily concentrated in areas that are already experiencing a substantial economic upturn. Instead of capital being routed into places that are struggling economically, the money is flowing to OZ areas experiencing major increases in population from those with correspondingly high income and education levels to afford to live there. 

Secondly, the current residents in OZ and OZ-adjacent census tracts are still not seeing any economic development even if they are able to brave the rising property taxes and rents brought by the development happening in nearby OZ tracts. Many are effectively priced out of their communities altogether. 

“When ranking census tracts by how much all-in commercial or multifamily housing investment they get, all zones except the very top see very low OZ investment levels, while roughly 75 percent of OZ investment goes into zones with the top 20 percent of commercial investment,” wrote Brady Meixell and Brett Theodos in a recent Urban Institute article on the needed reforms for OZs. “Further, more OZ investment went to zones in counties with higher incomes and educational attainment—areas with higher potential for appreciation (which drives greater tax benefits under the program). Rural areas pose a special challenge for the program. Of all Opportunity Zone investment, 93 percent went toward metropolitan areas.”

Contrary to the program’s stated intent, OZs are currently functioning as a handout to rich people rather than a hand up for struggling Americans. Luckily, Congress and the White House can fix that with a few key changes to the current OZ program.

NCRC recently sent a letter to the House of Representatives’ Ways and Means Committee and Senate’s Committee on Banking expressing concerns about the lack of meaningful economic development occurring in economically distressed communities via Opportunity Zones. The letter proposed several possible reform strategies to better harness the potential of OZ programs:

  • Tie investment benefits to affordability and community impact: Create a tiered structure offering enhanced tax benefits for projects that include affordable housing units with greater benefits for deeper affordability levels. Enhance OZ zone benefits for affordable housing by offering stronger incentives for projects serving households earning below 100% of the Area Median Income (AMI) level.
  • Lower improvement thresholds: Reduce barriers for rehabilitation of existing affordable housing units by adjusting substantial improvement requirements for projects with long-term affordability commitments.
  • Improve targeting to communities with greatest need: Implement a fresh designation process based on current economic data to ensure zones represent truly disadvantaged communities rather than those already experiencing investment.
  • Mandate meaningful reporting and accountability: Require detailed reporting on investment types, amounts and measurable community impacts. In addition, develop a standardized framework for evaluating investments based on benefits to existing residents, including affordable housing creation, job opportunities and small business development.
  • Help people stay in their homes: Require assessment of gentrification risk and the implementation of displacement mitigation strategies for investments in areas with rapidly changing demographics.
  • Align efforts with other community development tools: Position OZ zones to address market segments and geographies that other programs, such as the Low-Income Housing Tax Credit (LIHTC) and New Market Tax Credits (NMTC) programs, do not effectively reach. In addition, create pathways for community development financial institutions to better utilize OZ incentives. 

True community-centered economic development via the Opportunity Zones pathway should be substantially less focused on the profit motive solely and more focused on the community benefit holistically. Key stakeholders across the equitable community economic development ecosystem have a role to play in ensuring that OZs don’t continue to perpetuate the same economic inequities that they originally set out to remedy.

“If Opportunity Zones are to become the focus of community development,” said Bruce Mitchell, principal researcher for NCRC, “then we need to make sure that they are truly serving that purpose and are not just an investment vehicle for the wealthiest Americans.”

 

Timantha Goff is the Managing Editor for NCRC’s Communications team.

Photo credit: Brett Sayles via Pexels.

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Women Who Lead: The Heart and Strength of NCRC https://ncrc.org/women-who-lead-the-heart-and-strength-of-ncrc/?utm_source=rss&utm_medium=rss&utm_campaign=women-who-lead-the-heart-and-strength-of-ncrc Thu, 20 Mar 2025 16:55:32 +0000 https://ncrc.org/?p=246339 At NCRC, we take immense pride in the incredible women who make our workplace stronger, smarter and more inspiring every day. Their intelligence, dedication and passion fuel our mission and shape the foundation of who we are. Having them as part of our team is both a privilege and a blessing.

In addition to their hard work and commitment to economic justice for all, each of these women have personal goals and have accomplished achievements that mean the world to us.

Women can do it all and, at NCRC, we bear witness to that truth every day. Their resilience, ambition and unwavering drive are a testament to the power of women in the workplace and beyond. Today and always, we celebrate them.

Being a woman in America right now feels exhausting, but I’m proud of being able to work for an organization that is dedicated to a just economy. I’m proud of all the women in the world who are holding their ground and carving out a path for themselves and I look forward to a brighter future where justice and equality prevail.

— Elisabeth Butler

What makes me proud and happy as a woman is the confidence to lead and the courage to do it my way. In a world that often tries to put women in a box, I’ve built a career—and a life—by breaking barriers, trusting my instincts and leading with both strength and humor. I believe leadership isn’t just about making decisions: it’s about making connections, lifting others up and never being afraid to laugh along the way. Success is serious, but who says we can’t have fun getting there?

— Carolina Rodrigues

As the popular saying goes, ‘Behind every great woman is another great woman.’ I celebrate all the women who have invested in me, helping me become a powerful, gentle, brilliant and joyful woman. I can’t help but feel incredibly proud of all the strong and kind women in this world.

—Haley Schneider

‘A strong woman knows she has strength enough for the journey, but a woman of strength knows it is in the journey where she becomes strong.’ My greatest mentor and teacher in life is a woman—my mom. As a single mom she worked tirelessly to provide for me and my five siblings, often putting her own needs aside to ensure we had every opportunity to succeed. In May 2024, my mom was diagnosed with cancer. I watch her struggle to continue to navigate her diagnosis with strength and resilience—yet, becoming stronger every day. Now, as I reflect on my understanding of female joy and happiness, it is deeply rooted in the power that comes from a woman’s ability to overcome pain, hardships and injustice. It is in the way we find beauty despite the world wrongfully dictating what our beauty should be. During these difficult times for immigrants and women in America, I hope we find joy and happiness in the understanding that us, as women of strength, are made for this journey. We run this.

— Rose Ramirez

I work in economic justice because everyone deserves the dignity of a living wage and helping their family thrive. I’m grateful to be in a position to fight for a future where people who share my experiences can achieve both.

— Sabrina Terry

I am proud and happy that I can create space for others to be their full, authentic selves and let their strengths shine. As a transgender woman, this feels especially important in a time when women, queer people, immigrants, BIPOC people and so many others are under attack.

— Chloe Sabharwal

During these turbulent times in American history, I’m proud I work for an organization that believes everyone, regardless of their identifiers, has the right to financial services, a safe and affordable home, a thriving and healthy community and a country that not only promises but delivers to all Americans opportunities to build wealth and live well.

— Alyssa Wiltse

I am thankful to be a mother and to work in this space where my efforts—along with those of others—help bridge the racial wealth gap.

— Daniella Djiogan

I’m proud to have a powerful lineage of Black women here in the physical and in the spiritual realm whose work and legacies that continue to provide ample wisdom and guidance as I navigate my own journey.

— Timantha Goff

I take pride in providing guidance to the participants of our Marketing and Development internship program at NCRC. I’m also proud to be a woman achieving my goals despite life’s challenges. Additionally, I am proud to be the first in my family to earn a degree, travel the world and allow myself to achieve even more. Most importantly, I am proud to be myself—embracing my journey, my growth and everything that makes me who I am.

— Alejandra Pringle

I’m thrilled to be part of NCRC, where we support our members and work directly with people affected by housing and lending discrimination. As a woman in this field, it’s so fulfilling to channel my skills and background into advocating for economic justice. It is very rewarding to know that my work contributes to NCRC’s broader mission of creating pathways to wealth-building for all communities, regardless of race, gender or economic background.

— Victoria Haush

As a woman, I’m proud of the work that I can do to make the world better in a small way — through fair housing and other economic justice-related issues — and I hope I can inspire future generations of women to do the same.

— Nichole Nelson

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Timantha Goff https://ncrc.org/member/timantha-goff/?utm_source=rss&utm_medium=rss&utm_campaign=timantha-goff Mon, 18 Nov 2024 14:58:31 +0000 https://ncrc.org/?post_type=ex_team&p=239025 Timantha Goff (she/her) is NCRC’s Managing Editor and Writer. She was previously the Portfolio Director for the University of Chicago Crime Lab where, in addition to providing project and operations management support for a variety of programs, she assisted the Public Affairs team with producing communications materials on behalf of several programming and research initiatives. Before this, she was the Policy and Advocacy Analyst for the UndocuBlack Network where she was involved in federal legislative advocacy and policy analysis reporting work on behalf of Black immigrant communities. Lastly, she has been heavily involved in community-centered journalism and writing by way of her former online publication, the (New) Tulsa Star. She holds a bachelor’s degree in English literature and a Master of Public Administration degree with a focus in public policy from the University of Oklahoma.

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