Search Results for “jason richardson” – NCRC https://ncrc.org National Community Reinvestment Coalition Fri, 14 Aug 2026 18:22:10 +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 “jason richardson” – NCRC https://ncrc.org 32 32 NCRC’s Comment on the FFIEC’s Proposed Revisions to the CAMELS Rating System https://ncrc.org/ncrcs-comment-on-the-ffiecs-proposed-revisions-to-the-camels-rating-system/?utm_source=rss&utm_medium=rss&utm_campaign=ncrcs-comment-on-the-ffiecs-proposed-revisions-to-the-camels-rating-system Fri, 14 Aug 2026 18:20:07 +0000 https://ncrc.org/?p=291485

August 14, 2026

Federal Financial Institutions Examination Council (FFIEC)
l. William Seidman Center
3501 Fairfax Drive
Arlington, VA 22226-3550

Attn: Executive Secretary
Submitted through Regulations.gov

RE: FFIEC Docket ID OCC-2026-0562 Proposed revisions to the Uniform Financial Institutions Rating System (UFIRS), commonly referred to as the CAMELS rating system

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the FFIEC’s proposed revisions to UFIRS, commonly referred to as the CAMELS rating system.[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.

The CAMELS ratings system contains ratings from 1 to 5 that indicate the management competency and safety and soundness of banks. The FFIEC is proposing to de-emphasize the management factor in favor of more quantifiable financial risks. While the more quantifiable factors possess the alure of greater objectivity, a de-emphasis on management factors will ultimately pose more risk to the banking system. If the proposal is adopted, banks may appear to be stellar to examiners if they observe sound capital reserves, asset quality, earnings, and liquidity. When examiners perform cursory exams of management practices, they are less likely to notice reckless and careless practices. If unchecked, these practices over time will erode capital, asset quality, earnings, and liquidity.

Moreover, the revised system is less likely to capture and reflect poor compliance with the Community Reinvestment Act (CRA), consumer protection, and fair lending laws and regulations in CAMELS ratings. Poor compliance with reinvestment obligations and consumer protection statutes reflects an unwillingness to serve all communities, particularly low- and moderate-income (LMI) communities, consistent with safety and soundness. A bank is not well managed if it is not adequately serving a sizable part of its community. A bank is not well managed if it is not abiding by consumer protection laws and is charging consumers excessive and deceptive fees.

Ultimately, if a bank offers its products in a deceptive or unfair way, it can be costly because of the potential of increases in loan delinquencies and defaults. The 2008 financial crisis illustrated clearly how poorly managed independent mortgage companies and some investment banks ignored risks and overexposed themselves and consumers with unaffordable loans that ended up in delinquency and default.[2] Better oversight of mainstream banks through safety and soundness exams partly prevented most banks from making these harmful loans that injured consumers, communities and the global economy. Poor compliance with consumer protection and fair lending laws will impact banks’ safety and soundness and must be reflected in CAMELS ratings in order to prevent wider harm to the economy.

De-emphasizing management competency is not fair to banks that are complying with their legal requirements or are exhibiting exemplary responsiveness to community needs. All else equal, a bank exhibiting poor compliance with reinvestment and consumer protection requirements should not receive the same CAMELS rating as one doing well meeting these requirements. The good or excellent performers will lose incentives to maintain their performance. The result will be less sustainable and affordable lending in communities.

Proposed Diminishment of the Management Factor Will Encourage the Rise of Riskier Banks as Illustrated by the Case of USAA Federal Savings Bank

The FFIEC’s proposal to remove “responsiveness to recommendations from auditors and supervisory authorities” and “demonstrated willingness to serve the legitimate banking needs of the community” from the criteria used to evaluate the management of banks will have negative consequences for all stakeholders: banks, regulators, and borrowers.[3] The FFIEC’s stated reasoning for removing these factors is to “focus on the most material aspects of risk management.”[4]

The proposed rule states that, “[a]n observation from industry is that the Management rating has been overweighted relative to other CAMELS components in determining the composite rating. The supervisory agencies’ analysis suggested that the Management component has been the most influential factor in determining composite ratings, particularly in recent years.”[5]

This statement hints that such an emphasis on management competency is not healthy and might pose regulatory constraints on banks’ lending and business activity. However, it is not supported by any evidence that banks scoring poorly on the management factor nevertheless score well on the other components such as asset quality or liquidity. Nor is the statement supported by discussion of any relationship between the CAMELS components and loan-to-deposit ratios or any other indicators of lending levels. Nor does the FFIEC refute that there is an intuitive relationship between bank management competency and the level of material risk.

The recent history of USAA Federal Savings Bank (USAA) shows how deprioritizing compliance can lead to significant financial risks. USAA had the dubious distinction of failing two consecutive CRA exams administered by the Office of the Comptroller of the Currency (OCC) with Needs-to-Improve ratings. Its March 2019 exam found USAA exhibited poor performance on the lending test, the most highly weighted component test of a CRA exam. It had a Low Satisfactory rating on the lending test, which is just a notch above the failing rating of Needs-to-Improve. The poor rating was driven by a poor distribution of consumer loans by geography (relatively few loans in (LMI census tracts) and merely adequate distribution of loans to LMI borrowers.[6] The OCC lowered the overall rating on USAA’s exam to Needs-to-Improve due to 546 violations of the Servicemembers Civil Relief Act including “wrongful repossessions of vehicles, and the filing of inaccurate affidavits in default judgment cases.”[7]

After USAA’s next exam in 2022, the OCC again lowered the bank’s rating from Satisfactory to Needs-to-Improve because of law violations that were more widespread than those reported in the 2019 exam. This time, the OCC identified 6,477 violations of the Federal Trade Commission Act’s prohibition against unfair and deceptive acts or practices, including failures to provide promised interest rate discounts on automobile loans.[8] USAA subsequently settled a class action in 2024 totaling $64 million for its failure to adhere to consumer protection laws.[9]

USAA’s compliance failures were not limited to consumer protection law. In 2024, after the 2022 failed CRA exam, the OCC filed a consent order against USAA for deficiencies in their compliance management regarding IT issues and money laundering prevention. Previous regulatory settlements did not prevent the 2024 malfeasance; USAA also entered into regulatory settlements in 2022 and 2019.[10]

USAA management failures were systemic and widespread. Former USAA CEO Wayne Peacock has acknowledged that USAA did “not sufficiently invest in the capabilities and expertise necessary to meet regulatory requirements.” His assessment was amplified by a senior official of the Treasury Department, Himamauli Das, the acting director of the Treasury Department’s Financial Crimes Enforcement Network. Das stated, “As its customer base and revenue grew in recent years, USAA…willfully failed to ensure that its compliance program kept pace, resulting in millions of dollars in suspicious transactions flowing through the U.S. financial system without appropriate reporting.” He continued that the bank received “ample notice and opportunity to remediate” its issues but failed to do so.[11]

USAA as of the summer of 2026 is the 31st largest bank in the United States with assets of more than $109 billion according to the FDIC.[12] A bank of this size, if its poor management practices remain uncorrected, poses a risk to the wider community in addition to itself and its customers.  USAA failed two consecutive CRA exams, entered multiple consent orders, and settled a lawsuit. It caused significant consumer and community harm and failed to adequately protect against money laundering, potentially creating systemic risk in large part because of management’s failure to make sufficient investments in compliance.

The record demonstrates abject management failures in the case of USAA. If the agencies weaken the weight and depth of their management review in the CAMELS rating system, it risks encouraging more banks to relax its management practices, posing risks to themselves, consumers, and the economy.

Rigorous Management Reviews and CAMELS Unlikely to Lead to Less Lending as the CRA Experience Indicates

The proposed rule asserts that rigorous enforcement of regulatory requirements can lead to lower lending levels. It states that, “[r]esearch suggests that CAMELS ratings significantly affect lending behavior and bank performance, after attempting to control for some other factors, with downgraded banks exhibiting substantially lower loan growth.”[13] The assertion, however, is hedged and not definitive since it states that the research “attempted to control for some other factors.” Were the lower lending levels due to low CAMELS ratings or poor management and other factors that resulted in examiners giving low CAMELS ratings? It is likely that poor management, including inadequate marketing, loan underwriting, and monitoring loan performance, drove the lower lending levels.

The FFIEC cites a paper containing dated econometric analysis conducted a decade ago that does not make a convincing case that lower levels of lending for poorly rated banks are necessarily harmful. A question emerges about the independent variables that the analysis employs. The paper uses mostly internal bank health indicators such as liquidity levels and asset quality. It has some external economic controls including the housing price index, wage growth, unemployment rates, and credit card delinquency on a county level. But it neglects to consider housing cost burdens which could be a significant factor on borrowers’ abilities to acquire home loans or other types of loans.[14]

The other policy and management issue not considered by the paper is that banks with lower safety and soundness ratings should proceed cautiously with their lending activity until they make improvements in their management and fiscal condition. The FFIEC conducts safety and soundness exams once every twelve or eighteen months. This time period is reasonable, not unduly long, and adequate for banks to improve their soundness before resuming robust lending.

Rather than constrain lending, regulatory requirements may motivate banks to increase their lending to LMI borrowers. Using a Federal Reserve database of CRA exams from 2005 through 2017, NCRC found that banks rated Outstanding on the Lending Test made a median of 12 percent of their home loans to LMI borrowers. Those rated Needs-to-Improve made a median of 2 percent to LMI borrowers. Banks scoring High and Low Satisfactory on the Lending Test likewise made a much higher percentage of loans to LMI borrowers than the banks rated Needs-to-Improve. The great majority of banks (about 98 percent) pass their CRA exams and similar percentages pass the lending test of CRA exams. Only about 5 percent of the banks (420 out of 7,377 in the Federal Reserve longitudinal sample) received a Needs-to-Improve on the lending test of CRA exams.[15]

This analysis begs the question: Did the lower CRA ratings cause a decline in lending? Or was it overall management difficulties that caused the low percentage of lending to LMI borrowers and failed ratings on the lending test? Since the great majority of banks passed their lending test, it is unlikely that overly rigorous CRA exams caused declining percentages of lending to LMI borrowers. It is more likely that the ratings accurately captured the minority of banks that had more difficulties managing their lending overall and/or lending to LMI borrowers. Also, it is likely that CRA motivated most banks to make efforts to lend to LMI borrowers and increase their percentages of loans to LMI borrowers.

Banks with failed CRA ratings do not necessarily have low levels of lending. Instead, there are cases in which banks are failing to serve LMI borrowers and census tracts. Small bank CRA exam findings can illuminate issues with lending levels and distribution because examiners rate small banks almost entirely based on retail lending performance. For example, Merchants and Manufacturers Bank, a small bank located in Joliet, Illinois failed its 2020 CRA exam not because of a low level of lending as reflected in a low loan-to-deposit ratio. Instead, it failed its exam because it issued a low percentage of loans in LMI census tracts and to LMI borrowers.[16]

In another case involving a small bank, American Community Bank of Indiana failed its CRA exam in 2022 due not to a low loan-to-deposit ratio but because of low percentages of loans to LMI borrowers and census tracts.[17] On its 2024 exam, it maintained a reasonable loan-to-deposit ratio and increased its percentage of loans to LMI borrowers and census tracts.[18]

Diminishing the Management Factor Breaks with Decades of CAMELS Development and Would Not Constrain Increased Risk to the Financial System

When the agencies were updating the CAMELS rating system in July 1996, they observed that risk had increased in the financial industry and that the management factor needed to be elevated in importance. The agencies stated:

Changes in the financial services industry, however, have broadened the range of financial products offered by institutions and accelerated the pace of transactions. These trends reinforce the importance of institutions having sound risk management processes. Accordingly, the revised rating system would contain language in each of the components emphasizing the consideration of processes of identify, measure, monitor, and control risks.[19]

In December 1996, when the FFIEC finalized its proposed changes, it noted that:

The ability of management to respond to changing circumstances and to address the risks that may arise from changing business conditions, or the initiation of new activities or products, is an important factor in evaluating a financial institution’s overall risk profile and the level of supervisory attention warranted. For this reason, the management component is given special consideration when assigning a composite rating.[20]

The spate of bank failures in the spring of 2023, the rapid pace of change, and the emergence of potential systemic risks related to the opening of the banking system to new entrants, such as stablecoin issuers, and new activities suggest that federal bank agencies must proceed cautiously in changing their bank management expectations. The FFIEC recognized the importance of examining management in 1996 due to significant and rapid changes in the financial industry. The same caution is warranted today.

For example, in a span of a few weeks during 2023, three bank failures, Silicon Valley Bank, Signature Bank, and First Republic Bank, were among the largest bank failures in United States history and shocked confidence in the banking sector.[21] These banks were poorly managed, experienced rapid increases in assets and customers, accumulated large dollar amounts of uninsured deposits, and financed start-ups and other risky endeavors without prudent controls. In another case of a bank failing in 2023 due to excessive risk taking, Silvergate was a major enabler of cryptocurrency and had established an exchange and payments system fueling the growth of cryptocurrency.[22]

The relatively recent spate of bank failures is not the only consideration suggesting caution is necessary. Overall economic conditions, including increases in job layoffs, sluggish wage growth and persistent inflation, should motivate regulatory agencies to increase their oversight of management operations and practice.[23] As the economy stagnates, newspaper accounts indicate an increased exposure to fraudulent activity. Banks have taken losses after financing non-bank automobile lenders serving customers with subprime credit. Other banks have suffered fraud from commercial real estate firms.[24]

Because of economic conditions and the increase of risky bank practices, NCRC agrees with the sentiments of David L. Herndon, Bank Commissioner with Office of the State Bank Commissioner of Kansas:

I respectfully request that the FFIEC reconsider its deemphasis on the management qualitative factors. Strong board oversight, proper controls, and qualified key management is the best source of strength for a bank to weather weak economic conditions and to recover from an unsafe and unsound condition.

I strongly believe it (the management factor) is the most important factor of the CAMELS rating to ensure the safety and soundness of a bank and should continue to be heavily emphasized in safety and soundness examinations. I specifically disagree with removing the review of management succession, the willingness of the board to address monitor auditor or examiner recommendations and not discussing specialty reviews while reviewing management.[25]

Banks of all sizes, whether complex international and national banks or smaller rural based banks, need robust oversight of their management practices and policies. The proposal’s removal of language directing examiners to devote special consideration of the management factor will deemphasize management competence and capability at precisely the wrong time given all the new entrants to the banking system engaging in newly regulated activities during uncertain economic times.

Conclusion

The FFIEC’s proposed rule is based on faulty premises related to supposed negative consequences of rigorous reviews of management practices. The proposal upends decades of safety and soundness test methodology and practice. The quality of management critically impacts whether banks serve community needs in a non-discriminatory and safe and sound manner.  More rigor, not less, in these reviews are needed.

Thank you for considering our views on this important matter. If you have any questions, please contact Josh Silver, Senior Fellow and author of this letter at endredline77@gmail.com or me at jvantol@ncrc.org.

Sincerely,

Jesse Van Tol
President and CEO
National Community Reinvestment Coalition

 

[1] 91 Fed. Reg. 29128 (proposed May 19, 2026).
[2] National Commission on the Causes of the Financial and Economic Crisis in the United Sates, The Financial Crisis Inquiry Report: Final Report of the National Commission on the Causes of the Financial and Economic Crisis in the United States (New York: Public Affairs, 2011), xvii-xxiv, 7, 70, 75, 79.
[3] Federal Financial Institutions Examination Council, Uniform Financial Institutions Rating System, Notice and Request for Comment, Federal Register, Vol. 91, No. 96, Tuesday, May 19, 2026, pg. 29130. https://www.govinfo.gov/content/pkg/FR-2026-05-19/pdf/2026-09944.pdf
[4] Ibid.
[5] Ibid.
[6] OCC CRA performance evaluation of USAA Federal Savings Bank, March 18, 2019, pp. 7-8, https://occ.gov/static/cra/craeval/Sep20/707975.pdf
[7] CRA evaluation, 2019, p. 5
[8] OCC CRA performance evaluation of USA Federal Savings Bank, March 21, 2022, p. 6, https://occ.gov/static/cra/craeval/Oct22/707975.pdf
[9] Polo Rocha, USAA agrees to $64M settlement in class action overcharging case, American Banker, August 06, 2024, https://www.americanbanker.com/news/usaa-agrees-to-64m-settlement-in-class-action-overcharging-case
[10] OCC Issues Comprehensive Cease and Desist Order Against USAA Federal Savings Bank, News Release 2024-137, December 18, 2024, https://www.occ.gov/news-issuances/news-releases/2024/nr-occ-2024-137.html
[11] Polo Rocha and Sanford Nowlin, Fundamental breakdown: How USAA landed in regulators’ hot seat, American Banker, November 21, 2024, https://www.americanbanker.com/news/fundamental-breakdown-how-usaa-landed-in-regulators-hot-seat
[12] FDIC, BankFind Suite, https://banks.data.fdic.gov/bankfind-suite
[13] FFIEC, Proposed Rule, May 2026, p. 29133.
[14] Paul Kupiec, Yan Lee, and Claire Rosenfeld, Does Bank Supervision Impact Bank Loan Growth?, November 2016, https://www.aei.org/wp-content/uploads/2016/12/Kupiec-Does-bank-supervision-impact-bank-loan-growth.pdf, pp. 42-43
[15] Josh Silver and Jason Richardson, Do CRA Ratings Reflect Differences In Performance: An Examination Using Federal Reserve Data (Washington, D.C., NCRC, May 2020) https://ncrc.org/do-cra-ratings-reflect-differences-in-performance-an-examination-using-federal-reserve-data/
[16] FDIC CRA Performance Evaluation of Merchants and Manufacturers Bank, January 2020, https://crapes.fdic.gov/publish/2020/20040_200127.PDF
[17] FDIC, CRA Performance Evaluation of American Community Bank of Indiana, June 10, 2022, https://crapes.fdic.gov/publish/2022/29878_220610.PDF
[18]FDIC, CRA Performance Evaluation of American Community Bank of Indiana, October 21, 2024,  https://crapes.fdic.gov/publish/2024/29878_241021.PDF
[19] Federal Financial Institutions Examination Council, Proposed Rule and Request for Comment, Uniform Financial Institutions Rating System, Federal Register, Vol. 61, No. 139, Thursday, July 18, 1996, https://www.govinfo.gov/content/pkg/FR-1996-07-18/pdf/FR-1996-07-18.pdf,  p. 37474
[20]  Federal Financial Institutions Examination Council, Uniform Financial Institutions Rating System Federal Register, Vol. 61, No. 245, Thursday, December 19, 1996, p. 67025, https://www.govinfo.gov/content/pkg/FR-1996-12-19/pdf/96-32174.pdf
[21] Mishkin, F. S., & White, E. N. (2024). The failure of Silicon Valley Bank and the panic of 2023. Journal of Economic Perspectives, 38(1), 133–152. American Economic Association.
[22] Kate Rooney and Evelyn Cheng, CNBC, Meet the small community lender that’s become the go-to banker of the cryptocurrency world, May 31, 2018, https://www.cnbc.com/2018/05/31/meet-silvergates-alan-lane-whos-bankrolling-cryptocurrency-exchanges.html and MacKenzie Sigalos, Crypto-focused bank Silvergate is shutting operations and liquidating after market meltdown, Mar 8 2023, CNBC, https://www.cnbc.com/2018/05/31/meet-silvergates-alan-lane-whos-bankrolling-cryptocurrency-exchanges.html
[23] Lauren Kaori Gurley, Hiring slumped unexpectedly in July, as the economy shed 23,000 jobs, August 7, 2026, Washington Post, https://www.washingtonpost.com/business/2026/08/07/economy-shed-23000-jobs-july-labor-market-weakened/
[24] Aaron Gregg, Rise of ‘shadow banking’ brings new financial risks, experts say, October 18, 2025, Washington Post, https://www.washingtonpost.com/business/2025/10/18/first-brands-tricolor-shadow-banking-risk/
[25] Comment of David Herndon, https://www.regulations.gov/comment/OCC-2026-0562-0025

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Bank branch trends for 2026 (2nd quarter): Continued growth in the Southeast and Southwest metros https://ncrc.org/bank-branch-trends-for-2026-2nd-quarter-continued-growth-in-the-southeast-and-southwest-metros/?utm_source=rss&utm_medium=rss&utm_campaign=bank-branch-trends-for-2026-2nd-quarter-continued-growth-in-the-southeast-and-southwest-metros Mon, 27 Jul 2026 14:00:05 +0000 https://ncrc.org/?p=290545 The nation’s bank branch network changed little compared with the first three months in the second quarter of 2026, with 261 openings and 248 closings. This is the third straight quarter of net gains in branches, something that we haven’t seen since 2009. It has been a long time since we could say bank branches were growing in this country. 17 years ago, the Great Recession ended seven years of continuous branch growth. 

However, it is undeniable that in some parts of the country banks see a reason to expand their physical presence. This runs contrary to the conventional wisdom that physical bank branches were no longer relevant to consumers. It appears that in high growth metros banks find that physical locations are critical to their plans.

Three of the country’s eight regions – including the Southeast, the Southwest and the Rocky Mountain states – are adding branches, while the other five – including the Mideast and Northeast – are losing branches, with the losses being concentrated in a handful of large metro areas.

Some areas of the country are seeing growth while others continue to see branch closures

Table 1 shows the net change in bank branches across the country’s eight regions since the second quarter of 2026. It highlights the outsized role the Southeast plays in the country’s return to branch growth.

Table 1: Net bank branch change by BEA region, Q2 2025 through Q2 2026.

The Southeast is the clear driver of the national total, with the Southwest and the Rocky Mountain states also seeing positive branch growth. On the other hand, the Mideast –  including New York, New Jersey and Pennsylvania together with Delaware, Maryland and Washington, DC –  is losing branches faster than any other region in the country. However, it is not that simple, with Sunbelt cities in certain states outperforming every place else.

Growth concentrates in a handful of Southeast and Southwest states

Table 2 shows bank branch trends in the Southeast and Southwest regions by state. It shows that branch expansion is not spread evenly across the region as Florida and Texas account for roughly half of the combined gain alone.

Table 2: Net branch change by state, Southeast and Southwest, Q2 2025 through Q2 2026.

Florida and Texas account for a large share of the combined growth across both regions, more than the next several gaining states put together. Georgia, the Carolinas, Alabama and Tennessee round out a cluster of Deep South and Gulf Coast states that added branches in every quarter. Virginia and West Virginia, both a part of the Southeast under this framework, saw essentially no branch growth. Outside of Texas, the rest of the Southwest experienced flat to slightly negative growth, with Arizona showing no change and New Mexico actually losing branches.

New York’s losses are a story about scale, not decline

Table 3 shows the ten metro areas with the largest net branch change over the same five quarters. It shows that both the gains and the losses are concentrated in a small number of metro areas rather than spread broadly across the country.

Table 3: Top gaining and losing metro areas, Q2 2025 through Q2 2026.

Dallas-Fort Worth, Atlanta, Miami, Charlotte, Austin and Nashville lead the metros that reported a net gain in branches, with more branches opening than closing. The New York metro’s branch network is by far the largest in the country, more than three times the size of Boston’s or Philadelphia’s. On a percentage basis, New York’s decline was actually smaller than Philadelphia’s or Detroit’s over the same window, and roughly in line with Boston’s. However, the concentration of losses in a handful of legacy Northeastern and Midwestern metro areas is the most notable pattern. 

Growth is happening for full-service branches, not in-store locations

Table 4 shows net branch changes by service type (full-service brick-and-mortar branches versus in-store/retail locations, such as those inside a supermarket or big-box store) and how they are split between the Southeast and Southwest regions compared to the rest of the country. It shows that growth, even in the fastest-growing markets, is happening via brick-and-mortar branches rather than in-store locations, the latter of which are shrinking everywhere.

Table 4: Net branch change by service type and region (Southeast and Southwest versus rest of country) for Q2 2025 through Q2 2026.

Even in high growth markets, in-store and retail branches are also shrinking in number. Nationally, only 19 new in-store or retail branches opened over the entire five-quarter window compared with 96 that closed, a pattern that held firm in every quarter regardless of whether the broader branch count was growing or shrinking. Full-service brick-and-mortar branches account for the overwhelming majority of new openings everywhere, suggesting the in-store banking format is being wound down as a category rather than relocated to high growth markets.

Banking trade press coverage points to a straightforward explanation: in-store branches were built to provide transactional convenience for customers who were already at the store for something else. Online and mobile banking have eliminated most of the reason for that kind of interaction since routine transactions no longer require showing up in person at all. When customers do still need to visit a branch, recent reporting on bank branch strategy suggests they prefer a full-service location better suited to private conversations about banking needs rather than a retail store built for foot traffic.

The regional split lines up with where money and higher earners are moving

For banks, their branch strategy is a business decision made for many reasons that this data cannot pinpoint, but the geography trends outlined in this article line up closely with outside migration research. Demographic analysis published by Brookings Institute has tracked domestic out-migration from large coastal metro areas, including New York, Los Angeles, San Francisco, Boston and Seattle, alongside sustained in-migration to Sun Belt metro areas, such as Dallas, Tampa and Raleigh, since the early part of the pandemic. The same research found that a lot of what looked like a population rebound in big metro areas in 2023 and 2024 was driven mainly by a rise in immigration from abroad rather than a reversal of domestic migration rates. The newest available analysis on this migration found that metro population growth is declining again as immigration slows.

IRS migration data, which tracks income rather than head counts, shows the steadier pattern of growth behind the population volatility. The most recent filing-year data available covering 2022 to 2023 shows Florida gaining more than $20 billion in net adjusted gross income from interstate migration and Texas gaining more than $5 billion, while California, New York, Illinois, Massachusetts and New Jersey experienced the largest net losses. This state-by-state pattern matches this article’s branch findings closely, with the same handful of states gaining income being the ones gaining bank branches. New York, despite an overall population that has recovered in recent years due to immigration, continues to lose more income to domestic migration than nearly any other state, which is consistent with its outsized share of branch closures.

A note on data revisions

The figures in this article reflect the FDIC’s BankFind Suite structural change data as of the article’s publication date. Banks sometimes file branch opening, closing and relocation records after the quarter has ended, with FDIC assigning these filings a processing date that can fall months after the effective date of the change. As a result, figures for a given quarter can shift in later reports as additional filings are processed. This article reflects the most current data available and updates the prior quarter’s figures accordingly. The five-quarter window shown here has been refreshed against the newest available data pull, which includes revisions to the third and fourth quarter of 2025 and the first quarter of 2026. Readers comparing figures across published analyses should accept small revisions to prior quarter counts as a part of normal data processing, not as corrections to the overall methodology.

 

Methodology note: Figures cover FDIC-insured institutions’ full-service branch locations (brick-and-mortar and staffed retail/drive-through) based on FDIC’s OSCR structural change filings for the quarter shown. Regional definitions follow the U.S. Bureau of Economic Analysis’s eight-region scheme rather than the Census Bureau’s four-region scheme.

 

 

Jason Richardson is the Senior Director of Research with NCRC’s Research team.

Photo credit: Monstera Production via Pexels.

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Video: The Data Behind the Lending Landscape – Why Engaging Regional Financial Institutions Matter https://ncrc.org/video-the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matter/?utm_source=rss&utm_medium=rss&utm_campaign=video-the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matter Sun, 26 Jul 2026 16:34:08 +0000 https://ncrc.org/?p=290562 Online Event Archive Recorded July 15, 2026

As federal budget cuts challenge affordable housing and community development efforts, this session explores how nonprofits can use data, partnerships and regional banks to move projects forward.

Featuring insights from NCRC’s Jason Richardson, author Oscar Perry Abello and Citizens Savings Bank & Trust’s Corey Hammonds, the discussion examines lending trends, community development finance and strategies for building stronger relationships with local financial institutions. Moderated by Monchiere’ Holmes-Jones of MOJO Marketing and the Jefferson Street Historical Society.

 

Speakers

Oscar Perry Abello, Journalist, Next City
Corey Hammonds, Chief Operation/Credit Officer, Citizens Savings Bank & Trust
Monchiere’ Holmes-Jones, Founder, MOJO Marketing and Founder & Board Chair, Jefferson Street Historical Society
Jason Richardson, Senior Director of Research, 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.

Holmes-Jones 00:00
Hi everyone. My name is Monchiere’ Holmes-Jones. I am the CEO and Chief Impact Officer here at Mojo Impact Collective and a member of NCRC. I’ll be your moderator today for this great webinar titled “The Data Behind the Lending Landscape: Why Engaging Regional Financial Institutions Matters.”

Before we proceed any further, I want to take the time to go through our NCRC’s Code of Conduct. So, we’ll get that on the screen for you all. A little housekeeping. Please note: We welcome people from any and all diverse backgrounds as possible. We respect our events and any interactions within our community to be respectful and harassment-free at all times. Regarding any AI chatbots, NCRC does not permit AI chatbots to record our webinar today or any of our webinars. So, please note: we will be fielding questions at the end of the three presentations. So, if you’re interested in asking questions, please note you have the Q and A box right there at the bottom of your Zoom screen. Click the box, type your question. When you do, please identify which speaker you like to answer your question. That’ll be helpful to guide us through, and then we’ll answer accordingly.

For those unfamiliar with NCRC, we’re a network of 700 plus organizations from across the country. We work with our members to close the racial and socio-economic wealth and opportunity divides. If you’re watching this webinar from Nashville, we will be convening a community development training [there] in late September. We’ll have more details at the end of this event, so stay tuned. The purpose of our webinar today is to help our folks understand that context and the data behind our current lending landscape, and we’ll use Nashville as a great case study.

We’ll hear first from Jason Richardson, director of NCRC’s research team. Richardson will provide an analysis of Nashville’s mortgage lending and community investment data. Following Jason will be Next City journalist Oscar Perry Abello, who will discuss the findings from this year’s reporting at Next City and from his book The Banks We Deserve. Our final speaker will be Corey Hammonds, Chief Operating and Credit Officer at Citizen Savings and Bank and Trust in Nashville, one of the oldest Black banks in America. Hammonds will provide advice for those interested in developing a relationship with a bank and launching a community development project in your local area. Without further ado, here’s Jason Richardson. Jason, the floor is yours.

Richardson 02:40
Thank you, Monchiere’. Thank you very much again. I’m Jason Richardson, Senior Director of Research at NCRC, and I’ve got a lot of slides here. We’re going to actually hustle through some of them, so don’t worry. You’re going to be able to get a copy of these slides later on, but I want to make sure that we have enough time for the other speakers and Q&A. So, these are just slides where we’re kind of tooting my own horn about my team at NCRC and the support that we provide for NCRC members. Take a look at that later on when you have a chance. And, if you have any questions, feel free to email me. If you’re an NCRC member, you can always contact me for assistance with data analysis or just understanding the data you’ve got for your organization better.

Today though we’re going to be talking about Nashville. We’re going to be talking about the Nashville metro area, including 13 counties, and we’re going to talk about redlining. We’re going to talk about the echoes in that have continued to impact communities like Nashville since redlining was officially established in the 1930s. Right now, I want to go to the website that you see on your screen here. This is part of a report that we completed some time ago, but it is a great way to understand how redlining in the past affects lending today. What we’ve done here is pull together 40 years of mortgage lending data from 1981 through 2021. We’re going to compare that with the redlining that occurred in the past, and then you’re going to see patterns emerge over time as Nashville has grown.

So, I’m going to share my screen now. So, when you go to the website that I put on the screen, you’re going to see this map. Today, we’re going to zoom in on Nashville. Come in slowly here, and we’re going to zoom in a little close. What you see here then [are] the red areas that are outlined in red are neighborhoods that were redlined in the 1930s by the Homeowners Loan Corporation. Now, we’ve published extensively on redlining, and this is not really a redlining presentation, so I’m just going to cover this briefly. But, essentially at the time, the government decided that they were not going to purchase loans that were made in certain areas of cities. There were a lot of reasons that areas were redlined, with the presence of African Americans being a key part of that distinction. Here you see those historical redlined areas. And, we’ve overlaid it with 1981 data. So the purple areas are majority-minority census tracts. The darker purple indicate 80% or more minority population and minority means anything other than non-Hispanic white.

So, in Nashville, that’s primarily going to be African American populations. The circles you see here in the blue and gray; those are mortgage lending activity. So, this shows the distribution of mortgage loans across the city in 1981, and you can see some patterns. Parts of the redlined communities do have some lending, but many of them you don’t see a whole lot of lending going on. But, what’s interesting here is as we set this in motion, you’re going to see these patterns change. This is 1981. You can go to the lower right-hand side here, open up the legend so you understand what the the map is showing you, and click play. And, let’s let it run for a little bit. We’re going to get into the 1990s here in just a second. And, the first thing you’ll notice, we’re in 1993. Excuse me, is that you’ve seen the purple areas expand. The number of majority-minority census tracts in the area has increased. You’ll also notice that the mortgage lending has vanished from a large part of the map here. So where did it go? Well, let’s back up a little bit, and you can see that a lot of the lending shifted to outer portions of the metro area and areas just to the south of Nashville. This is not an unusual pattern. The ’90s saw a lot of construction outside of cities, and you’re seeing a lot of that mortgage activity shifting from the city itself, especially from the high minority areas, out into these exurban areas. Let’s go a little bit further, though.

Richardson 06:44
We’re going to stop around 2005, so we’re talking about 2005 being kind of the height of the housing boom period in this country. And, you see again, there’s been a shifting pattern here. Mortgage lending has shifted to the east and the southeast of Nashville, and you can also see some more changes. I’m going to zoom in again here a little bit. Some more changes in the share of loans that are being made in majority-minority census tracts. You’re starting to see areas around the airport near Antioch that have become majority-minority. Generally, we don’t see a whole lot of lending in many of these areas, but to the southeast of the airport, you do see quite a bit of lending during this time. Now, I understand that during this time we saw a significant migration of African Americans from Nashville into this area, and that’s going to show up here in just a minute because right after this, we experienced the housing crash in 2008.

So, let’s go to 2012. There we go. Now [in] 2012, we had officially recovered supposedly from the recession. However, we can still see a lot of patterns in the lending here that are concerning. First of all, let’s zoom out again, and we again see these concentrations of loans to the east and to the southeast, but look what’s happened in Antioch, where the minority population has grown so much. There’s an absence of mortgage lending during this time. Now, if we zoom back into Nashville proper, we can also see a very clear pattern where mortgage lending is concentrated only in the White communities to the south. In fact, if you zoom in even closer, this area of downtown Nashville that was majority-minority when we started this discussion has shifted to majority-White, and the area to the north that was heavily minority is now 80 percent or more minority when we started is now still majority-minority, but not as heavily. And, if we play this through to the last date, 2021, the pattern is not going to change very much. And, that’s where we’re sitting today. So, you can go to the website yourself and play around with this map. I’m going to stop sharing now, and we’re going to shift to the rest of my presentation. And, if anybody has any questions about the HLD map, that’s the HMDA longitudinal database, then just email me after the call, and I can help you out more with it if you want to understand where that’s coming from.

Now, we’re going to talk about data. We’re going to talk about mortgage lending, small business lending, and commercial lending in Nashville. In 2025, there were 25,297 loans across the Nashville metro area. Those are home purchase loans. There were 591 individual lenders, and 20 lenders, the top 20, made half of those loans. Who got those loans? So, it’s interesting to look at not just who got the loans, but also the population in the area. Here you see the blue lines indicate the share of loans going to each individual racial group. The pink lines below it are their share of the population. Those little black vertical lines there are new figures. It’s just to give you something to compare to. The things that hop out at me here are pretty simple. 77% of home purchase loans in 2025 went to White applicants, who are 69% of the adult population. Hispanic borrowers actually got slightly more loans than their population size. That’s part of a national trend that we’re seeing across the country with Hispanic borrowers. However, Black borrowers are receiving less than half of the share of loans that they should be getting based on their population size. Asians are also a little overrepresented, but the American Indian and Native American, as well as the Native Hawaiian and Pacific Islander populations, are relatively small, so who’s doing all this lending? Here are the top 20 mortgage lenders in the country, or in the, I’m sorry, in the Nashville area. United Wholesale Mortgage is one of the top lenders in the country, so it’s no surprise that they’re there. And, my guess is most of you probably have never heard of United Wholesale Mortgage, so they are a wholesale lender. Most of their loans would have been made by mortgage brokers or smaller lenders. The same with CMG Mortgage.

Richardson 11:05
Then, you get to First Bank, and, if you’ll notice, there’s only a few banks in this list: First Bank, and then Pinnacle Bank, which is a Tennessee-based bank, Old National, J.P. Morgan, and another Tennessee bank, Wilson Bank and Trust. This rounds out the top 20. So, when you look at those individual lenders though, the share of their loans going to Black borrowers is dramatically different across lenders. Your top three here includes Wilson Bank and Trust, one of those Tennessee banks that we mentioned earlier. But, at the lower end, some of these lenders are making very low amounts of loans to Nashville African Americans despite their sizable portion of the population, commercial lending and small business lending.

So, commercial lending in the last 13 months, across April 2025 through May 2026, we’re talking about 6.9 billion dollars in lending. This is for apartments, office buildings, retail, industrial properties, 311 total transactions across 153 different lenders. Top lenders and commercial lending is a little more complicated. There are often multiple lenders but [one of] the major lenders here [is] Fannie Mae for apartments, which is not a surprise. They’re the largest apartment lender in the country. But, for industrial, office, retail, and hotels, Pinnacle Bank and Wilson Bank and Trust, local banks that are based in Tennessee. In fact, when we look at the number of commercial deals, Pinnacle and Wilson are on top, followed closely by Renaissance and First Bank. Small business lending. So, commercial lending is for large properties. Small business lending are loans under a million dollars to small businesses. In 2024, which is the most recent year of data that we’ve got, 2.1 billion dollars in small business loans were made in the Nashville area. We’re talking about 56, almost 57,000 individual loans across 174 lenders. Half of them are going to businesses that are considered small businesses, where the revenue is under a million dollars a year. And, who is doing these loans? First of all, you’ll notice by loan count, J.P. Morgan Chase, Bank of America, American Express, these are credit card lenders. So, it’s not a surprise that they’re leading the pack in terms of the number of loans. But, look on the right-hand side in terms of dollar volume, Pinnacle Bank on top, 117 billion dollars followed by, you know, some other national banks, but the fact that a local bank is on top here by a significant margin, I think, is really interesting.

So, what have we learned? First, [the] Nashville market is unequal. Black applicants are denied much more often. I didn’t really get into that too much, and Black and Hispanic borrowers are concentrated in the same low- to moderate-income tracts that the HLC graded as hazardous in the 1930s. The market is concentrated. You have 591 home purchase lenders, 153 commercial lenders, but the top 20 home purchase lenders capture almost half the market. Nationally, that, you know, differs quite a bit nationally. The top 20 lenders only capture 38.6% of the market. So, Nashville is actually a little more concentrated than the national market. Local, meaning that locally headquartered headquartered banks lead commercial lending, they lead small business lending, and they’re very important for mortgage lending. So, the map from the 1930s is interesting because within the context of the city of Nashville, you can see how it still shapes where the mortgage lending is going, and that is something that we see across the country. Cities that I look at all the time they show the same pattern. The 1930 maps captured segregation that existed in those cities at the time, and they instituted a program where banks spent a generation avoiding those areas because they knew that nobody would buy the loans. Today, we still see the echoes of that. Those properties are generally less worthless, and banks are finding it harder to make loans there.

Well, with that, I’m going to turn things over to Oscar. Oscar’s going to talk a little bit about the importance of local and regional banks, I think and I hope, that I can’t wait to hear it. Thank you very much.

Abello 15:05
All right. Well, thank you, Jason. Appreciate the presentation. It’s pretty fascinating, and it really, really just jived in with what I found in my work as a journalist, writing, and reporting about community development and economic development across the country over the past 10 years. So, you know, a lot of that work culminated in my first book, The Banks We Deserve, which came out last year. I might have seen some of you on [the] book tour last year in 18 different cities. Some of these photos are in Cleveland or Rochester, San Francisco, Baltimore. It was really all over the country talking about pretty much what Jason found in the data so, you know, and this, the book, itself draws on my reporting for Next City. So, at Next City, we’ve been around since 2003 and we are an online newsroom covering solutions to advance social, racial, and environmental justice in cities across the country. I’ve been there since 2015 myself, so about 10, so over 10 years now, and I’m currently [the] economic senior economic justice correspondent.

And so, you know, one simple way to think about my job is I’m looking at community development, especially economic development on the economic side in historically redlined neighborhoods. I’m looking at who’s doing it, where are they getting the funds to do it, who owns the properties, who owns the businesses, how are they getting access to capital. You know, I’m looking at where the money is coming from, and that’s what I’ve been doing since 2015. These are some of the headlines just from 2023, which was the the year I kind of took a break toward the end of this year to start working on the book and, like I said, my job basically is to look at who’s doing economic development in historically redlined neighborhoods and, particularly as a journalist, you know, follow the money. Where’s the money coming from? And, of course, I know it’s… I don’t have to tell you all. The money is mostly coming from banks.

The thing is, if you just look at where the money is coming from and, I’m just looking at the assets of the banks, I might get distracted by the big banks, right? Because the big banks here are in the orange, right? These are banks with more than $100 billion in assets. There’s only 32 banks across the country that have more than $100 billion in assets, and then the blue is the banks with $100 billion or less in assets. There are more than 4,000 of those banks – 42 actually – 4,200 of those banks in the blue. But, of course, the bigger banks are the bigger banks, and they dominate. They seem to dominate the market today. If you just look at the top line assets, but what am I looking for? What am I looking for as a journalist? I’m looking for who’s doing things like building housing anywhere but, in particular, in restricted redlined neighborhoods. Who’s doing things like financing commercial real estates on main streets and commercial corridors in cities across the country?

Then, whether it’s revitalizing old storefronts or taking old industrial buildings and turning them into something new for a neighborhood, or taking housing that’s been neglected by landlords for decades and trying to renovate it and fix it back up and put it back on the market, hopefully at prices most people can actually afford. Turns out, you know, if you’re going to do all that work, you’re going to need a construction loan from somewhere. And, where are the construction loans coming from? It’s not that giant orange slice, because if you just look at that, look at just the construction and development loans of bank books across the country, that orange slice becomes much smaller. You can see the blue slice – banks with $100 billion or less in assets – these are your local and regional banks. That’s where 73% of all construction and development lending from banks comes from. It comes from those 4,200 smaller local and regional banks. The next, if you look at the uncommercial real estate, same story.

Abello 18:57
Commercial real estate, most of the 74% coming from banks, the 40-200 banks with $100 billion or less in assets and, then on, small business lending. Okay, a little, a little bit, the larger banks doing a little bit better, as Jason pointed out, a lot of credit card lending in that orange slice in this picture. But, on that blue slice, you’re talking about, as Jason said, longer relationship-based loans to buy the buildings, you know, for a business owner where they’ve been operating their restaurant or their barber shop or whatever it might be -loans to buy equipment for a grocery store or a bodega. Those longer-term, larger relationship-based loans, again, coming mostly from those smaller banks.

So what’s going on here? You know, I’m a journalist, I’m supposed to figure it out. One of the things I found is that those local and regional banks… They have a real relationship with the people that they’re lending to, especially when it comes to construction and acquisition, rehab. Commercial real estate and small business lending, and just to give you an example of, like, what’s possible here, what’s in that blue slice. The City of Bridges Community Land Trust. You know, this is a newer community land trust. It’s a newer developer, so to speak. You know, they don’t have decades of experience in affordable housing, but they built a relationship with First Commonwealth Bank, a $12 billion bank based in Western Pennsylvania (a regional bank), and they just have a relationship with this first Commonwealth Bank. They have a weekly call every Wednesday, just like every other affordable housing developer or any developer in in the bank’s portfolio. They have a regular call with the bank. If for, in City Bridges case, it’s at 2 o’clock every Wednesday. They have a phone call to talk about what’s in the pipeline. That’s the kind of thing that’s possible. So, again, what’s going on here? So, it turns out that the size of the bank isn’t just about, like, what what deals it’s interested in or able to do. It also has a lot to do with the structure of the bank and how it actually makes loans, sources loans, and underwrites loans.

Community banks – they have these longer-term relationships with customers. They have loan officers, credit committee members, even boards that are meeting every week to talk about specific loans to specific businesses or specific projects in specific locations, and they’re talking about what we all know in small, which we’re dealing with small business or economic development location. They’re talking about, you know, is this the right business? Is this the right project for this location for this neighborhood? Who do we know who lives in the neighborhood? Are they going to shop at this business? Is this a project that this community needs in this location? It’s not just how they source loans; it’s also how they underwrite loans. It’s how the credit committee talks about every loan, every one of these loans that they’re making. This is a quote from Douglas Amaro, who works at the $3 billion Ponce Bank, a community bank, one of only two banks based in the South Bronx. They meet every week. I mean, sometimes, they’ll meet multiple times a week, just on a specific deal that might come across the plate that might have some kind of time urgency, and it’s not, it’s part of the underwriting, right? They don’t just source the loans through relationships.

They also [are] able to tell the regulator we’ve done our homework as a bank. We know the neighborhood, we know the borrower, we know the business, we know the developer. We know that this is a safe and sound loan to make. That’s the reason why these smaller banks do so much more than those larger banks, and it’s really stark, especially when you get to, like, when you compare the smallest banks and the biggest banks. Right, those biggest banks, just the big four – Chase Bank, Wells Fargo, and Citi – they’ve got $9 trillion in assets compared to the $2.7 trillion at the three 900 community banks. So, you think, oh, big four banks again? Are they the partners we need? Are they doing the work that we need banks to do?

Abello 22:52
The answer is pretty much no, they’re not. Those those 4,000 community banks do three times more construction loans than the big four banks combined. They do three times more commercial real estate loans than the big four banks combined. They even do twice as much small business lending than the big four banks combined. This is what’s in their their portfolios right now, as of the latest call report from the federal regulators. Just as another example of, like, what’s possible. Again, here’s a real estate cooperative just north of Minneapolis in a place called Brooklyn Center. We’re about there were a few dozen business women, mostly Black and immigrant business women in the Minneapolis suburbs. If, you know, the Minneapolis suburbs, this is a heavily immigrant neighborhood. Something like 25% of the population was born outside of the U.S. in Brooklyn Center, but the landlords weren’t giving them opportunities to lease out storefronts in strip malls that are vacant. Like, they all got stuck in these office buildings. I’m talking about like a hair salon or a nail salon operating on the third floor of an office building, and what the heck is going on? It’s the only opportunity they could get. So, a few dozen of these women got together, pooled their capital, and they got a loan, a $3.4 million loan out of $5 million in capital they needed to raise to acquire this strip mall last year, or about two years ago now.

So, and you can see here, I’ve got a quote here from the commercial from the loan officer that worked on the steel, and she’s looking at their cooperative model and saying, “Yeah, you know, this is creative. These women have been in the neighborhood. Some of them have businesses that have been around for 15-20, or 20 years.” They can talk to them. They can go out and meet them, and she can bring the credit committee to go out and meet these business owners, and they can all build a relationship and say, yeah, you know what? These landlords, conventional models, conventional landlords can’t figure out what to do with these strip malls. You have, but you guys have thriving businesses despite being stuck in these office centers, office buildings, like, this travel agency you can see on the right. They, this is one of this, is the travel agency that one of these travel agencies. It was, it was stuck on, like, a second floor of an office building around the corner from this strip mall. Now, it’s got this beautiful storefront. She’s expanded into selling luggage, suitcases, travel accessories. Right, her name’s Janie Sabor. She’s the chair of the co-op that bought this strip mall. So, now she’s in there and she owns the strip mall along with the 30 other women in the real estate cooperative that acquired this a couple years ago. Again, relationship building – it’s all about relationships. It’s community. It’s community based, and that’s what’s possible when you have a local bank involved.

So, what’s the problem, right? This is the big problem, right? You know, Jason pointing out the numbers and giving you the national picture. It’s local banks, community banks, regional banks that are doing most of the work that communities actually need. But, here’s the story that I think a lot of you know at NCRC. There’s been [a] tremendous consolidation of the banking sector. We haven’t just lost, you know, it’s the banking sector itself has grown, right? But, we’ve lost the institutions, and when we lose the institutions, we lose the relationships, the networks that those institutions lend through. So, it’s not just the fact that we have larger banks now shifting from a large bank-based from a small bank-based system to a large bank-based system means shifting what the system is able to do, and that’s of course not the only problem, right? Jason talked about redlining, and those community banks, these existing community banks, they’re the banks that redline, right? We’re talking about, you know, when you think about all the community banks we used to have, they were part of this history.

Abello 26:35

They were part of that Fannie Mae history of, like you know, all those billions and billions of dollars of more small dollar mortgages issued by community banks going to 98% [of] White families, and they’re still doing it. When we talk, not everybody has the same access to that community-based underwriting. What you’re looking at here is the chart that shows the different kinds of lenders using HMDA data. So, the the smaller bars in the middle, those are your community banks, the smallest bars, meaning they’re the least likely to serve majority-minority census tracts, less than even the the top 25 largest banks. You can see them just to the right. Credit unions doing a little bit better. CDFIs is doing a little bit better than credit unions. But, who’s doing the best? It’s the minority depository institutions. In this chart, that includes both community banks, includes both banks and credit unions that are NDIs. That’s no surprise. They’re the most likely to serve majority-minority census tracts because it turns out relationship-based lending and relationship and community-based underwriting is both a strength and a weakness, right? If you’re lending [is] based on who your board, your loan officers, your credit committee [is], if you’re lending based on who they know, the neighborhoods they understand, then who they are really matters.

And, so that’s why this number is just so stark and shocking to me. It’s still something I think about. I wake up and think about it almost every day. Out of the 3,900 community banks that are still out there. Out of the 3,900 of those community banks doing all the community-based underwriting, commercial real estate lending, construction lending, talking about specific deals in specific places, talking about it every week at the credit committee and the board level. Only 130 of those banks are owned or controlled by non-White Hispanic communities. So, you just think about like how many CDFIs are there? 1,400 CDFIs. Okay, great. There are 4,000 community banks doing all that construction, commercial real estate, and small business lending to the communities that they know, based on who serves, who’s on their board, who’s on, who are the loan officers, who’s their credit committee. There are 4,000 of those banks doing that work for White communities and only 130 for everybody else. And, if you break it down by geography, it really gets really stark, right? I live in New York City. You can see we got 19 White community banks in New York City serving 2.6 million White folks. Only one community bank for Black folks. Only one Hispanic community bank for Hispanic folks, and it’s everywhere, right? Here’s New Orleans, stark. It’s the same. Here’s Chicago. Chicago’s crazy, right? Chicago’s got the metro area’s got 73 White community banks. You have some beautiful downtowns and main streets in the Chicago metro area, whether it’s on the north side of Chicago or out in the suburbs, in the White suburbs, beautiful neighborhoods out there. One community bank, Black community bank left. Zero Hispanic community banks left for Chicago. Detroit, same story, and Nashville.

We’re talking about Nashville today. Here you are. You’ve got 19 White-owned community banks in Nashville. Only one Black community bank, and I’ve got them listed out here for you. Jason mentioned, you know, Pinnacle Bank here is a regional bank. It should, it’s doing what it should, what it’s always been doing, what they’re structured to do as as a regional bank. They’re doing what they’re doing, but you only have one NDI bank here. Now, I don’t want to leave you with just a picture. So here, so what’s possible with an MDI bank even today? And, if and should we have more of them? I mean, if you just think about it, like maybe we should have more. I don’t. I don’t know how many exactly more we should have. But, what if? What if you just started a new one today? What could it do? So, in Columbus, Ohio, Adelphi Bank became the first newly chartered African American NDI since 2003 since before the crisis, right? The first new one. They’re three years in. They’ve already got 100 million in assets.

Abello 30:28
You can see here almost $27 million in construction and development loans, $38 million in commercial real estate, $20 million in commercial and industrial. So, that’s mostly small business lending. So, just three years in and where’s where is it lending to. Okay, so here’s a map of the Columbus metropolitan area. So, this [is] Columbus and the surrounding area. The star is where Adelphi is – one branch. They only have one branch so far. It’s a new bank, right? One branch, the star. It’s in the historic east side of Columbus, historically Black east side of Columbus, and you can see in this racial dot map. So, every, you know, if the font’s kind of hard to see, but basically you’re looking for the yellow, right? The yellowish areas, the yellow dots, are the Black population in Columbus. And, like many cities, the Black population ended up on one side of the city, and Columbus it ended up being the east side. So the east side of Columbus, you can see the yellowish areas. Now, if we go to the next slide, these yellow dots are where Adolfo Bank is lending. As close as I can approximate the two maps together, right? Unfortunately, I’m not the greatest for graphics. Maybe Jason can do this, but the yellow dots are primarily in the predominantly Black neighborhoods throughout the Columbus area, from the historic east side around the branch to other parts of the Columbus area where there are Black neighborhoods.

I looked at the racial demographics of the zip codes where, um, where Adolph Bank has made these mortgages. You know, the yellow again,  each yellow is one commercial, is one mortgage. They’re primarily commercial real estate mortgages. And, Adelphi Banks’ top five zip codes. If you look at the top five zip codes where they’re lending, three of the top five are majority Black neighborhoods, and a fourth is 40% Black. And, then, the fifth of the top five is the zip code that that includes the Ohio State University. Which, of course, I mean, how can you avoid making a loan to a business near a college like that? So, that’s possible in just three years of work. Like, imagine what it’ll be in 10 years, 15 years, 20 years as a bank having the same access to the kind of banking, the relationship-based, community-based underwriting that the White neighborhoods have now. They have access to that in the Black neighborhoods in Columbus, and yeah, I’m excited to hear from Corey about the work that his bank has been doing, Citizen Savings Bank and Trust in Nashville.

Hammonds 32:42
Thank you, Oscar. My name is Corey Hammonds. I’m representing Citizen Savings Bank and Trust here in Nashville. Our claim to fame: We are the oldest African American-owned bank in the country. We were founded in 1904. We are an MDI, and then we are also a CDFI bank. I am here to talk to you very briefly about banking relationships and how your most important source of capital is the local community banks. I serve proudly as the chief operating and credit officer of the bank. I’m also the founder and owner of the Hammonds Group, which is a appraisal, a real estate development and brokerage firm. My focus is bridging the gap between corporate banking, real estate investment, and community growth. My mission, and also the reason why I’m affiliated with Citizens Bank, is their mission of empowering local entrepreneurs, expanding assets to capital, and building long-term generational wealth.

As Oscar mentioned, and as you have heard over this panel discussion, banking relationships do matter, and when you bank with a local community bank, whether you are an individual, whether you are an organization, nonprofit, or even a small business, the best time to build an institutional banking relationship is long before you need a request for a loan. So, no matter what it is that you need, it starts with a banking relationship, a depository relationship. I tell folks all the time, Citizens having the long history and foundation and longevity that we do have. Just imagine if we led the way into in-deposit generation. If we were as big as, let’s just say, a Wells Fargo from a depository standpoint. A lot of the issues that we’re talking about on this panel discussion right now would not exist for Black and Brown people. So, the main takeaway from that is where you put your money is really what you support. And, so if you really have a interest in making a difference, where you bank, where you have your excess cash, where you have your operating deposits, think about putting those with a local community bank because local community banks are the first line of folks and organizations that put money back directly into the communities that they serve. What helps projects gain traction?

So, I get a lot of very mission-minded projects that different developers want financing for, but what bankers really look for outside of that is clear. Framework, real contingencies, and a structure sponsor contribution model. So, what that really means is we really want to define scope of not only just how your project, from an economic development standpoint, helps the community. We also, we are still a bank, so we still have to make sure to de-risk and to make sure that the cap, the cap stack, as we call it, is diversified. So, when folks come to us, we want realistic timelines, reliable contingency allowances, and material sponsor equity to demonstrate alignment with your project. We also need balanced funding architectures combining sponsored equity, tax credits, state federal grants, and traditional debt. It’s very, very important if you’re doing any type of development that’s affordable housing, workforce housing, or anything that’s [a] economic development model or framework is to make sure that your capital stacking, your equity is in place, and that what helps community banks specifically underwrite the deal and make sure the deal is not only profitable to the bank and also profitable to the developer, but also good to the community. So, one of the reasons why banks might walk away is that there’s gaps.

You know, the the underwriting roadblocks, overly aggressive projections lacking submarket historical validation. You have to know the information of your market, of your development, of your project, equity deficits is another one. Intervention sponsor, financial commitment, or direct operational equity. What that basically means is there’s not enough cash injection or equity being put into the project. One of the things that people fail to think about is what we call underwriting friction. You know, as banks request things, late document submission, unaddressed liabilities, or missing reports. It’s critical to have all the information that you really need on the front end. So, when banks, we can build that rapport with potential borrowers who are doing good in the community. Some of the other things is the “Trust us” narrative.

Hammonds 36:57
Just because you’re doing good, like I said before, and you have a a project that is good for the community. We still need all of the information that we got to have. Compressed time windows, meaning you know a project, no matter what size or what scale it is, we really need to have enough time to underwrite it properly, and then also you know operating on flat budgets without material cost overrun assumptions. When you’re doing development deals, there’s always something that’s going to come up, so making sure that you have all of that cushion, or contingency capital, squared away is very, very important. So, the core principle of this is banks rarely decline deals due to mission alignment. I get a lot of requests throughout the Nashville area where there are mission-aligned projects, especially with the mission of Citizens, normally it’s walked away because the risk cannot be underwritten securely. So, from a capital stack perspective and from a cash flow perspective, that is very, very important in making sure that the bank is with you as it pertains to providing you the financing that you need.

So, to end my presentation, successful community development financing occurs at the intersection of three things: 1) strong relationships, but it starts at the depository level. 2) measurable community impact. We want to see not only that you’re a current customer of the bank or current customer of, you know, the community. We also want to see how do you measure the community impact based on what it is that you’re doing, and then thirdly, because we are a bank, we still have to, you know, stick to sound banking fundamentals, and that’s making sure capital stack is adequate, and that’s also making sure that the information that is requested cash flows properly, so we can stick to sound banking fundamentals. Thank you for the presentation, and I’ll turn it back over to Monchiere’ for any questions that anyone might have.

Holmes-Jones 38:43
Corey, thank you so much. That was really, really good, and succinct. I love that. If you have any questions, I saw a couple questions in the Q and A, and thanks Jason for getting in there and answering a couple of those. We have one that I need to answer, and I will need a little help on this one that I see still out there. How long will the replay be available? Not sure if we know that just yet, but I’ll get that information. But, if there’s any additional questions, someone’s typing that answer now. Thank you. Any additional questions for any of our panelists? I would love to open the floor for that. If you can just go into the Q and A at the bottom of your screen, screen there, we can get those answered. This has been a great presentation. I was taking notes. I need to go back to that map. That map for Nashville. Thank you for doing Nashville. That’s really huge for us here. Again, Jason, Oscar, Corey, great, great, great presentation! So excited! Oh, Ron Thompson, thank you, Ron. What can Nashville do today to turn this trend around? I’ll throw that to Oscar just based on some of your notes of kind of surveying the whole United States with your book. And then everybody else can follow … Corey Jason… and I can answer it again if you don’t see it.

Abello 40:04
Oh, I can see it. Yeah, I mean, one thing that, I guess, [is a] pattern I would say has existed over time. It’s not necessarily what’s happening, what’s been happening recently. If you do look at the 21st Century ROAD to Housing Act, which just passed, there are several provisions in there that are specifically tailored to support community banks, local and regional banks, to be a more significant piece of the sort of affordable housing infrastructure in every across the country. Right, there’s a cap on public welfare investments, raising the cap on public welfare investments, making it easier to hold reciprocal deposits or custodial deposits. So, you know, if you have a large deposit or anchor institution like a hospital or university, you know, there’s only so much, and they can leave deposited at a community bank, a smaller bank. But, that amount is a little bit bigger now. But that bill that just passed, you know, is probably the first time in a very long time when policymakers centered local banks in the delivery infrastructure for community development, you know, writ large.

You know, once upon a time when we created the FDA, the Federal Reserve. Let’s start with the Federal Reserve, the first one, right? When you create the Federal Reserve, that was originally to support local banks. That’s the reason why there’s 12 Federal Reserve banks. There’s not one Federal Reserve in New York, even though you know we can talk. I can talk. I will talk offline about what’s the New York one dominating the others. But, there’s a reason why there’s 12 federal reserve banks. The FDIC originally created to support local banks that needed the backing of the federal government so that they could continue to attract deposits locally. The federal home loan banks originally created again to support small savings and loan associations across the entire country. Once upon a time, policymakers centered community banks and local banks in everything that they expected to happen when it comes to community development and economic development. The idea of having big banks come in and be a partner did not figure into the equation because they didn’t exist until recently, right? In 1986, when we had 15,700 community banks, those community banks were 40% of the banking system, and the top four banks, the same top four banks we have today, those four banks were 6% of the banking system. We had a much more local and regionally-oriented banking system back in the day, and that was a result of policymakers centering local banks, and that can happen at the state and local levels too. It doesn’t just happen at the federal level. State and local governments can also do a lot to support local banks.

Hammonds 42:55
I want to add one thing to that. Yeah, especially in the Nashville area, which I’ve been a part of personally, is public and private partnerships. I think that is very, very important for the public sector and the private sector to come together and make sure that economic development, community reinvestment actually does take places in the areas, specifically of Nashville, that is needed for.

Holmes-Jones 43:19
That’s good. We love public and private partnerships in Nashville for sure. It’s how we move the needle. I’ll also add, you know, community development entails a lot of things. So, when we have these public and private partnerships, these webinars like this and events that we have, are really key to meeting the right people and the people who are ready for those types of conversations. So, beyond going, driving, yourself to the bank, so don’t forget to sign up. We’ll have some stuff for that in the future towards the end. Thank you for that, Oscar and Corey. I have another question here, and let me see if I can sum it up here really quick. Carmelita Turner, thank you. Enjoyed hearing your talk, Corey. It looks like, sounds like, the comments alluded to the Black community not being prepared or bankable, and so Citizens helps with that. She doesn’t have that data in front of her, but she was wondering. She never hears the organizations tell the person how they can. I love this. I’ve never liked hearing organizations tell the person who has been hit by a car to get up and walk over to the ambulance. I’ll go ahead and say, Citizens is definitely not those folks. They will hold your hand from front to back. Great partnerships. I’m a banker at Citizens as well and a Black-owned business on historic Jefferson Street. But, I’ll let Corey go ahead and answer that to your point on that.

Hammonds 44:36
Not only just, you know, Black and Brown communit[ies], but anybody that is, you know, underserved or underbanked. What we specifically do, we have a partnership with a nonprofit out of Atlanta called Operation Hope. It is free to the community, to anybody that wants to come about, and it is for individuals whether they need budgeting, is for small business or entrepreneurs who need counseling to get their businesses off the ground. This is not a one-time type of counseling. You can come as many times as you want, and it is totally free. And, what we do is we try to prepare whether it’s an individual, whether it’s an entrepreneur, or some type of other organization. We want to prepare them for the financing that they need, especially when what they’re doing is community-focused.

Holmes-Jones 45:20
Okay, I love it. We have one more question before we turn to our closing notes. How have the community and regional banks played a role in the housing recovery since 2008? Jason, I felt like when you said that earlier, that was a good primer. Like, did we get back together by 2012 in real life? Let me see. I don’t think so, but this question I’ll kick to you from Athena Gore.

Richardson 45:43
I’m sorry. Let me take a look here.

Holmes-Jones 45:45
No, it’s okay. How have community and regional banks played a role in the housing recovery?

Richardson 45:50
So, what we’re finding, so ever since the housing crash, banks have every year we’ve seen them pull back further and further from mortgage lending, and I’m going to confine my comments right now to mortgage lending because it’s what I work with the most. So, for a variety of reasons, banks have every year ceded the mortgage space to mortgage companies. In fact, in 2025, only 30% of home purchase loans nationally were made by a bank. About 10 or 11% were made by credit unions. The rest of them are made by mortgage companies. Large banks were actually finding now that they are turning from making mortgage loans directly. Instead, they’re opening up massive lines of credit for mortgage companies, and by doing so, banks can sidestep regulations like the Community Reinvestment Act in certain ways, and I think that that is a particular concern.

NCRC has been a strong advocate for modernizing the Community Reinvestment Act to cover mortgage companies as well. And, if you’re not familiar with it, the Community Reinvestment Act is a law that requires banks to reinvest in the communities where they take deposits from – it’s a really simple concept. You cannot take deposits from a community and then refuse to lend money in that community, or simply avoid that community. And, right now, mortgage companies are exempt from that, so there is no obligation for them to service lower-income areas of Nashville, and we feel that is, you know, a gap certainly in oversight that we hope at some point is corrected. One other thing we’ve done is help groups promote state-level Community Reinvestment Act[s]. Illinois just implemented [one]. New York has a state-level CRA and, hopefully, New Jersey soon will as well. So, you know, and I’m kind of sidestepping your question here because I don’t have specific data about Nashville for the entire time period for regional banks, but I can tell you that banks like Wilson Bank and Trust and Pinnacle Bank that I talked about, they have remained in the mortgage business, and I think that’s great. They are regularly examined to make sure that they are lending in lower-income areas and to lower-income home buyers. But, if you have any specific questions and you’re a member of NCRC, keep in mind you can just drop me a line anytime. Shoot me an email. I put my email in the chat, and I’m happy to look at specific banks or banks in your specific area.

Holmes-Jones 48:25
Awesome, thank you, Jason. That’s really, really good, and also I think the link was in the chat as well. But, to his map, that map that was really, really helpful. So, if you have not grabbed it, I want to go ahead and take these last few minutes here to get you ready. This was first of many. We will host a training in Nashville related to community development and investment. So, if you’re in the Metro Nashville area and would like to attend, go ahead and email Greg Wilson, G Wilson at NCRC.org. For those of you on the West Coast, NCRC will be hosting our Reinvest Washington Economic Summer Summit in Tacoma, Washington on September 22. That sounds amazing. And, for those of you across the country, NCRC will be hosting our 2027 Just Economy Conference May six through seven, Washington D.C. Of course, if you have an idea for a need, for a panel, and we need to submit that idea, please do that by July 30th of this year. For more information, you can always become a member to stay tuned and stay connected and get all of this good information by going to ncrc.org/membership. And, for more details on future events and webinars like this, do the same thing. Go to ncrc.org/events. Today was amazing. Content was solid. Thank you all so much. We appreciate you here in Nashville, of course, but we appreciate NCRC just as well. Thank you so much, and have a great day.

 

Transcribed by https://otter.ai

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NCRC’s Comment on the FHFA’s Proposed Rulemaking on the Enterprise Duty to Serve (DTS) Underserved Markets https://ncrc.org/ncrcs-comment-on-the-fhfas-proposed-rulemaking-on-the-enterprise-duty-to-serve-dts-underserved-markets/?utm_source=rss&utm_medium=rss&utm_campaign=ncrcs-comment-on-the-fhfas-proposed-rulemaking-on-the-enterprise-duty-to-serve-dts-underserved-markets Fri, 24 Jul 2026 03:51:29 +0000 https://ncrc.org/?p=290685

July 23, 2026

Clinton Jones
General Counsel
Attention: Comments
Enterprise Duty to Serve Underserved Markets
RIN 2590–AB64
Federal Housing Finance Agency
400 Seventh Street SW
Washington, DC 20219

Dear Mr. Jones:

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on proposed changes to the regulations implementing the Enterprise Duty to Serve (DTS) Underserved Markets, RIN 2590-AB64. The DTS regulations help ensure that the Government Sponsored Enterprises (GSEs), Fannie Mae and Freddie Mac, target their product development, outreach, and loan purchase activities to traditionally underserved markets including rural areas, affordable housing preservation, and manufactured housing. The DTS regulation must measure whether the GSEs are fulfilling their statutory duties to “increase the liquidity of mortgage investments and improve the distribution of investment capital available for mortgage financing for underserved markets.”[1] Accordingly, the FHFA must improve the rigor of its proposed rule so it can accurately measure the GSEs’ activities in underserved markets and encourage an increase in those activities.

NCRC supports aspects of the proposed rule such as requiring the GSEs to formally respond to public comments and eliminating abuse of the plan modification process. However, we urge the FHFA to reconsider major aspects of the proposed rule which could reduce financing for the populations with the most pressing needs by relaxing income targets and instituting a vague ratings regime. The proposed ratings system could make it easier for the GSEs to pass their DTS requirements while not increasing and possibly reducing their financing of lending activity to the DTS underserved markets. Under the proposed ratings system, the GSEs would receive passing or failing numerical ratings that measure their activities (loan product development, outreach, loan purchases, investments and grants) in each of the three DTS markets of rural areas, affordable housing preservation, and manufactured housing. As described in detail below, the proposed ratings system lacks objective measures of performance which could likely result in subjective and inflated ratings.

NCRC is a coalition of more than 750 community-based organizations fighting for a just economy. For nearly 30 years, NCRC has worked to create opportunities for people and communities to build and maintain wealth. NCRC members include community reinvestment organizations, community development corporations, local and state government agencies, faith-based institutions, fair housing and civil rights groups, minority and women-owned business associations, and housing counselors from across the nation. Our community members need the GSEs to help facilitate access to credit and wealth building opportunities for modest income neighborhoods and communities of color.

Our comment will make the following major points:

  • The proposed elimination of a prescribed list of activities for DTS plans and evaluations is likely to result in the GSEs choosing activities that are less impactful in terms of leveraging financing for the DTS markets. The rule must not allow the GSEs to re-label their regular activities as those targeted at DTS markets. This would result in a significant loss of impactful activities that would leverage more investment capital for mortgages serving DTS markets.
  • The relaxation of income targets in the proposed rule would encourage the GSEs to decrease their focus on populations with the most housing needs in favor of higher income populations for which financing housing is not as difficult.
  • NCRC supports the FHFA’s proposed requirements regarding the GSEs’ obligations to help banks comply with Community Reinvestment Act (CRA) obligations and to help create an institutional infrastructure for financing affordable housing that includes nonprofit organizations and state and local governments.
  • While NCRC supports the FHFA requirement that the GSEs explicitly respond to public comments on their draft DTS plans, NCRC requests that FHFA lengthens its proposed public comment period from 45 to 60 days.
  • As part of DTS plan development, NCRC supports the FHFA’s proposal to make it more difficult for the GSEs to modify plan requirements. The current procedure is prone to manipulation in the form of weaking plan goals to avoid GSE failure to achieve plan requirements.
  • NCRC reiterates our long-time position that a two-year plan is more feasible than a three- year DTS plan for the GSEs to achieve. A two-year plan would also reduce the need for modifications and would also provide more opportunities for public input.
  • NCRC generally supports the FHFA’s proposed dissemination of DTS-related documents and annual reports, but we suggest improvements to the proposal.
  • The FHFA proposed rating system for the DTS plans and annual performance is too subjective with an absence of measurable outcomes and benchmarks. The FHFA’s proposed new activities such as program management on DTS evaluations will also likely increase subjectivity and inconsistencies in ratings. The result could be ratings inflation that reward stagnant or declining levels of financing in the DTS markets.

Elimination of Prescribed List of Activities Would Reduce GSE Attention to Impactful Activities

Under the current DTS regulations, the GSEs are required to specify goals for an established set of statutory and regulatory activities for each DTS market (the GSEs have to choose activities within the established set of activities). For example, under the affordable housing preservation market, GSEs are required to develop goals for loan production, outreach, loan purchase, or investments and grants for activities such as financing Section 8 properties, Section 515 properties, or Low-Income Housing Tax Credit (LIHTC) properties for lower income households. The GSEs can also propose additional activities that would receive favorable consideration upon the approval of the FHFA.

The FHFA is proposing to delete these lists of activities and allowing the GSEs to propose their own activities that will promote financing of affordable housing preservation, manufactured housing, and housing in rural areas. The FHFA would then approve or reject these proposed activities.[2] The FHFA believes that the current procedure of established lists stifles innovation and causes the GSEs to chase a list of predetermined activities that might not be the most responsive to need.

The FHFA states that the list of activities “may have incentivized a ‘compliance-centric’ mindset that prioritizes the fulfillment of granular regulatory benchmarks over meaningful market impact.”[3] The FHFA continues that the agency, “is also concerned that prescribing Activities, some of which focus on narrow geographies or specific populations, may have had the unintended consequence of limiting the Enterprises and their ability to support the holistic health of the broader secondary market for very low-, low-, and moderate-income families.”[4]

The FHFA, however, ignores the history of the development of the activities. Over several years, the FHFA had proposed several iterations of the DTS regulation and solicited input from stakeholders via comment periods and during forums. Under previous agency directors, the FHFA carefully developed the list of activities by considering the views of the GSEs, community-based organizations, lenders, and public sector entities regarding the activities’ importance in responding to housing needs. Discarding the current activity list in favor of allowing the GSEs to propose their own activities replaces a set of activities that had achieved stakeholder consensus regarding their importance with a set of activities chosen by the GSEs which might be responsive to needs but could primarily facilitate GSE business activities driven by their profit considerations.

An example of a seemingly arbitrary removal of prescribed activities is the deletion of required water and energy efficiency activities. The FHFA cites an Executive Order that mandates the deletion of incentives for “costly energy efficiency and water use requirements” from regulation.[5] Yet, the FHFA offered no data or analysis concluding that costs of energy efficiency improvements outweighed the benefits. Borrowers can probably better afford their mortgages if home improvement loans for energy efficiency resulted in considerable savings on utility bills. A study conducted by the UNC Center for Community Capital found that homeowners of energy efficient homes are 32 percent less likely to default than those not in energy efficient homes.[6] In addition, the U.S. Department of Energy estimates that its weatherization program saves households an average of $372 annually on utility payments.[7]  Based on this evidence, it is likely that, GSE purchases of loans that included improvements and rehabilitation geared towards energy and water efficiencies would improve the performance of loans in the GSEs’ portfolios or in Mortgage-Backed Securities (MBS) purchased by investors.

The proposed FHFA’s role of reviewing the activities selected by the GSEs might offer some level of protection against activities biased towards GSE business considerations. However, the process would be dominated by interactions between the GSEs and the agency with a lesser role played by community stakeholders in influencing the activities. Community stakeholders would be able to comment on draft GSE DTS plans but the emphasis would now be on GSE-selected activities instead of GSEs responding to a list of activities developed in public processes over several years. The proposed GSEs’ top-down process would bias the selection of activities to the imperatives of the GSEs as opposed to broader public needs.

In addition, the proposal to require the GSEs to develop a list of activities may not be successful as suggested by the track record of CRA strategic plans. Financial institutions prefer a consistent set of rules such as reacting to a prescribed list of activities to a strategic planning process in which they develop their own plans for satisfying community needs for affordable housing. Over the years, banks have opted for regular CRA exams much more frequently than strategic plans under which they establish their own goals. In 2025, for example, the agencies conducted 1,145 exams but evaluated just 20 strategic plans. For all the exam records over the years maintained by the Federal Financial Institutions Examination Council, the agencies conducted 83,727 exams but evaluated just 264 strategic plans.[8] In other words, strategic plans are not a popular choice as revealed by their frequency of less than 1 percent of all CRA exams.

CRA exams assess bank performance on established criteria for lending, investing, and services in low- and moderate-income communities. In contrast, strategic plans require banks to develop their own goals and performance measures for evaluating their success in achieving their goals. The FHFA is pushing the GSEs to adopt an evaluation regime that resembles the CRA strategic plan that benefits neither the GSEs nor communities as much as the current evaluation system.

Finally, the proposal to provide the GSEs with discretion to establish their activities may encourage the GSEs to label their regular activities serving mainstream markets as activities designated for DTS markets. The current prescribed list identified activities that often required institutional partnerships and flexible products so that they could successfully reach DTS markets. Removing this list potentially allows the GSEs to substitute activities that will not serve DTS markets as well because they lack institutional support and flexibility. This would reduce the volume of GSE supported financing for the DTS markets. This adverse outcome could be accelerated if the proposed rating system with subjective measures of performance is finalized as described below.

Proposed Relaxation of Income Targets Would Skew GSE DTS Activities Away from Borrowers and Communities with Most Pressing Needs

The FHFA proposed changes for loan eligibility for GSE purchases in rural areas and for manufactured homes would probably result in a GSE loan portfolio with fewer loans for families with the most needs. For rural areas, the FHFA is proposing that it use the highest of national, county, or state-wide nonmetropolitan income medians for purposes of calculating percentage of median incomes and qualifying loans for borrowers with incomes that are lower than a threshold percentage (such as 80 percent of area median income).

The FHFA believes that the current procedure of not considering national medians artificially depresses GSE rural loan purchases and does not meaningfully target purchasing activity towards those borrowers with lower incomes. The agency cites data analysis suggesting only a modest increase of a few thousand dollars of the median income of borrowers that would be served in the rural market due to its proposal.[9] Firstly, this analysis suggests that the change may not be meaningful because it results in borrowers having just modestly higher incomes.

Alternatively, the proposal may be detrimental. The FHFA did not consider the impact on the incidence of housing problems such as housing affordability or substandard housing by its proposed change. It is possible that a borrower distribution tilted towards a higher income mix could be experiencing a lower level of housing problems. The modestly higher income level of about $4,500 for the typical borrower due to the proposal could make a significant difference in the borrower’s ability to afford monthly housing cost or repairs to convert housing from substandard to habitable.[10] Thus, the proposal could divert affordable finance away from lower income borrowers more in need of the financing.

Housing needs are local, not national. Analysts should not compare housing needs or monthly costs in a rural county to national needs and costs that are often quite different. Likewise, median income levels in a rural community should not be compared to rural national median income levels, which could be quite different. The FHFA’s proposal ignores the interaction between local borrower income levels and rental or mortgage costs, which are influenced by supply and demand on a local level, and not a national level. Considerably lower income in some rural communities could be matched by considerably lower rents or mortgages due to lower costs to build and maintain housing. Thus, making more borrowers eligible for GSE rural financing by using a national income median might be inappropriate and target borrowers with higher incomes that can more easily afford local rents or mortgages. The FHFA does not offer any analysis that considers local housing market dynamics of this sort.

The FHFA offers the example of Puerto Rico and a few other outliers to say that the current procedure not allowing comparisons to national medians dramatically depresses the number of loans that the GSEs can purchase in rural areas.[11]/ However, an untested assumption is that increases in loan purchases are automatically a beneficial impact of the proposed change without analyzing whether increases in loan purchases might crowd out financing for borrowers or families with more pressing needs. If the agency had demonstrated the absence of crowding out in some geographical areas, it could analyze which other market conditions were present and could establish a rule allowing for use of national medians in those markets only.

The FHFA also proposes the same change for determining DTS eligibility for metropolitan areas. The agency will compare the income of the borrower to the highest of the metropolitan area median income, the State median income including metropolitan areas, or national median

income including metropolitan areas.[12] For reasons similar to the case of rural areas, NCRC strenuously opposes the proposed change as resulting in reduced targeting for the lower income and needier households and families.

As with rural areas, the FHFA proposed a change for manufactured housing that lacks complete analysis and could result in reduced access for the households with the most needs. Under current procedures, the agency considers a loan purchase to be DTS eligible for manufactured housing that is in census tracts with incomes at or below median income levels. The agency proposed deleting this location requirement and instead presume that all loan purchases for manufactured housing are eligible under DTS rules. Its data analysis suggests that most purchasers of manufactured housing have low incomes. However, it did not consider that most purchasers are low-income because of the current census tract restriction. That is, most households with limited incomes are unlikely to cast a wide geographical net while house hunting and may reside mostly in lower income census tracts that are more likely to have manufactured housing. The FHFA does not consider this possibility.

Moreover, instead of merely lifting the current census tract restriction, the agency could have considered establishing a mortgage dollar limit based on data analysis that would instead target the GSE manufactured home activity towards lower income households. The median mortgage amount currently for manufactured home communities could be increased with inflation. This would ensure continued targeting of manufactured home communities that serve lower income households and families.

Eliminating targeting mechanisms ensuring that DTS activity in manufactured housing is focused on households with lower income levels and the most pressing needs does not guard against future market developments that may skew away from modest income borrowers. For example, manufactured housing communities may enter other markets including middle-income markets as zoning and other regulatory rules change.

Changes to Rural High Needs Regions and Populations Need to be Implemented Carefully

Just as any changes to income targets need to be judicious, the FHFA should proceed cautiously with changing the definitions of high needs rural populations and deleting reference to Native Americans and agricultural workers. NCRC is concerned that removing explicit references to Native Americans and agricultural workers could weaken the focus on populations that the current DTS framework identifies as having distinct housing needs.

The FHFA suggests that under the rural activity category, the GSEs focus almost entirely on high needs rural areas which are currently defined to include Appalachia, the Lower Mississippi Delta, persistent poverty counties, and Colonias on the Texas Border.[13] By retaining the current high needs rural areas in the rural category as well as making it clear that the GSEs are to serve all rural areas, the FHFA intends for the GSEs to address a broad array of needs in rural areas. Yet, expansion could divert GSEs activities away from high needs rural areas.

A potential compromise is to retain the current high needs areas, make it clear that the GSEs can serve other rural areas, but also map and identify other rural counties exhibiting the highest incidence of cost burdens and substandard housing. The FHFA could then assess the distribution of GSE purchases across rural counties and provide higher ratings to the GSE that purchases higher percentages of loans in the counties with the highest incidence of cost burden and inadequate housing in addition to purchases in the current high needs rural areas. The FHFA should assess the results of any changes carefully and should revise its approach if both GSEs end up purchasing most of their loans in rural counties without the highest needs.

Similarly, the FHFA should carefully evaluate any changes it makes to the definitions of high needs rural populations. NCRC opposes the proposed deletion of agricultural workers and Native American populations for the reasons detailed by the Housing Assistance Council and the National American Indian Housing Council.

If the agency deletes references to Native Americans as a high needs rural population, it should examine whether GSE loan purchases are higher in Native American areas which the agency proposes to add to the high needs rural areas category.[14] NCRC found that tribal areas are lending deserts so we appreciate that FHFA is proposing to add Native American areas as a needs category.[15] However, FHFA should also track lending trends to Native Americans to make sure the GSEs are not neglecting this traditionally underserved category of borrowers. Likewise, it should track purchases of loans financing housing for agricultural workers if it deletes agricultural workers from the high needs population category.[16] As much as possible, data should be used in this assessment as well as interviews with stakeholders providing farm worker housing and social services to agricultural workers.

The FHFA should use the current level of GSE loan purchases and other activities in high needs rural areas and to high needs rural populations as a baseline in its evaluation of changes to the definitions and regulatory requirements. It should establish an expectation that the GSEs should not diminish activities and loan purchases to the current high needs rural areas and populations but should at least maintain the baseline level of activities if they seek to serve other areas with pressing needs.

Lastly, the FHFA should proceed cautiously regarding its proposal to relax the restriction on GSE Low Income Housing Tax Credit (LIHTC) for rural areas only.[17] Large metropolitan areas with several bank headquarters probably do not need GSE LIHTC assistance since CRA requirements are encouraging high levels of bank LIHTC activity in these areas. However, it is possible that smaller metropolitan areas are more in need of GSE LIHTC financing. The FHFA should expect the GSEs to retain and increase their current level of rural LIHTC financing while targeting urban financing to those areas that would receive little LIHTC financing but for the financial assistance of the GSEs. The GSEs should document the “but for” test in the LIHTC part of their DTS plans. In other words, for the urban LIHTC deals, the GSEs should describe how their financing was pivotal for executing the deals.

Plan Requirements Regarding CRA and Description of Mortgage Products Will Assist in Making GSEs More Effective in Serving DTS Markets

In contrast to the loosening of income target requirements, FHFA’s proposed requirements for developing institutional strategies will facilitate GSEs serving DTS markets. The FHFA proposes to require the GSEs to not only discuss “the challenges faced by insured depository institutions in meeting their CRA obligations and general affordability concerns in low-income areas,” but to also develop specific plans for helping banks meet CRA obligations and affordability challenges.[18] In other words, the plans would probably need to discuss the building of institutional relationships with banks and products that GSEs would develop with banks that help them meet CRA requirements and ease affordability challenges for borrowers. Ultimately, CRA works best if primary and secondary institutions collaborate more effectively with community and public sector entities. To the extent that the DTS plans promote more collaboration, lower income populations should receive more access to affordable credit.

Moreover, the FHFA’s proposal emphasizes development of institutional relationships and partnerships with a wide variety of stakeholders. It states:

In brief, proposed § 1283.3(b) would require the Enterprises to: (i) design programs and products that facilitate the use of federal, state, and local governments assistance programs; (ii) develop relationships with nonprofit and for-profit organizations that develop and finance housing with state and local governments; (iii) assist primary lenders to make housing credit available in areas with concentrations of low-income and minority families, and assist insured depository institutions to meet their CRA obligations; and (iv) develop the institutional capacity to help finance low- and moderate-income housing, including for first-time homebuyers.[19]

This proposed language must be finalized. In addition, the FHFA should clarify that under the loan product and outreach criteria, the GSES should describe programs and products developed with public sector entities and nonprofit community-based organizations. The description of the programs and products should also focus on how they will be directed to modest income neighborhoods and communities of color as well as first-time homebuyers.

The proposed list of tables will likewise boost transparency and facilitate stakeholder understanding of the GSE products and activities that would serve DTS markets. The FHFA proposes to require the GSEs to provide:

  • A list of mortgage products that will reach underserved markets,
  • Descriptions of GSE activities under the four statutory criteria of loan products, outreach, loan purchases, and investment and grants, and
  • A separate table of all loan purchase targets over the three years.[20]

This is similar to current requirements but nevertheless is important to maintain and require for future plans.

Plan Development and Public Comment Procedures Are a Good Start but Should be Strengthened

The proposed rule appropriately replaces GSE discretion in responding to public comments with a requirement that the GSEs respond to the substantive points raised in the public comments. Specifically, the FHFA states:

The existing regulation provides that each Enterprise “may, in its discretion, make revisions” based on public input, but does not require the Enterprise to respond to stakeholder concerns. To enhance transparency and ensure a meaningful exchange of information, the proposed rule would replace this discretionary standard with a requirement that the Enterprises provide a reasoned response to substantial points raised during the public comment period. This element is intended to promote accountability and provide the public with a clearer understanding of the technical, operational, or policy constraints informing the Enterprises’ final determinations.[21]

Over the years, NCRC and our member organizations have made several recommendations on draft plans regarding improving data analysis, identifying needs, and more effective targeting of borrowers and communities with pressing needs. These substantiative comments often went unanswered and a succession of draft DTS plans suggested that the GSEs did not seriously consider or incorporate them in their DTS plan development.

When the GSEs and/or the FHFA did not appear to seriously consider comments, either incorporating suggestions or explaining why they did not, the GSEs and/or FHFA undermine the public’s trust in the process. The result was less robust DTS plans that generate fewer and less insightful public comments for improvement. We are pleased the FHFA signals that public comments should receive the respect that they deserve and we urge the FHFA to retain these instructions in the final regulation about the importance of responding to comments in their final rule.

The FHFA would improve upon its insistence on the importance of public comments if it changes its proposed 45-day period to 60 days for receiving public comments on draft DTS plans.[22] NCRC itself is a coalition of 750 member community-based organizations. Engaging our members in outreach and conference calls regarding complicated DTS draft plans takes a significant amount of time that a 45-day comment period cannot accommodate. First, NCRC and our member organizations wishing to comment must develop their responses to provisions in lengthy draft DTS plans. Then NCRC and our members hold conference calls to further flesh out and revise our opinions. A minimum of a month to a month and a half is needed for this process. This is followed by drafting comment letters and reviewing them, which takes at least another month. In order for FHFA to receive thoughtful input from coalitions like NCRC, a comment period must be a minimum of 60 days.

NCRC is just one example of the thousands of stakeholders that would want to review DTS plans, both organizations that are involved in coalitions as well as interested members of the public that are not formally in coalitions. The FHFA seeks to solicit input from a wide variety of organizations ranging from community-based organizations, public sector agencies, to primary lending institutions and their trade associations. Moreover, several organizations located in rural and other underserved areas have less access to the internet and the policy milieu based in Washington DC. To more fully solicit the views of communities that are the intended targets of DTS plans, the FHFA must provide a 60-day comment period. The FHFA itself must undertake strenuous efforts in outreach and information sessions that are better accommodated by a 60-day comment period.

The FHFA is proposing a six-month period for the development and revisions of draft DTS plans. Increasing the public comment period from 45 to 60 days would not interfere with achieving a six-month development period and would benefit the plans by generating more insightful suggestions for improving their effectiveness in reaching underserved markets.

After plans are finalized, the FHFA must ensure that the GSEs implement them faithfully by instituting effective monitoring processes. The first step is to widely disseminate GSE annual reports in which the GSEs report on their progress in achieving the DTS plan goals. NCRC supports the FHFA proposal to require the GSEs to place their annual reports on their websites.[23] However, we urge the FHFA to widely publicize when the GSEs do this, and to encourage the public to review the plans. The FHFA should hold information sessions on the annual reports and receive public comments regarding GSE performance.

The FHFA proposes deleting publication of quarterly data by the GSEs as redundant.[24] NCRC does not agree with the assertion that such reporting is onerous since the GSEs must routinely collect data. A potential compromise is to require reporting halfway through the year in addition to the annual report. Thus, the GSEs would report data twice a year instead of four times. The FHFA should make the six-month data publicly available. This would increase the chances of GSE goal attainment by increasing the public accountability of the GSEs.

Increasing public accountability would have an additional benefit of making the GSEs increase their efforts at achieving plan goals and lessen their habit of seeking plan modifications during the year when they realize they will not meet their annual or three-year plan goals. The FHFA proposes to reduce the tendency of GSEs to request frequent plan modifications (about 15 modification requests annually for each GSE) by establishing a higher bar for modification requests. The FHFA proposes that it would grant modification requests only in response to special circumstances such as “significant market disruptions” or a “systematic financial crisis.”[25]

As well as supporting the FHFA tightening of plan modifications to avoid DTS plan manipulation, NCRC reiterates our suggestion that the plan term be two years instead of three years. A three-year plan presents difficulties for goal attainment because economic forecasting used for GSE goal establishment is more uncertain for three-years than two-years in the future. In addition, two-year plan cycles create more opportunities for public comment, engagement, and partnership building with the GSEs.

The FHFA itself understands challenges of a three-year planning cycle. It states, “However, FHFA recognizes the difficulty in projecting loan purchase targets up to three years in the future.”[26] Instead of contemplating “narrow” GSE loan purchase modification requests in the fourth quarter of the prior year for the next year, the FHFA should instead institute a two-year DTS plan requirement.[27]

New Evaluation System and Ratings Likely to Inflate Performance and Result in Reduced DTS Activities

The FHFA proposes to discard the current ratings for evaluating compliance with GSE DTS plans and replace them with an under-developed ratings system that in its proposed form would probably lead to ratings inflation. If not bolstered, the proposed ratings system would result in reduced GSE financing of rural housing, manufactured housing, and preservation of the low- and moderate-income housing stock.

The FHFA is correct in assessing that the current rating system is confusing. The difference between impact and concept scores under the current rating system is baffling for stakeholders. However, the point system corresponding to the current ratings allows for more gradations in ratings and more transparency in depicting differences in performance. NCRC therefore urges the FHFA to retain a point system for its proposed ratings.

The Proposed Five Ratings are Needed for a Rigorous Scoring System

The FHFA proposes establishing a ratings system from 1 to 5 with 1 indicating the best performance and 5 indicating the worst performance. The FHFA asserts the proposed numerical ratings system is consistent with CAMELSO, the rating system used by the FHFA for other compliance exams and consistent with compliance exams for banks.[28] NCRC approves of the five ratings because they are better able to reveal gradations in performance than the four ratings on CRA exams (in contrast, the component tests on CRA exams have five ratings which are more revealing of distinctions in performance). However, NCRC also urges the FHFA to assign words to each of the numerical ratings such as the CRA component test ratings of Outstanding, High Satisfactory, Low Satisfactory, Needs-to-Improve, and Substantial Noncompliance. The public has a better understanding of words than numbers for ratings.

NCRC supports the FHFA proposal that the two worst numerical ratings, not just the worst rating, indicate failure of the exam. As the FHFA states:

FHFA believes that the Enterprises have now had ten years of experience with developing and implementing Plans, such that performance previously justifying a Minimally Passing should not, in the future, be deemed as complying with the Duty to Serve. FHFA does not intend the Enterprises to target “minimal” performance; it intends the Enterprises to provide meaningful support to the underserved markets.[29]

These assertions are correct since the GSEs have had a decade of experience with DTS plans. Moreover, banks are subjected to failure on CRA exams if they receive one of the two worst ratings, not just if they receive the worst rating. This proposal would help level the playing field among banks and the GSEs by expecting the GSEs to achieve ratings that more accurately reflect compliance with DTS requirements.

Proposed Activities for Evaluating GSEs are Flawed and Subjective

The FHFA proposes to assign a rating for each of the three DTS underserved markets (rural, manufactured housing, and affordable housing preservation), based on how the GSEs perform on each of the required activities. The activity categories include current activities, which are loan purchases, loan product development, investments and grants, and outreach.[30] The current activities are clear and can be readily evaluated and rated.

However, the FHFA proposes adding two more activities, program requirements and program management, that are not well defined and would probably lead to ratings inflation. Program requirements, according to the proposed rule, regards the “effort and execution” of the GSE to meet the DTS requirements.[31] The proposal does not provide any further explanation of how effort and execution would be measured, which suggests that judging this activity could be subjective and arbitrary. Assessing effort is also redundant since the outcomes under the four existing activities such as loan purchases is the best way to measure effort. If a GSE does not meet loan purchase targets, for example, it merits a low rating. There is no reason to assess a GSE’s effort in addition to achievements under the existing activities.

Likewise, the FHFA intends to assess program management by evaluating the extent to which a GSE’s board and senior staff are involved in the DTS programs.[32] Evaluating program management is redundant because the performance under the existing activities suggests the extent to which the board and management are involved. It is unlikely that a GSE could meet its loan purchase goals if the board and senior staff are not involved in the DTS program. The results on the loan purchase activity would speak for itself, suggesting the program management activity is unnecessary. It is possible that if a GSE is performing poorly under the existing activities, the FHFA could use subjective judgements under program requirements and management to artificially boost a rating to one of the passing ratings. Alternatively, if the FHFA is not favorably disposed towards the GSEs for some reason, good performance on the existing activities could be dragged down by unfairly harsh judgements on these proposed subjective activities. The possibilities of exam manipulation should be eliminated by not adopting the program requirement and management activities.

The last proposed activity is any additional activity that the FHFA judges worthy of evaluating. The FHFA would add any new activity in the year prior to the first year of a DTS plan.[33] The proposal is unclear about when the agency would add an activity. The GSEs need ample lead time regarding the activities under which they will be evaluated so they can adequately develop their DTS plans. A lack of clarity regarding when the agency would adopt additional activities makes this proposal flawed. Furthermore, the additional activity option could introduce exams that evaluate a different range of activities in different time periods, making it difficult to judge whether the GSEs are improving over time in their DTS activities.  In the history of either DTS, Affordable Housing Goals, or CRA exam for banks, NCRC is not aware of criteria being added to exams at any time outside of a rulemaking process involving public comment periods. The FHFA must not implement this potentially arbitrary feature to DTS evaluations.

NCRC not only urges the FHFA to refrain from adding new activities but also should assign weights to the existing activities. Loan purchases are the most important activity since purchasing loans from primary market lenders and providing more resources for lenders to make more loans is the reason why the GSEs exist. Accordingly, loan purchases should be weighted at 50 percent.

Loan product development is also important because without continual innovations in underwriting and assessing borrower creditworthiness, the GSEs will not adapt to changes in the primary market and cannot be as effective in purchasing loans. Accordingly, a weight of 20 percent is appropriate for this activity. Twenty percent would also be appropriate for investments and grants because this activity builds an infrastructure for making loans. Grants support housing counseling agencies that produce creditworthy borrowers. Similarly, housing-related investments build and maintain the housing stock which ultimately generates more lending opportunities.

Finally, outreach is important but would be weighted less at 10 percent. If a GSE is not performing outreach to find banks, non-bank lenders, nonprofit community-based organizations, and public sector entities with which to do business, it will not be successful under the loan purchase activity. Therefore, outreach would be a natural byproduct of needing to excel on loan purchase activity. GSEs wishing to do well on their DTS evaluations would automatically engage in rigorous outreach, which does not therefore need as high a weight for motivating the GSEs to engage in this activity.

A Lack of Standards for Judging GSE Activity Performance Likely to Inflate Ratings

The proposal to create two ratings indicating failure is seriously undercut by a lack of standards for assessing how GSE performance corresponds to the proposed ratings. The proposed standards for awarding the ratings to various activities are subjective and unclear. For example, the FHFA states that “A rating of “1” could be achieved if the Enterprise demonstrated exceptional leadership in the market in developing loan products and flexible underwriting guidelines to facilitate a secondary market for mortgages for very low-, low-, and moderate-income families in the underserved market.”[34] The key words, “exceptional leadership,” are not defined. Would the leadership be exceptional if the loan product development was judged to be more innovative, flexible, and responsive compared to the other GSE or to the other GSE and primary lenders, for instance. The proposal lacks benchmarks for creating objective judgments and ratings.

The lack of benchmarks is a pressing issue for the loan purchase category. There is no reason why benchmarks could not have been proposed similar to benchmarks used on CRA exams. For rural housing, for example, a performance measure such as the percentage of purchases that qualified as rural purchases could have been developed and this percentage could have been compared to the other GSE and the primary market. Another comparison also could have been a demographic benchmark such as the percentage of households or homeowners that reside in rural areas. Alternatively, a benchmark measuring loans per household in rural areas could have been developed and compared against the other GSE and the primary market. A rating of “1” could have been assigned if a particular GSE’s performance based on an objective benchmark exceeded the other GSE and the primary market. A rating of “2” could have been awarded if the particular GSE was better than the other one and was at least comparable to the primary market on the benchmark. Further guidelines for the other ratings could also have been developed by comparing the GSEs to industry peer and demographic benchmarks.

Other benchmarks for judging performance could include objective comparisons with GSE past performance. Under the loan purchase category, for example, is the GSE DTS plan committing the GSEs to increasing their loan purchases compared to past performance and did the GSE achieve these increased loan purchases?

Another problematic aspect of the proposed rule is that there is no standard for determining how many component ratings would correspond to the overall rating. For instance, the proposed rule says that to achieve a “1,” a GSE would need to have a “1” rating for most components of a DTS market.[35] The proposal could have eliminated the ambiguity surrounding the word “most” by proposing a certain percentage of the component ratings would need to be a “1.” NCRC submits that to receive the highest rating, the GSE must have the highest rating on at least 60 percent of the component tests and preferably 70 percent. A similar grading system should have been developed for the other overall ratings.

The FHFA must not finalize this proposed rule without developing benchmarks and standards for evaluating GSE performance. The FHFA should either re-propose this rule or propose guidance subject to public comment that contains objective standards for assigning ratings. If the FHFA does not take these steps, the public does not have an objective means for assessing whether this proposed rule would enhance or worsen GSE compliance with their DTS obligations.

Annual Dissemination of Ratings

NCRC approves FHFA’s proposal to codify the publishing of DTS market ratings in its annual report. It is also positive that the FHFA is proposing to produce narrative describing GSEs’ performance.[36] The narrative should guide readers to assessing strengths and weaknesses in the GSEs’ performance. NCRC suggests that the narrative would be more interactive if it also published substantive public comments received by the GSEs or FHFA during the year and the GSEs’ response to those comments.

Conclusion

While the FHFA proposes reforms that would bolster the importance of public comments and accountability, other proposed changes would overwhelm the positive proposals and result in more subjective DTS exams. The totality of the changes would probably reduce the amount of GSE financing of housing in rural areas, manufactured housing, and preservation of the affordable housing stock. The FHFA proposes that the two worst ratings instead of just the worst rating would cause a GSE to fail its exam. This would provide a significant incentive to improve performance but is undercut by a lack of objective performance measures and benchmarks, and too much discretion for the GSEs to choose the activities against which they would be evaluated.

Likewise, it is commendable that the FHFA proposes to require the GSEs to respond thoughtfully to substantive public comments on draft plans and reduce exam manipulation by decreasing permissible modifications to DTS plan goals. Again, however, these positive proposals are undermined by relaxed requirements to target and verify that regions and borrowers with the lowest incomes and most pressing needs are the focus of DTS plans.

On balance, if the FHFA does not make significant changes to its proposed rule, future GSE financing of DTS market needs will decrease. These harmful outcomes would be driven by the proposals that would decrease the focus on the communities with pressing needs, increase the subjectivity of exams, and provide too much discretion to the GSEs for choosing activities for the DTS evaluations in place of a public process for choosing activities for evaluation. The FHFA must not finalize a rule that would make it too easy for the GSEs to label their activities for mainstream markets as those for DTS markets. This would result in the GSEs not adhering to the “but for” maxim in that if it were not for the GSE financing, the DTS markets would continue to be underserved.

Thank you for the opportunity to comment on this important matter. If you have any questions, you can email me on jvantol@ncrc.org or Josh Silver, Senior Fellow and author of this comment, on endredline77@gmail.com.

Sincerely,

Jesse Van Tol
President and CEO
National Community Reinvestment Coalition

 

[1]12 U.S. Code § 4565 – Duty to serve underserved markets and other requirements, Cornell Law School, Legal Information Institute, https://www.law.cornell.edu/uscode/text/12/4565
[2] Federal Housing Finance Agency (FHFA), Notice of Proposed Rulemaking (NPR), Enterprise Duty to Serve Underserved Markets, RIN 2590–AB64, Federal Register, Vol. 91, No. 120, Wednesday, June 24, 2026, p.  37850
[3] FHFA, NPR, 37852
[4] FHFA, NPR, 37852
[5] FHFA, NPR, 37853
[6] UNC Center for Community Capital, Home Energy Efficiency and Mortgage Risks, March 2013, https://imt.org/wp-content/uploads/2018/02/IMT_UNC_HomeEEMortgageRisksfinal.pdf, p. 1
[7] U.S. Department of Energy, Weatherization Assistance Program, https://www.energy.gov/cmei/scep/wap/weatherization-assistance-program
[8] Review of CRA ratings and types of exams accessed on July 3, 2026 on website of the Federal Financial Institutions Examination Council, https://www.ffiec.gov/data/cra/ratings
[9] FHFA, NPR, 37865
[10] FHFA, NPR, 37865
[11] FHFA, NPR, 37865
[12] FHFA, NPR, 37872.
[13] FHFA, NPR, 37855
[14] FHFA, NPR, 37855
[15] Dave Castillo, Bruce C. Mitchell, Jason Richardson, Jad Edlebi, Redlining The Reservation: The Brutal Cost Of Financial Services Inaccessibility in Native Communities, NCRC, December 23023,  https://ncrc.org/wp-content/uploads/2023/11/Tribal-Lands-Report-v14.pdf
[16] FHFA, NPR, 37853
[17] FHFA, NPR, 37854
[18] FHFA, NPR, 37858
[19] FHFA, NPR, 37856
[20] FHFA, NPR, 37858
[21] FHFA, NPR, 37858
[22] FHFA, NPR, 37859
[23] FHFA, NPR, 37861
[24] FHFA, NPR, 37861
[25] FHFA, NPR, 37859
[26] FHFA, NPR, 37860
[27] FHFA, NPR, 37860
[28] FHFA, NPR, 37862
[29] FHFA, NPR, 37862
[30] FHFA, NPR, 37862
[31] FHFA, NPR, 37862
[32] FHFA, NPR, 37862
[33] FHFA, NPR, 37862
[34] FHFA, NPR, 37863
[35] FHFA, NPR, 37863
[36] FHFA, NPR, 37863

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2026 NCRC Mortgage Market Series — Part 1: A Stagnant Mortgage Market: A Shrinking CRA https://ncrc.org/2026-ncrc-mortgage-market-series-part-1-a-stagnant-mortgage-market-a-shrinking-cra/?utm_source=rss&utm_medium=rss&utm_campaign=2026-ncrc-mortgage-market-series-part-1-a-stagnant-mortgage-market-a-shrinking-cra Thu, 16 Jul 2026 14:00:38 +0000 https://ncrc.org/?p=289355

This is the first part in NCRC’s 2026 Mortgage Market Series. Subsequent articles will examine lending by race and ethnicity, by neighborhood, across cities, in Native American and Hawaiian communities, in the down payment assistance market and among the largest lenders.

Buying a home is still the main way most American families build wealth. It is also one of the largest financial decisions a household will make, ultimately shaping where people live, where their kids go to school and what their finances look like for decades to come.

For three years in a row, the number of families buying homes has remained the same at about 2.9 million. This is a warning sign. Homeownership is fundamental to how Americans build wealth, and it has always been plagued by unequal access. For decades, housing policy has sought to expand homeownership to all Americans on an equal basis.

If we want to see homeownership continue to grow among people traditionally excluded from this path to building wealth, we need to see growth in the number of home purchases. Instead, the number of purchase loans remains frozen in place, with the people who can still afford to buy being increasingly limited to people that already have substantial wealth.

The market is not just stuck, but is changing in ways that further limit the ability of families to transition from renting to ownership. The mix of lenders inside are also changing in ways that will have consequences for those families and neighborhoods most likely to be left out. In 2025, banks made less than a third of the home purchase loans in America. Mortgage companies, which do not take deposits and have no physical branch locations, made almost two-thirds.

The Community Reinvestment Act that was passed in 1977 to push banks to lend in the lower-income and historically excluded neighborhoods where they take deposits applies only to banks. The lenders making most of the home purchase loans in 2025 have no such obligation.

Jason Richardson, Senior Director of Research

Resources

For the complete series, including videos, interactive visualizations and localized market analysis, visit our 2026 Mortgage Market series homepage. 

NCRC uses AI tools to assist with data processing, query development and report drafting. NCRC maintains full responsibility for the accuracy of all published analyses.

For customized community data requests or inquiries about membership benefits contact Ralph Cyrus (Membership Engagement Specialist) at rcyrus@ncrc.org.

Key Takeaways

1

Home purchase originations held flat for a third straight year at about 2.87 million in 2025, 35% below the 2021 peak of 4.42 million, with none of the rebound that a normal market produces after a downturn.

2

Banks originated 30.1% of home purchase loans in 2025, down from 42.5% in 2018. Mortgage companies originated 64.2%, up from 44.6% over the same period.

3

The home purchase denial rate held steady at about 7%. But, the denial reasons have shifted away from credit score and other reasons and directly toward reasons that are related to affordability. Debt-to-income was cited in 42% of denials in 2025 – up from 35% in 2021 – as higher rates and prices pushed the same borrowers into higher debt-to-income bands.

4

Banks’ lending to nondepository financial institutions, the channel that funds nonbank mortgage companies, increased. Since 2018 this lending has tripled from $417 billion to $1.4 trillion, concentrated among the largest banks.

Applications and Originations

Lenders received 13.5 million applications in 2025. That is up modestly from the 2023 low but is still a 48% drop from the 26.2 million filed in 2021, when rates were at historic pandemic lows.

The chart below shows the total number of mortgage applications for the 2021 through 2025 period broken into three outcomes: originated, denied and fallout. The fallout category combines the number of applications the borrower withdrew, applications that were closed because the paperwork was never completed and applications that were approved but were not accepted by the borrower.

The collapse from 2021 to 2023 was driven mostly by refinancing. Mortgage rates roughly doubled over those two years, from around 3% to around 7%. Refinance applications fell by about two-thirds when rates rose because refinancing only saves money when the new rate is lower than the existing one, and most homeowners are now locked in well below current rates. Refinance volume is now recovering modestly as borrowers adjust. Home purchase applications fell less sharply, by about a third, but have not recovered at all.

Home purchase loans declined less than refinances but have remained flat since 2023. Originations haven’t changed much in number or when it comes to the overall share of applications, meaning that we aren’t seeing a tightening of credit. Instead, the number of people applying for loans is staying stagnant.

The chart below shows the number of home purchase applications reported by lenders for each year along with the outcome of the application (origination, denial or fallout), including reasons such as borrower withdrawing from the process, declining the lender’s offer or other reasons:

A normal housing market would produce a rebound two years after a decline. Traditionally, higher prices and rates drive buyers from the market. Then, prices adjust and buyers come back. Home purchase lending has not come back. The number of applications has held flat, with the mix of denials, originations and fallouts barely shifting across that time period. Each year, roughly the same share of loans is originated, denied, withdrawn or left incomplete.

The data we have describe only the people who reach the point of applying for a loan, and that pool is shrinking at the front end. Would-be buyers who can see they cannot afford today’s prices and rates increasingly do not apply at all, so the applicants who remain are tilted toward those who already have money. Incomes have risen, but home prices and interest rates rose faster, and the buyers who cannot cover the larger down payment and monthly cost are simply absent from the data.

That selection is the quieter force behind a flat market, and it matters more given who is doing the lending. Banks have pulled back from originating mortgages directly to buyers, and nonbank mortgage companies have taken their place, lenders that carry no obligation under the Community Reinvestment Act to serve lower-income borrowers. As the cost of buying climbs and the buyer pool narrows to those who can absorb it, the lenders gaining ground have the least reason to chase the lower-income families the law was built to reach.

The chart below shows the originations that were made during the 2021 through 2025 period broken into five categories: home purchase, refinance, cash-out refinance, home improvement and home equity:

Rates of refinance lending have rebounded modestly in 2025, although it remains much lower than the lending in 2020 and 2021. Home equity and home improvement lending have held steady. Home purchase lending has held at about 2.9 million originations per year for three years running, with no sign of recovering. Three years at this volume is where we can safely call it a trend. It is indicative of a market that has adjusted to higher rates and higher prices and shows no signs of changing its direction.

The Role of the Debt-to-Income Ratio

The applicants who do file are running into a different set of pressures than the ones who applied four years ago, and the same applicant now looks riskier to a lender than they would have then, largely because of the rate environment. The clearest single measure of that pressure is the debt-to-income ratio. Debt-to-income, or DTI, is the share of a borrower’s gross monthly income that goes to debt payments, including the proposed mortgage plus credit cards, car loans, student loans and other monthly obligations. Lenders treat it as a primary measure of whether a borrower can afford to take on a mortgage, and the lower the ratio, the more comfortable the lender is with the loan.

The chart below shows the rates of home purchase applicants distributed across four DTI bands in 2021 and 2025 separated by whether the loan was originated or denied:

The share of originated home purchase loans where the borrower’s DTI was in the safest band, under 36%, fell by 11 percentage points. The share of loans with a DTI above 50% – the territory where most lenders will not write a conventional loan without compensating factors – grew. This same pattern appears more sharply on the denied loan applications side. Among denied applications, the share above 50% DTI rose to nearly half.

A buyer in 2025 borrowing $400,000 at a 7% rate faces a monthly principal and interest payment of about $2,660. The same loan in 2021 at 3% would have carried a payment of about $1,690. That is nearly $1,000 more per month for the same loan amount, on top of higher home prices over the same period. The same income now stretches less against the cost of buying a home today.

This does not mean lenders relaxed their standards. It means rising rates and rising home prices pushed the same kind of borrower into a higher DTI band than they would have been in when rates were lower. A buyer who would have qualified comfortably four years ago is now struggling to get a loan with the same income.

The Reasons Borrowers are Getting Denied has Changed

When a lender denies a home purchase application, they record up to four reasons. The home purchase denial rate has held steady at about 7% across the period. What has changed is the mix of reasons lenders are citing.

In 2021, DTI was listed as a reason in 35% of denied home purchase applications. By 2025, that share had climbed to 42%. This is the same trend visible in the DTI distribution chart above. Applicants across the board have higher DTI ratios. When more applicants are pushing into the high-DTI territory of the application pool, more denials cite DTI as the reason. A recent Federal Reserve Bank of St. Louis study of more than 30 million home purchase applications found that when interest rates spiked in 2022 and 2023, more people were denied because the higher monthly payments pushed their debt too high relative to their income.

The other denial reasons in the chart fit the same pattern. Insufficient cash for the down payment and closing costs grew from 8% of denied applications in 2021 to 12% in 2025. Borrowers can have the income to support a mortgage and still fail to assemble the cash needed to close on a home at today’s prices. The other denial reasons showed little change over the time period. Lenders are not denying borrowers for creditworthiness as much as they used to. They are citing affordability as the biggest barrier that today’s homebuyers face.

Banks are Leaving Home Purchase Lending and the CRA is Leaving with Them

The most consequential shift in the 2025 home purchase market is not how many loans are getting made. It is who is making them. Banks originated about 30% of home purchase loans in 2025, down from more than 40% in 2018. Mortgage companies, which do not take deposits and have no physical branches, now originate almost two-thirds of the market.

The chart below shows that shift across the full period:

Lender type matters because the federal framework that governs mortgage lending was built around banks. The Community Reinvestment Act (CRA) is the government’s primary tool for ensuring mortgage credit reaches communities that have been historically underserved. The CRA only applies to banks, not mortgage companies or credit unions. In return for deposit insurance and federal support, a bank accepts an obligation to serve its whole community, while a non-bank mortgage company takes on no such duty. As banks make up a smaller share of the home purchase market, the share of lending subject to any community service obligation shrinks along with it.

The way that banks participate in the mortgage market has changed. Report data show that as banks have made fewer home loans, their lending to nondepository financial institutions, the channel that funds the nonbank mortgage companies, has grown. This kind of lending by banks has more than tripled between 2018 and 2025, from about $417 billion to $1.4 trillion. The shift is concentrated among the largest banks. Even as banks step back from mortgage lending, they remain deeply tied to the mortgage market and increasingly finance lenders that carry no such obligation.

The federal response to this gap has been stymied for years, with the financial sector resisting any requirements that mandate them to consider the credit needs of the community. In October 2023, federal regulators finalized a long-overdue update to the CRA rules that would have, among other things, evaluated large banks on their lending performance outside of their branch networks, which is where a growing share of bank lending actually happens. Unfortunately, the 2023 rule never took effect.

Methodology

This analysis uses data from the Home Mortgage Disclosure Act (HMDA) modified Loan Application Register (LAR) for the 2018 through 2025 period, which was released by the Consumer Financial Protection Bureau (CFPB) on March 31, 2026 as the Modified LAR. Since this analysis began the CFPB has released the final snapshot file. NCRC has determined that the differences between the modified LAR and the snapshot are minor and no relevant to this analysis.

Resources

For the complete series, including videos, interactive visualizations and localized market analysis, visit our 2026 Mortgage Market series homepage. NCRC members can request customized community data requests as well. Those interested in membership benefits should contact Ralph Cyrus (Membership Engagement Specialist) at rcyrus@ncrc.org.

Mortgage Market Series

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The Data Behind the Lending Landscape: Why Engaging Regional Financial Institutions Matters https://ncrc.org/event/the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matters-2/?utm_source=rss&utm_medium=rss&utm_campaign=the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matters-2 Wed, 15 Jul 2026 17:00:00 +0000 https://ncrc.org/?post_type=tribe_events&p=289144

July 15 , 1:00 pm EDT – 2:00 pm EDT

As federal budget cuts create headwinds for affordable housing and community development projects, local nonprofits and coalitions may want to look to data, relationship-building and regional financial institutions to move projects forward. Using Metro Nashville as a case study, NCRC’s Jason Richardson will illustrate how mortgage lending evolved over the past four decades and where it took place last year. He will close by analyzing community development lending in Music City as well. Oscar Perry Abello, author of The Banks We Deserve, will then reveal how the data shows that regional and community banks are responsible for 73% of construction and development lending from banks and what that means for nonprofits, CDCs and CDFIs seeking local investment partners. Citizens Savings Bank & Trust Company’s Chief Operating/Credit Officer Corey Hammonds will provide a candid look at how banks evaluate community development projects today, including what helps proposals gain traction and what causes institutions to walk away. Together, community leaders will see how data will help them better understand today’s lending landscape, identify where opportunity still exists and strengthen their approach to engaging financial institutions in a rapidly changing environment. NCRC member Monchiere’ Holmes-Jones, CEO and Chief Impact Officer at MOJO Impact Collective, will moderate the session.

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The Data Behind the Lending Landscape: Why Engaging Regional Financial Institutions Matters https://ncrc.org/event/the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matters/?utm_source=rss&utm_medium=rss&utm_campaign=the-data-behind-the-lending-landscape-why-engaging-regional-financial-institutions-matters Wed, 15 Jul 2026 17:00:00 +0000 https://ncrc.org/?post_type=tribe_events&p=289138

July 15 , 1:00 pm EDT

As federal budget cuts create headwinds for affordable housing and community development projects, local nonprofits and coalitions may want to look to data, relationship-building and regional financial institutions to move projects forward. Using Metro Nashville as a case study, NCRC’s Jason Richardson will illustrate how mortgage lending evolved over the past four decades and where it took place last year. He will close by analyzing community development lending in Music City as well. Oscar Perry Abello, author of The Banks We Deserve, will then reveal how the data shows that regional and community banks are responsible for 73% of construction and development lending from banks and what that means for nonprofits, CDCs and CDFIs seeking local investment partners. Citizens Savings Bank & Trust Company’s Chief Operating/Credit Officer Corey Hammonds will provide a candid look at how banks evaluate community development projects today, including what helps proposals gain traction and what causes institutions to walk away. Together, community leaders will see how data will help them better understand today’s lending landscape, identify where opportunity still exists and strengthen their approach to engaging financial institutions in a rapidly changing environment. NCRC member Monchiere’ Holmes-Jones, founder of MOJO Marketing and founder and board chair of Jefferson Street Historical Society, will moderate the session.

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NCRC Analysis of the CFPB’s Section 1071 Rule of 2026 https://ncrc.org/ncrc-analysis-of-the-cfpbs-section-1071-rule-of-2026/?utm_source=rss&utm_medium=rss&utm_campaign=ncrc-analysis-of-the-cfpbs-section-1071-rule-of-2026 Wed, 10 Jun 2026 15:14:49 +0000 https://ncrc.org/?p=289010

NCRC Analysis of the CFPB’s Section 1071 Rule of 2026

June 2026

Josh Silver, Senior Fellow

Introduction

As part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, Section 1071 mandated the collection of several data points associated with small business lending. These include demographic data and data on loan characteristics and actions. The purpose of the data collection according to the text of Section 1071 was to “facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses.”[1]

To achieve these statutory purposes, the Consumer Financial Protection Bureau (CFPB) promulgated a rule implementing Section 1071 in 2023 that would have required collection and dissemination of robust data. Section 1071 required the collection of data on the characteristics of the small business loan applicant, including the race and gender of the owner(s) as well as loan characteristics and actions, such as approval or rejection. In addition to the data collection required by the statute, Section 1071 provided the CFPB with the discretion to collect additional data points that would further the purpose of the statute.

Using the discretionary authority under Section 1071, the CFPB in its 2023 rule added pricing information and more characteristics of the small businesses, including the number of years in existence and the number of employees. In its 2026 rule, the CFPB retained the mandatory data points but deleted most of the discretionary data points. This will impair the ability of the Section 1071 data to achieve the fair lending and community development purposes of Dodd-Frank. For example, the pricing data combined with more information on the characteristics of the small businesses would have provided insights into whether businesses that are similarly situated except for when the gender and/or race of the owners were treated the same in terms of price and access to loans.

Rationale for the 2026 Rule’s Reduction in Data is Flawed

The CFPB’s 2026 rule maintained that the purposes of Section 1071 were best achieved by a lean database with relatively few data points that were well-defined and could be collected readily by lenders. According to the CFPB, “at the onset of a potentially long-term data collection regime, it should start with more modest requirements, focusing on core lending products, lenders, and data.” The agency stated further that “a longer-term approach to advance the statutory purposes of section 1071 is to commence the collection of data with a narrower scope to ensure its quality and to limit, as much as possible, any disturbance of the provision and availability of credit to small businesses. The statutory purposes of the rule are not well served by an expansive rule that could create disruptions in small business lending markets.”[2]

Throughout the preamble of the 2026 rule, the agency raised concerns about the expense of collecting several data points and suggested that the cost would be so high that lenders would reduce the volume of their small business lending. The agency pointed to the experience of the collection of Home Mortgage Disclosure Act (HMDA) data to support its position that it was best to start with modest data collection and then incrementally add more data over several years.

As NCRC maintained in its comment letter, the analogy with HMDA is not applicable. Congress passed HMDA in 1975 when computing power was considerably less sophisticated than it is today. Hence, the Federal Reserve Board, the agency implementing the HMDA regulation for several years, adopted an incremental approach. For example, the Federal Reserve introduced pricing information in the early 2000’s, more than 25 years after Congress passed HMDA.

In the implementation of Section 1071, lenders and the CFPB can learn from the HMDA experience to more readily implement similar data points concerning pricing and loan characteristics. More sophisticated data software should facilitate data collection that could not be as easily executed in the 1970s, or even the 1990s.

The CFPB’s own estimates of cost in the final rule suggests that lenders will not confront such high costs that they will need to significantly reduce their lending. After the reductions in data collection instituted by the 2026 rule, the CFPB calculated that lenders would save just $1 to $8 per application, depending on their loan volume.[3]  Under its 2023 rule, the CFPB estimated that per application ongoing costs ranged from $8 to $34, depending on the number of loans issued by the lender.[4] Comparing the original CFPB estimates for the per application costs with the savings in the 2026 rule illustrates that overall data collection costs are small and the savings achieved by reducing the data collection are even smaller. This casts doubt regarding the agency’s central rationale that reducing data and costs would avoid reductions in lending.

A rationale for a comprehensive Section 1071 database was to save costs for banks by deleting their requirements to submit small business and small farm lending data required under the regulations implementing the Community Reinvestment Act (CRA). For banks that had reporting requirements under Section 1071, the 2023 final rule relieved them of data reporting responsibilities under the CRA. After replacing the 2023 rule with the 2026 rule, the CFPB reinstated data reporting under the CRA and Section 1071 for these banks. For these lenders, the duplicative reporting requirements are likely to eliminate the modest savings achieved by the 2026 rule’s paring back of Section 1071 data.

The same logic would apply to Farm Credit System (FCS) lenders. If the Farm Credit Administration (FCA) had worked with the CFPB to eliminate or reduce FCA data reporting requirements, the FCS lenders would have reduced their costs. Capturing their lending under Section 1071 would have been preferable to a separate FCA database since data users could more readily compare their lending to other agricultural lenders. Instead, by deleting FCS lenders from the Section 1071 data, the CFPB missed an opportunity to reduce costs for FCS lenders and to establish a more comprehensive database.

Reduction in Number of Lenders and Loans Compromises the Section 1071 Data

A detrimental aspect of the CFPB’s 2026 rule was eliminating data reporting for thousands of lending institutions by exempting lenders that issued less than 1,000 loans annually. The previous threshold was 100 loans in the 2023 rule. Under the 2023 rule, the CFPB estimated about 1,700 depository institutions would have been covered, or approximately 17 percent of such institutions (banks, thrifts and credit unions).[5] After implementation of the 2026 rule, only 181 depository institutions, or just about 2 percent of all depository institutions, remain covered.[6] For context, approximately 4,279 banks and thrifts conduct business in the United States.[7]

The rule would also result in miniscule coverage of credit unions. The CFPB estimated that only 5 credit unions would be covered, or one tenth of one percent, of all credit unions under the 2026 rule.[8] Likewise, the reductions in the number of non-depository institutions reporting are steep. The 2026 rule reduced the number of non-depository institutions reporting data from about 610 to 31.[9]

The CFPB justified the reduction in the number of lenders by asserting that more than 90 percent of depository institutions’ lending would still be covered.[10] A critical aspect of the new rule, according to the CFPB, was that core lenders responsible for most lending activity were still covered. In contrast, the smaller lenders that would face the most costs were now exempt. However, the estimated costs were small for all lenders as discussed above.

In addition, as described in more detail below, the CFPB’s estimate that 90 percent of depository institutions’ lending would be covered is probably a considerable overestimate. Nevertheless, justifying a rule that will obscure lending trends in several counties across the country by asserting that most lending is still covered is disingenuous. One of the major purposes of the statute is to reveal whether community needs for credit are being met. A rule that does not facilitate investigation into credit needs for several geographical areas is not consistent with the purposes of the statute. 

Moreover, the concept of core lenders is misapplied. For smaller metropolitan areas and rural counties, the smaller lenders that the agency may not consider “core” lenders are quite important because small businesses rely upon them for service. Smaller banks excel at small business lending because they have firsthand knowledge of small businesses and have unique insights into judging their creditworthiness that quantitative underwriting used by larger lenders may lack. Exempting them from reporting data requirements misses a critical part of the market in medium size and smaller communities and thus prevents the Section 1071 data from assessing whether community needs continue to be met in these communities. In fact, NCRC’s spatial analysis in our comment letter on the proposed 2026 rule showed that counties experiencing sizable reductions in the percentage of reported loans (of at least 20 percent of loans issued in 2024) were clustered in the Midwest, mountain states and Appalachia.[11]

The CFPB itself acknowledged that under its 2026 rule, “25 percent of rural depository institution branches and about 63 percent of non-rural depository institution branches would be covered under the proposed rule (finalized in 2026). Under the baseline (in the 2023 rule), the Bureau estimates that about 65 to 68 percent of rural depository institution branches and about 84 to 85 percent of non-rural depository institution branches are covered.” The loss of coverage in rural and smaller communities is significant as the agency itself acknowledged.[12]

This reduction in Section 1071 coverage was similar to the CFPB’s decision to reduce coverage under the Home Mortgage Disclosure Act (HMDA) data that was overturned in a court case. In ruling against the CFPB in 2022 in a case involving raising the HMDA threshold for reporting institutions from 25 to 100 closed end loans, Chief Judge Beryl A. Howell stated that “An agency acts arbitrarily and capriciously when it ‘entirely fail[s] to consider an important aspect of the problem,’ offers an explanation for its decision that ‘runs counter to the evidence before the agency.’”[13]

She further explained that “…rather than look to gross transaction numbers as CFPB does, plaintiffs’ focus on the financial institutions newly exempt is more probative of the impact of the 2020 Rule on the ability of regulatory agencies, policymakers and HMDA users to identify problematic home lending practices at a community level, in furtherance of the statute’s express goals.”[14] The same reasoning applies in this matter since Section 1071 of the Dodd Frank law stipulates that the data must further the objectives of fair lending and community development.

Exemption for Merchant Cash Advance and Agricultural Lending Obscures Important Parts of the Marketplace

Like the exemption of most lenders from reporting requirements, the exemption of significant types of lending prevents an accurate depiction of the lending marketplace. The 2026 rule, for example, deletes the requirement that Merchant Cash Advances (MCAs) be reported. MCAs are agreements under which a lender will provide an upfront lump sum to a small business in return for regular payments out of monthly small business receipts. As NCRC’s comment letter documented, MCAs are difficult for small businesses to understand, making them vulnerable to abusive lending.[15]

The CFPB acknowledged the growing role of MCAs in the marketplace, citing projections of almost $33 billion in MCAs by 2032.[16] The CFPB further stated that “The Bureau acknowledges the concern by some commenters that excluding MCAs may obscure risks to small business that use MCAs and reduce market transparency.”[17] Nevertheless, the CFPB decided that requiring the disclosure of MCAs could include some forms of MCAs that are not loans or closely resemble credit.[18] This rationale is unconvincing considering the several years the agency examined MCAs and had decided how to capture MCAs that were loans in the final 2023 rule.

The CFPB also employed a suspect rationale for excluding agricultural loans from Section 1071 reporting. It claimed that underwriting is so different for agricultural lending that it could not be meaningfully compared to non-agricultural lending. The agency stated, “Agricultural loans are often secured by biological-based assets, such as crops or livestock, which are subject to variables and risk from weather and disease. These characteristics create unique underwriting challenges that make such loans difficult to compare to those in other industries.”[19]

Yet, the CRA regulation has mandated reporting and disclosure of farm lending for decades. It is understandable for the public and analysts to separately consider farm lending since the data has a variable indicating whether the loan is farm lending or small business lending. The rationale concerning the difficulty of comparisons seems at best a minor difficulty, especially compared against the greater loss of data revealing whether underserved farmers, including minority or women farmers, are now receiving farm loans. Moreover, by exempting agriculture lending from Section 1071, the CFPB prevents the public from observing on a per application basis the demographics of the farms that banks are approving and rejecting for loans.  

In addition to exempting banks from reporting agricultural loans, the CFPB effectively exempted non-bank Farm Credit System (FCS) lenders from disclosure requirements although these FCS lenders are cooperatives and serve important market niches. As non-banks, FCS lending data does not appear in the CRA data. Nonetheless, they should not have difficulty reporting data since they are already required to do so by their regulator: the FCA.[20] However, the FCA does not make the data publicly available and does not report demographic information on a per application basis, which is what the Section 1071 data requires.[21] Overall, it is not sufficient to claim that CRA data provides a comprehensive picture of agricultural lending because the CRA data does not include FCS and other non-bank lenders that have important niches in the marketplace.

CFPB’s Definition of Small Business Reduces Loan Data by Up to Half

The CFPB further limited the usefulness of the Section 1071 database by its definition of small businesses, which results in even fewer loans being reported. The 2023 rule had defined a small business as one with up to $5 million in revenue. The 2026 rule reduced the revenue threshold to $1 million.

The CFPB disputed NCRC’s assertion that adopting a revenue threshold of $1 million would significantly reduce the size of the loan database. In our comment letter on the proposed 2026 rule, NCRC calculated that changing the threshold from $5 million to $1 million would reduce the number of loans in the Section 1071 database by about half over a several year period.[22] Challenging this assertion, the CFPB cited a study stating that existing CRA small business data excludes loans above $1 million and thus may omit several loans to the smallest businesses. Yet, the CFPB offered no reliable estimates of how many larger loans above $1 million went to businesses with revenues under $1 million and how many went to businesses with revenues between $1 million and $5 million.[23]

It is thus not possible to recalculate NCRC’s estimate that up to half the loans would be lost by the change in the definition of small businesses. It is unlikely, however, that a disproportionate number of loans greater than $1 million went to businesses with less than $1 million in revenue. Therefore, NCRC’s estimate probably would not change significantly if data on loans above $1 million were available. Even considering the study cited by the CFPB, a reasonable conclusion remains that the Section 1071 database would be significantly reduced by the changed definition of a small business. This means that the database would be less able to depict lending trends and outcomes to small businesses with various revenue sizes.

While the smallest businesses under $1 million are likely to be the most disadvantaged in the marketplace, it is likely that those with revenues between $1 million and $5 million also confront obstacles to credit. Disagreeing with this, the CFPB stated, “Businesses above that threshold ($1 million) are likely to be well capitalized and less likely to face undue barriers to credit, even if they may still be transitioning between early stages of growth, as some commenters assert.”[24] A NCRC study found that 35 percent of the businesses loan applicants with revenues between $500,000 and $1 million and 55 percent of the businesses with revenues between $1 million and $5 million received loans in Appalachia.[25] While approval rates are higher for businesses with more revenue, those with under $5 million in revenue still confronted a high denial rate of 45 percent. It would have been valuable to use the Section 1071 data containing information on businesses with up to $5 million in revenue size to assess whether the disparities in approval or denial rates for businesses with different revenue sizes narrow over time and, if not, what policy or programmatic steps could be undertaken to reduce the disparities.

Several Characteristics of Small Businesses and Pricing Data Eliminated

The CFPB’s decision to eliminate several data points concerning the characteristics of small businesses substantially limits the ability of the data to assess whether different subgroups of small businesses receive loans. These deletions will impair investigations into community needs and credit gaps. It will also frustrate fair lending analyses assessing whether businesses with similar characteristics – but under control of owners of various races and genders – have similar access to loans and receive similar fees and interest rates when approved for loans.

For example, the CFPB deleted disaggregated race and ethnicity categories. The 2023 final rule established subcategories for Hispanics, Asians, African Americans, Native Hawaiian and other Pacific Islanders. HMDA data for the disaggregated race and ethnicity categories has revealed fair lending concerns and significant differences in access to credit for racial and ethnic subcategories. With the CFPB eliminating these categories for the small business data, stakeholders will not be able to determine whether there are similar differences in access to credit for various racial and ethnic small businesses.

The CFPB claimed that loan applicants would be reluctant to disclose racial and ethnic subcategories.[26] However, studies on HMDA data submissions revealed that the subcategories were popular with loan applicants and were not onerous for lenders. A 2018 revision to HMDA allowed Latino, Asian, Hawaiian and Pacific Islander applicants to report more precisely on their country or place of origin. Among eligible 2021 applicants, over 60 percent utilized these optional fields to specify their identity.[27]

Other business characteristics deleted from the 2026 rule include the LGBTQ status of the small business owners and the number of workers in the small business.[28] These deletions will further diminish the ability of the data to access whether LGBTQ and the smallest businesses with one or no employees have access to credit.

The 2026 rule retained information on the number of years a small business is in operation, the number of principal owners and the North American Industrial Classification (NAICs) code of the small business, which indicates the type and sector of the small business.[29] The CFPB’s decision to retain these data points while deleting other important data points on business characteristics further illustrates the inconsistent treatment of variables in the 2026 rule. The agency judged some variables as important and straightforward to collect while considering others as not precise or difficult to collect without clearly describing differences among the data variables on these criteria.  

The 2023 rule included data on pricing including information on fees and interest rates. The 2026 rule eliminated pricing information as too complex and costly to collect although the CFPB acknowledged its value in fair lending analysis.[30] It cited HMDA’s incremental introduction of price data over several years. However, the analogy is misapplied since several lenders have now had experience with pricing data and computer technology is vastly improved. Rather than choose a more limited but useful disclosure of price data, the CFPB opted for the more drastic option of eliminating all pricing data to the detriment of the usefulness of the data. 

Along with the elimination of pricing, the CFPB deleted application method (online, phone, or in-person), application recipient (lender or third party) and denial reasons from the data.[31] These data points would have enhanced fair lending analyses by describing whether pricing or denial reasons had varied by how the application was processed and received. Combined with enhanced data on business characteristics, the pricing and application method data would have provided a fuller picture regarding whether businesses with similar characteristics and methods of applying were being treated comparably in terms of price and access to credit. Under the 2026 rule’s deletions, the CFPB forfeited an important opportunity to more rigorously investigate fair lending concerns and enforce fair lending laws.

Public Dissemination of the Data Delayed

The CFPB delayed the date under which lenders must start data collection until January 1, 2028.[32] Lenders must then submit the data to the CFPB by June 1, 2029. When the CFPB has the first years’ worth of data by the summer of 2029, the agency will analyze it and then release a request for public comments on a proposed rulemaking indicating which variables will be publicly disclosed and whether any of them will be modified before disclosure.[33] Since rulemaking generally occurs over a period of several months, it is possible that the public will not access data until 2030, which is 20 years after the Dodd-Frank Wall Street Reform and Consumer Protection Act passed in 2010. The two-decade delay is not consistent with the objectives of public accountability through data disclosure improving fair lending and community development outcomes.

Conclusion

The CFPB’s 2026 rule regarding Section 1071 data eliminates reporting requirements for thousands of lending institutions and reduces the amount of data reported by up to one half. Significant gaps in terms of identifying lending patterns, particularly in smaller metropolitan areas and rural counties, will result contrary to the community development and fair lending purposes of the statute. The CFPB failed to offer a convincing case that the 2026 rule’s reductions of data reporting were justified by cost or would prevent significant numbers of lenders from exiting the small business lending market. The fair lending value of the data is further diminished by the elimination of several characteristics of small business applicants, data on loan pricing and application processes. Lastly, the rule will delay public dissemination of the data by a full two decades after the passage of a law mandating data collection transparency. 

[1] Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. No:111-203, 124 Stat. 2057 (2010), Sec. 1071, p. 681, https://www.congress.gov/bill/111th-congress/house-bill/4173/text

[2] Consumer Financial Protection Bureau (CFPB), Small Business Lending Under the Equal Credit Opportunity Act (Regulation B), Final Rule, 12 CFR Part 1002, Docket No. CFPB–2025–0040, RIN 3170–AB4, Federal Register, Vol. 91, No. 84, Friday, May 1, 2026, p. 23531

[3] CFPB Final Rule, Small Business Lending, May 2026, p. 23592

[4] Ibid.

[5] Consumer Financial Protection Bureau, Proposed Rule: Small Business Lending Under the Equal Credit Opportunity Act (Regulation B), Docket No. CFPB–2025–0040, RIN 3170–AB40, Federal Register, Vol. 90, No. 217, Thursday, November 13, 2025, p. 50971

[6] https://ncrc.org/section1071/

[7] FDIC BankFind, count of banks and thrifts as of May 15, 2026, https://banks.data.fdic.gov/bankfind-suite/bankfind

[8] CFPB Proposed Rule, Small Business Lending, November 13, p. 50970

[9] https://ncrc.org/section1071/

[10] CFPB, Final Rule, Small Business Lending, May 2026, p. 23553

[11] NCRC Comment Letter on CFPB Proposed Small Business Lending Rule, December 12, 2025, https://ncrc.org/ncrcs-comment-on-the-cfpbs-proposed-rule-to-strip-section-1071-data-collection/

[12] CFPB Proposed Rule, Small Business Lending, November 13, 50984

[13] Chief Judge Beryl A. Howell, Civil Action No. 20-2074 (BAH), United States District Court for the District of Columbia, NCRC et al. v CFPB, p. 38, https://law.justia.com/cases/federal/district-courts/district-of-columbia/dcdce/1:2020cv02074/220484/26/

[14] Chief Judge Beryl A. Howell, Civil Action No. 20-2074, p. 42.

[15] NCRC Comment Letter on CFPB Proposed Small Business Lending Rule, December 12, 2025, https://ncrc.org/ncrcs-comment-on-the-cfpbs-proposed-rule-to-strip-section-1071-data-collection/

[16] CFPB Final Rule, Small Business Lending, May 2026, p. 23538

[17] CFPB Final Rule, Small Business Lending, May 2026, p. 23540

[18] CFPB Final Rule, Small Business Lending, May 2026, p. 23541

[19] CFPB Final Rule, Small Business Lending, May 2026, p. 23543

[20] Ibid. Also, it is important to note that the CRA data will not contain information for FCS lenders since they are not banks. The CFPB missed an opportunity to capture FCS lending data under Section 1071.

[21] CFPB Final Rule, Small Business Lending, May 2026, p. 23542

[22] NCRC Comment Letter on CFPB Proposed Small Business Lending Rule, December 12, 2025, https://ncrc.org/ncrcs-comment-on-the-cfpbs-proposed-rule-to-strip-section-1071-data-collection/

[23] CFPB Final Rule, Small Business Lending, May 2026, p. 23581

[24] CFPB Final Rule, Small Business Lending, May 2026, p. 23557

[25] Josh Silver, Archana Pradhan (NCRC), Spencer Cowan (Woodstock Institute), Access to Capital and Credit in Appalachia and the Impact of the Financial Crisis and Recession on Commercial Lending and Finance in the Region. Appalachian Regional Commission (ARC), p. 86. https://www.ncrc.org/access-to-capital-and-credit-in-appalachia-and-the-impact-of-the-financial-crisis-and-recession-on-commercial-lending-and-finance-in-the-region/

[26] CFPB Final Rule, Small Business Lending, May 2026, p. 23564

[27] Seema Agnani and Jason Richardson, Mortgage Lending in the Asian American and Pacific Islander Community. NCRC, August 6, 2020.

[28] CFPB Final Rule, Small Business Lending, May 2026, pgs. 23565, 23562

[29] CFPB Final Rule, Small Business Lending, May 2026, pgs. 23561, 23562, 23563

[30] CFPB Final Rule, Small Business Lending, May 2026, pg. 23560

[31] CFPB Final Rule, Small Business Lending, May 2026, pg. 23559

[32]CFPB Final Rule, Small Business Lending, May 2026, pg. 23572

[33] CFPB Final Rule, Small Business Lending, May 2026, pg. 23575

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Historic redlining continues to color mortgage odds, wealth opportunities today https://ncrc.org/historic-redlining-continues-to-color-mortgage-odds-wealth-opportunities-today-2/?utm_source=rss&utm_medium=rss&utm_campaign=historic-redlining-continues-to-color-mortgage-odds-wealth-opportunities-today-2 Tue, 02 Jun 2026 17:16:07 +0000 https://ncrc.org/?p=288862 April 30, 2026, WJLA, Historic Redlining Continues To Color Mortgage Odds, Wealth Opportunities Today

The Fair Housing Act of 1968 made redlining illegal, but the old red lines still influence who can and can’t get a mortgage today. 

The National Community Reinvestment Coalition (NCRC), a nonprofit organization focused on underserved communities, analyzed Home Mortgage Disclosure Act (HMDA) data from 1991 and 2021. Neighborhoods once marked “hazardous” on HOLC maps received 2.5 times fewer loans than areas once graded as “best.” The disparity remains even after accounting for vacancy, owner-occupancy rates and housing age.

“Formerly redlined communities had reduced mortgage investment for over a century,” says Bruce Mitchell, a principal researcher at the NCRC. “The impact was especially deep in redlined Black neighborhoods, where mortgage availability was further suppressed until the most recent decade.”

Even today, homeownership rates in formerly “hazardous” areas are still roughly half those in greenlined neighborhoods, according to the most recent data from the Federal Reserve Bank of St. Louis. 

“Mortgage markets are backward-looking, relying on historical sales to determine present values,” says Jason Richardson, senior director of research at the NCRC.

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Historic redlining continues to color mortgage odds, wealth opportunities today  https://ncrc.org/historic-redlining-continues-to-color-mortgage-odds-wealth-opportunities-today/?utm_source=rss&utm_medium=rss&utm_campaign=historic-redlining-continues-to-color-mortgage-odds-wealth-opportunities-today Tue, 02 Jun 2026 15:32:23 +0000 https://ncrc.org/?p=288840 April 30, 2026, Bankrate, Historic Redlining Continues To Color Mortgage Odds, Wealth Opportunities Today 

The Fair Housing Act of 1968 made redlining illegal, but the old red lines still influence who can and can’t get a mortgage today. 

The National Community Reinvestment Coalition (NCRC), a nonprofit organization focused on underserved communities, analyzed Home Mortgage Disclosure Act (HMDA) data from 1991 and 2021. Neighborhoods once marked “hazardous” on HOLC maps received 2.5 times fewer loans than areas once graded as “best.” The disparity remains even after accounting for vacancy, owner-occupancy rates and housing age.

“Formerly redlined communities had reduced mortgage investment for over a century,” says Bruce Mitchell, a principal researcher at the NCRC. “The impact was especially deep in redlined Black neighborhoods, where mortgage availability was further suppressed until the most recent decade.”

Even today, homeownership rates in formerly “hazardous” areas are still roughly half those in greenlined neighborhoods, according to the most recent data from the Federal Reserve Bank of St. Louis. 

“Mortgage markets are backward-looking, relying on historical sales to determine present values,” says Jason Richardson, senior director of research at the NCRC.

The lack of lending in one year depresses values, which makes lending more difficult the next. That is how lending discrimination became self-reinforcing.— Jason Richardson, Senior Director of Research, NCRC

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