Research – NCRC https://ncrc.org National Community Reinvestment Coalition Tue, 25 Aug 2026 19:43:13 +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 Research – NCRC https://ncrc.org 32 32 Racial Wealth Snapshot Series: Economic Outlook Overview for the Asian American Community https://ncrc.org/racial-wealth-snapshot-series-economic-outlook-overview-for-the-asian-american-community/?utm_source=rss&utm_medium=rss&utm_campaign=racial-wealth-snapshot-series-economic-outlook-overview-for-the-asian-american-community https://ncrc.org/racial-wealth-snapshot-series-economic-outlook-overview-for-the-asian-american-community/#respond Wed, 26 Aug 2026 13:00:15 +0000 https://ncrc.org/?p=291701

Definition of Terms

Asian Americans (AA) are a diverse group of individuals. The US Census defines Asian American as someone originating from the Far East (i.e., China, Indonesia, etc.), Southeast (i.e., Cambodia, Laos, Vietnam, etc.) or the Indian subcontinent. The 41 groups within the broader AA umbrella don’t fall neatly into national categories, such as Okinawans in Japan and the Hmong from Chinese descent. Additionally, the Census specifies demographic data by the category of “alone” for a person that is counted as only one racial or ethnic group or as “alone or in combination” for a person who identifies with more than one racial or ethnic group.

Demographics History

Changes to US immigration law have shaped the demographic history of Asian Americans. The California Gold Rush and western railroad construction in the mid-1800s brought thousands of Chinese laborers, and smaller numbers of Japanese and other Southeast Asian migrants, to the West Coast. This early period of immigration concluded with the Chinese Exclusion Act of 1882. Legal pathways for immigrating to the US were becoming increasingly restrictive with the passage of the Immigration Acts of 1917 and 1924. The former barred immigration from virtually all of Asia and the latter created a racial quota system that limited the number of immigrants who could enter the country from the continent.

The Immigration and Nationality Act of 1965, which ended the restrictive racial quota system, marks the start of the large-scale arrival of Asian immigrants. The act replaced national origin restrictions with skills-based preferences, which brought waves of Indian, Pakistani, Chinese and Filipino immigrants. The Indochina Migration and Refugee Assistance Act of 1975 also provided a pathway for Vietnamese, Hmong, Cambodian and other Southeast Asian refugees to come to the United States.

The different circumstances under which Asian Americans immigrated to the United States are visible in differential socioeconomic outcomes detailed later in this snapshot. Additionally, demographic differences between AA subgroups, such as language and education, contributed to who was able to come to the United States. For instance, the introduction of skills-based immigration pathways combined with a large population of English-speaking professionals is partly why today Indian Americans are the largest Asian American subgroup given their surplus of citizens who meet both requirements.

The Census Bureau counted 1.5 million Asians and Pacific Islanders in 1970, which rose to 3.7 million in 1980 and to 7.3 million by 1990. However, the Bureau cautions that part of that growth reflects changes in the Census’ race categories rather than a true spike in population for these groups. In 1970, there was no Asian category at all. The Census counted Japanese, Chinese, Filipino, Korean and Hawaiian as separate races, classified Asian Indians as White and placed Vietnamese under “Other race,” with no option to report more than one race.

In 1980, Asian Indian and Vietnamese were included in separate categories. In the 2000 Census, Asian Americans, Native Hawaiian and Pacific Islanders were separated into two categories. The 2000 Census also allowed respondents to record more than one racial category for the first time. In the 2000 Census, 10.2 million self-identified as Asian alone, which climbed to 14.7 million by 2010. Today, 19.9 million, or 5.95% of the population, identify as Asian American alone.

The chart below shows that about three quarters of the Asian American population consist of just five groups:

Those five groups include Indian Americans, who account for almost a quarter of the total population share, and Chinese Americans, who account for over a fifth of the total Asian American population. The three remaining groups (Filipino, Vietnamese and Korean) all have totals over 1 million.

The states of California and Hawaii played an important role in the history of Asian American immigration. Given their proximity to Asia, both states have become top destinations for Asian Americans. California has the largest number of Asian-alone persons at 6.1 million. Hawaii is the only state with a majority Asian (for those classified as “alone or in combination”) population, which currently sits at 57% of the total Hawaiian population.

The chart below shows that three states (California, New York and Texas) contain almost half of the total Asian American population:

Wealth Accumulation in Communities

The Survey of Consumer Finances, the premier dataset for measuring household wealth in the United States, measured Asian Americans separately for its 2022 release for the first time. They found that the median Asian American household held $536,000 in net worth – the highest of the racial groups surveyed. However, this figure masks the large level of wealth inequality between Asian American subgroups.

There are no national surveys that examine wealth among Asian American subgroups. However, a 2016 report from the New School found that the median household wealth of Korean Americans living in Los Angeles was $23,400. Their Japanese counterparts in Los Angeles held $592,000 in median household wealth. This is nearly a 25 to 1 ratio difference, indicating how large disparities exist between Asian American subgroups.

Similar to income inequality, wealth is distributed unevenly across Asian American groups. The intra-group wealth inequality stems from the effects of the different immigration paths among Asian Americans. As noted in the demographics section, some groups have arrived in the United States already highly educated via skills-based visa pathways while others came over as refugees with less financial resources.

Asian Americans have an overall homeownership rate (62.7%) that is around the national average (65%). However, similar to overall wealth rates, homeownership is distributed unevenly among Asian Americans. The homeownership rate varies widely, from 56% for Korean Americans to 69.6% for Vietnamese Americans.

Asian American households have a higher stock ownership rate (38%) than White households (24%), the highest of all racial groups. Business ownership is an important source of wealth for AA households, with about 15% reporting having business assets.

Rates of Educational Attainment

Asian Americans as a group have the highest level of educational attainment amongst all racial and ethnic groups in the United States. 56.7% of AAs have attained a bachelor’s degree or higher. However, vast differences in educational attainment among Asian American subgroups exist.

For example, while 80.6% of Taiwanese Americans have a bachelor’s degree or higher, only 52.6% Filipino Americans have obtained at least a bachelor’s degree. Similar differences exist for overall college enrollment rates as well. For example, 28.5% of Japanese Americans are enrolled in college compared to 37.6% of Chinese Americans.

Educational attainment differs by Asian American subgroup as shown in the chart below:

There are also sizable educational attainment differences between immigrants and US-born Asians. For example, 59% US-born Vietnamese adults have a bachelor’s degree compared to only 29% of foreign-born Vietnamese. Similarly, 54% of foreign-born Chinese Americans have at least a bachelor’s degree compared to 70% of US-born Chinese Americans.

Income Levels Across Groups

Asian Americans have the highest median household income of all racial and ethnic groups at $121,700. Similar to the aforementioned educational and demographic statistics, there are vast differences among AA subgroups. Indian Americans, the largest Asian subgroup, have the largest median household income ($165,721). This is over twice as much as Bangladeshi Americans ($76,365) and over 50% higher than Chinese Americans ($108,626), the second largest Asian sub-group.

These income differences are shown in this chart:

Within and between Asian American subgroups, vast disparities exist between the highest earnings and the lowest earnings. To gain a clearer sense of the intra-group income inequality that exists between AA subgroups, one can use the 90/10 ratio, the ratio of the top 10% of household income to the bottom 10%. A ratio of 20 means that households in the top 10% of earners have 20 times the income as households in the bottom 10%. For Chinese Americans, the ratio is 19.2 compared to 9.8 for Indian Americans. While the ratio for both groups was virtually identical in 1980, the former has shot up by 10.9 by 2022 compared to only .8 for the latter.

The intra-subgroup disparities can be partly explained by nativity, meaning native-born households have higher incomes than their newly arrived immigrant counterparts. For example, among immigrant-headed, Korean American households, their overall income was $82,000 versus $104,900 for US born-headed Korean American households.

While typically, US born Asian American households had higher incomes than immigrant-headed households, this is not true for Indian Americans. Immigrant-headed Indian American households have higher incomes ($156,000) than their US-born Indian American counterparts ($120,200). This stems from the fact that US and foreign-born Indian Americans have nearly identical rates of educational attainment. As the demographics section detailed, this trend is a byproduct of the skills-based immigration pathways many Indian Americans have been able to access.

Work and Labor Trends

A notable labor trend for Asian Americans is the high percentage who work in managerial and professional occupations (57.2%). This stems from their aforementioned higher educational attainment rates. Another unique trend is their relatively low unemployment rate (2.8% in 2022), compared to the overall population (3.6%). Even across the major Asian American subgroups, the unemployment rate is low, including 1.8% for Japanese Americans and 2.7% for Indian Americans.

The distribution of occupations and industries that Asian Americans work in are shown below:

However, there is a substantial group of Asian Americans who are low- and moderate-income, with occupational segregation, the over-representation of one group in an occupation, being common for some Asian Americans. For example, Asian women without a college degree are more likely to work in occupations that manage beauty, fitness and other personal needs of clients.

Workers in these occupations, such as manicurists, housekeepers and home health aides, are at the greatest risk of being misclassified as independent contractors. This results in workers having overtime protections stripped from them, the inability to access unemployment insurance and fewer legal avenues to collectively bargain for better working conditions and form unions.

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Preventing Hyperscale Harm: Analyzing the Potential Impact of Opportunity Zones 2.0 in Rural Communities Experiencing Accelerating AI Data Center Construction https://ncrc.org/preventing-hyperscale-harm-analyzing-the-potential-impact-of-opportunity-zones-2-0/?utm_source=rss&utm_medium=rss&utm_campaign=preventing-hyperscale-harm-analyzing-the-potential-impact-of-opportunity-zones-2-0 Mon, 17 Aug 2026 13:41:38 +0000 https://ncrc.org/?p=290921

Preventing Hyperscale Harm:

Analyzing the Potential Impact of Opportunity Zones 2.0 in Rural Communities Experiencing Accelerating AI Data Center Construction

August 2026

Simon Wang, Economic Mobility Specialist
Bruce C. Mitchell, PhD, Principal Researcher
Jad Edlebi, GIS Data Engineer

Interactive Map Application

View map icon

The Hyperscale Data Center  interactive map application shows rural low-income communities eligible to become Qualified Opportunity Zones under the new OZ program.

Executive Summary

Data centers are the backbone of the digital economy. Since the rise of the internet, the United States has become the data center capital of the world, housing nearly
40% of the world’s data centers to date. Before recent breakthroughs in large language models (LLMs) shifted the  landscape of artificial intelligence (AI) investment, data centers operated relatively innocuously, often housing institutional data and servicing basic cloud computing needs.

However, the demands of newer AI models have required historic amounts of investment in larger, more resource-intensive data centers. In general, more data centers of all kinds are needed to support the wider integration of AI into the digital economy. While hyperscale data centers are increasingly viewed as critical infrastructure for the digital economy, their rapid expansion places considerable demands on local energy grids, water supplies, land use and public services, generating growing concerns about their effects on host communities.

The Growth and Acceleration of AI Data Center Construction

By the end of this year, an estimated $500 to $700 billion will have been put toward data center development, with a stamp of approval from the federal government to move forward as quickly as possible. In an increasingly stagnant economy suffering
from diminished consumer spending as well as slowing job growth, data centers
and capital expenditure commitments by the so-called “Magnificent 7” Big Tech conglomerates (Apple, Microsoft, Amazon, Google, Meta, Tesla and NVIDIA) have become the engine of the economy. Some estimates suggest spending on data centers contributed as much as 92% of gross domestic product (GDP) growth during the first half of 2025.

While the financial markets continue to show confidence in AI, people on the ground have shown growing opposition to the construction of data centers and apprehension about the broader economic and societal impacts of AI. Poll after poll demonstrates Americans strongly oppose data center development in their communities. The most recent Gallup survey from March 2026 found that seven in 10 Americans oppose constructing AI data centers in their local areas, including 48% who strongly opposed it. Although some question the breadth of data center opposition, the consensus from most polling suggests that Americans across the political spectrum oppose data center development.

The billions of dollars in AI data center investment are placing a physical toll on communities, especially in rural areas. As data center proposals show up across the country, local residents are learning in real time just how powerful OpenAI, Anthropic and the rest of the Big Tech companies really are as well as what the costs of AI are to their land, resources, health and ways of life.

Structural Factors Pushing AI Data Centers to Rural Communities

As AI models have changed, so too has the physical footprint of the data centers
powering them. Recent estimates suggest that the overwhelming majority of new data center projects in the US are planned to be constructed in rural areas, even though most of those currently operating are located in cities. The shift in the geography of data center projects is largely a byproduct of alignment between the needs of the latest AI technology and the advantages of developing newer, larger AI data centers in rural areas of the country.

However, all data centers are not created equal. As frontier AI labs have doubled
down on models that require enormous amounts of data to train and operate, the size and scale of data centers have grown astronomically. These so-called hyperscale data centers and mega-campuses (henceforth referred to as AI data centers) are built specifically for AI and have completely altered the landscape of data center construction across the board, expanding quickly into communities that had largely been left behind in the digital economy until recently.

The move to hyperscale data centers is a marked shift from the wave of data centers built during the rise of the internet and cloud computing. This previous cohort of data centers was built primarily to optimize latency (the time it takes for data to pass from one point on a network to another), which meant building near urban communities with high concentrations of end users or suburban areas with access to high-speed fiber optic cables (e.g., “Data Center Alley” in Northern Virginia).

Figure 1, shown below, shows the dense concentration of data centers found along power lines in Northern Virginia. Access to government users and close proximity to the submarine transatlantic cables that run along the ocean floor made Northern Virginia an ideal location for data center construction.

Figure 1. “Data Center Alley” outside Washington D.C. in Ashburn, VA. Large circles are hyperscale data centers. Orange lines are high voltage power transmission lines.

These data centers were much smaller, housed fewer servers and, by extension, required less resources and introduced fewer adverse effects to the surrounding environment. In fact, most data centers operated relatively innocuously, sometimes housed in downtown buildings nearly indistinguishable from office parks. However, in recent decades, the rise of cloud services like Google Drive and Microsoft SharePoint in addition to growing interest in big data increased interest in larger data centers.

Throughout the 2010s, hyperscale data centers began to emerge around the world to meet this demand for storing and processing data. Although demand for data centers was already rising steadily, the emergence of generative AI has led to a dramatic expansion. A recent McKinsey analysis estimates around 70% of the growing demand is for data centers built specifically to support AI.

To build AI data centers, vast amounts of natural resources (e.g. land, energy, water) are needed in quantities that are magnitudes greater than the data centers primarily used for other purposes. The availability and price of these resources, especially land, in rural areas have made them particularly attractive to companies involved in the construction, management and use of AI data centers. As a result, rural communities are increasingly finding AI data center developers at their doorstep.

There are five key resource and infrastructure requirements that are required to develop an AI data center: land, energy, water, electricity grid and fiber optic network infrastructure. Rural areas vary in the cost and availability of these inputs, but generally they offer more favorable  environments for AI data center construction and operation.

Land
Hyperscale data centers have historically been defined as taking up at least 10,000 square feet for the actual facility. However, more recently, AI data center developers have been buying thousands of acres of land for facilities spanning millions of square feet. Some of the cheapest available raw land is found in large, rural states with low population density and high land supply.

Energy
The equipment housed in a hyperscale data center requires vast amounts of energy to operate. Estimates now suggest that data centers could make up roughly 1% of global power demand and 11% of total domestic electricity consumption by 2030 – a share projected to grow substantially as AI workloads expand.

Water
The heat generated by hyperscale facilities place substantial demands on local water used in cooling systems, with some large facilities consuming millions of gallons yearly. While newer direct liquid cooling, air cooling technologies and closed-loop systems are beginning to reduce this burden, these improvements in water use depend on system design and local climate conditions.

Electricity Grid
AI data centers place growing stress on an already aging nationwide electrical grid, often requiring major improvements to infrastructure in order to gain access to electricity at the scale and frequency needed to support AI development.

Fiber Optic Network Infrastructure
Data centers must be located within a reasonable distance of the fiber optic backbone that spans the country because latency and bandwidth constraints make rural remote siting viable only where it can be accessed or extended economically. Unlike previous eras of data centers focused on latency, distance to internet infrastructure is a secondary factor to the electricity grid when it comes to AI data centers.

Tradeoffs of Rural AI Centers

Demographic Access and Exclusion

As rural communities face growing interest from AI data center developers, disinvestment and demographic shifts away from rural areas have shaped how communities and elected officials have responded. Rural areas of the country have been losing population density for decades, putting local governments under significant financial pressure as their tax bases have declined. Even in communities that recognize the risks and negative  effects of AI data centers, many have been overlooked by other, perhaps more desirable, economic
development projects. As a result, elected officials are left without an alternative.

Based on the lack of interest from other developers, many states and local governments have  embraced AI data centers as the key to restoring tax revenue in rural areas. Some even introduced tax incentives and abatements to compete with other regions and attract data center developers to their communities. In return for subsidizing development, local officials are often promised jobs, tax revenue and other community development initiatives.

However, the costs of an AI data center are not just financial. AI data centers also introduce a multitude of externalities that are not accounted for on the balance sheet, such as straining energy supply and electricity grids, contaminating the local water supply and polluting the air. Ultimately, the net impact of data centers is difficult to forecast, especially without transparency standards, updated zoning codes and environmental impact assessments.

The demographic shifts and resulting financial challenges facing rural communities are yet another contributor to the acceleration of AI data center development. In recent years, grassroots opposition has mounted as people from across the political spectrum are coalescing to reject data center builds.

Stuck between fervent local opposition, pressure from developers to move quickly and the tradeoffs of allowing construction to move forward, rural policymakers have been put in an impossible position. Either circumvent constituents and accept the costs of constructing an AI data center or risk jeopardizing the financial security of their community. All of this has turned AI data centers into one of the most polarizing economic development projects in the country.

Federal Tax Policy May Further Incentivize Rural AI Data Centers

Recent changes to a federal community development initiative called the Opportunity Zones (OZs) program could provide additional economic incentives for AI companies to develop hyperscale data centers in rural areas of the country. The OZ program was first created through the Tax Cuts and Jobs Act of 2017 as a place-based economic development initiative designed to channel private capital into low-income communities.

By offering investors preferential tax treatment on capital gains, policymakers hoped to stimulate business activity, job creation and long-term community development in economically distressed census tracts.

By 2026, it is estimated that investors had directed roughly $100 billion nationwide into economic development projects through the OZ program. However, the effectiveness of that money in uplifting disadvantaged communities has been widely debated. Although some argue the OZ program has attracted capital to communities that had long struggled to secure investments, further analysis reveals the hollow nature of those contributions. Estimates suggest a substantial share of the funds invested through the first OZ program ended up flowing into projects that would have happened even without the tax incentive.

Some analyses have found that many of the projects delivered minimal direct benefits to residents of the low-income communities it was designed to serve. Rather than helping the persistently distressed communities that the OZ program was purportedly created to serve, the investments that did materialize were disproportionately put toward constructing market-rate real estate in the most well-off enclaves of the zone.

By allowing investors to lift and defer taxes on long-term investments, OZs reward economic development projects that are likely to increase in value and generate capital gains over time, such as market-rate housing or AI data centers. As a result, investments made through the OZ program often ended up going to areas with the least need rather than being put toward job-creating businesses in distressed communities.

Despite these concerns, Congress renewed and expanded the program in 2025, making OZs a permanent feature of the federal economic development landscape and creating a new facet of the program called the Qualified Rural Opportunity Fund to focus specifically on driving investment in rural communities. In addition to questions about whether this action will offer tangible benefits to rural communities and not just wealthy investors, the race to develop AI data centers across rural America introduces another set of concerns about whether the projects that rural OZs may attract will translate to meaningful impact.

AI data centers are exactly the kind of capital-intensive, long-duration, asset-heavy investment that OZ-style incentives are structured to reward. Rural areas designated as OZs that offer comparatively cheap land costs, access to affordable energy and proximity to fiber optic infrastructure present an attractive investment profile for AI companies seeking to maximize the tax advantages of long-term asset appreciation.

While this situation might be beneficial for investors, constructing an AI data center imposes many costs on residents without many clear direct benefits beyond some immediate relief to the local tax base and perhaps a handful of long-term jobs. Just as market-rate housing in wealthier metropolitan neighborhoods became the go-to project for OZ investors, AI data centers could repeat this pattern in rural OZs, albeit at a much greater scale of investment and with far greater negative consequences.

Identifying Rural Communities Impacted by Data Center Development in Opportunity Zones

To anticipate which rural communities could become targets for AI data center development, we used ArcGIS to create a map of the United States at the census tract level. Next, we constructed an AI data center siting index using the characteristics identified. The AI data center siting index was constructed using the locations of existing data centers to identify the factors that best predict where future data centers are likely to be located.

These factors include the density of the electrical power grid, their proximity to internet exchange points and the high-speed fiber-optic backbone. Locational data came from the FracTracker Alliance, who publishes a publicly available dataset of more than 1,600 data centers. The map below (Figure 2) shows in darker colors areas with a greater risk of development. Next, the results of the index were overlaid on a map of all low-income census tracts identified in the 2024 Census data. Finally, we plotted the location of the data centers using the data from FracTracker Alliance.

Hyperscale Data Center Interactive Map

Figure 2- Rural low-income communities eligible to become Qualified Opportunity Zones under the new iteration of the OZ program. Darker shaded census tracts are more highly rated under the AI data center siting index for electric grid density, proximity to IXP sites and internet backbone structure. Interstate highways are in yellow.

Overall, 14% of all data centers were located within OZs. However, the concentration was notably higher among approved, permitted and under-construction facilities, with 17.3% being located in OZs. Given the share of all Census tracts designated as OZs, this rate is 46% higher than expected. Operating facilities were also overrepresented, while cancelled projects exhibited the highest concentration, with nearly one in five located in an OZ. 

State and Local Policy Recommendations

OZs should be used to promote real economic development with real benefits for communities rather than jeopardizing community health, safety and autonomy in return for modest economic benefits. Moreover, rural governments should not feel forced to accept projects that their constituents are against. To avoid repeating the mistakes of the first round OZ program, there are two complementary courses of action that state and local governments impacted by rural OZ designations could take to preserve community autonomy and long-term interests.

Incentivize Community-Aligned AI Data Center Alternatives
First and foremost, governors must listen to community groups (vs. industry) and nominate LMI census tracts that have high potential for OZ investment to benefit their communities. Then, local and state governments representing rural communities should pair the OZ designation with additional strategies for attracting community-aligned projects.

That begins with rigorous planning that empowers residents to build a vision for their community’s future. Local governments should ensure they have strong, ambitious plans and goals co-created alongside community members. The resulting plans and objectives offer a roadmap for policymakers and community members that represents their shared priorities. In fact, many communities already engage in this process.

These may include but are not limited to implementing the following:

  • A water usage plan,
  • An energy usage plan,
  • A heat mitigation plan,
  • An economic development plan,
  • Clear environmental standards (such as air pollution and emissions
    reduction guidelines),
  • Concrete environmental justice goals,
  • Public health goals, and
  • A city equity plan.

Using these plans, local officials should first identify the kinds of economic development projects that match residents’ priorities. Then, they should encourage the creation of those projects by stacking additional incentives onto census tracts designated as rural OZs. Doing so will help to direct Qualified Rural Opportunity Fund investments into projects that will more positively impact the community, cause fewer negative effects and align better with residents’ needs.

At the local level, zoning ordinances offer policy levers for both preventing AI data center construction and further incentivizing other projects. For example, municipalities can change the zoning code to restrict data centers from being developed in OZ-designated census tracts. In Atlanta, Georgia, the city council amended their zoning code to prohibit data centers in the Beltline Overlay District, an initiative to link green space, trails, transit and economic development. At the same time, local governments can make it easier to build projects that better align with community priorities. They could, for example, reduce permitting requirements or shorten review periods for affordable housing, local businesses or other preferred developments.

At the state level, lawmakers can pass state‑specific OZ tax credits or subsidies for other kinds of economic development projects that have stronger evidence of delivering long-term community benefits. Stacking tax credits for certain kinds of projects adds another layer of incentives for investing in projects that advance the community’s goals (e.g. state-specific Low-Income Housing Tax Credit programs).

States can also pave the way for residents to participate as investors in their own communities. Offering state tax incentives for state resident investments in local businesses and incentivizing community investment funds allow ordinary investors to participate in OZs and guide OZ investments to locally led projects. Passing state-level Community Reinvestment Acts can also increase the amount of investment from financial institutions that is available to communities in these areas. Overall, this place-based, people-led approach helps to align economic incentives with what the community wants and needs, encouraging more democratic development.

Condition Data Center Permits on Alignment and Commitment to the Community
More broadly, state and local governments should set policies that establish a baseline set of guardrails that ensure data center proposals are introduced transparently and with the support of their communities. Given the power imbalances between Big Tech companies and local governments, AI data centers offer little possibility for parity in shared agreements.

Not every community will have what it takes to organize a successful negotiation with AI companies and developers. Under voluntary frameworks, every shared agreement requires strong organizing campaigns and local leadership to negotiate with a Big Tech company. If the company breaches their agreement, then local governments are also unlikely to have the resources needed to withstand long legal fights.

AI data centers should fit into the existing community planning goals mentioned earlier. Local governments can achieve this by establishing a conditional use permitting process for data centers (e.g. Limerick Township, Pennsylvania). Conditional use permits require developers to apply to the zoning board for permission to use the land for specific purposes. Developers must meet specific conditions set by the local government before they receive approval, with their permits being revoked if conditions are not met throughout the lifespan of the property. Local governments can set rules for what kinds of projects require approval and what is required to be approved for a permit. Approval for AI data centers should be conditioned on adherence to transparency measures as well as alignment with community goals.

The approval process for data center projects should reject applications that fail to comply with these expectations. The burden should be on the data center developer to prove how the project will fit within a community’s priorities, with clear and transparent timelines, plans and accountability measures. Failure to effectively demonstrate this should result in rejection. Moreover, successful applications should be accompanied by a requirement that the developer complete a legally enforceable community benefits agreement (CBA) with residents.

One of the key goals of a CBA is to secure real commitments for community members from data center developers before construction proceeds. They have long been used in a variety of large-scale economic development projects, including professional sports stadiums, clean energy projects and bank investments. In recent years, several localities have signed CBAs with data center developers. In Lancaster, Pennsylvania, a CBA secured a water use cap, emissions controls and a $20 million community fund. In St. Louis, Missouri, the city negotiated binding commitments on noise, sustainability and water use, retaining the right to seek legal recourse if provisions go unmet.

Growing resident concerns about data centers are prompting a range of state and local policy responses, from moratoriums to broader debates over how proposals should be evaluated through permitting and zoning processes. CBAs are increasingly seen as an important piece of that puzzle (e.g., the NAACP CBA framework and the Federation of American Scientists’ CBA framework). By tying the permitting process to developers’ commitment to community priorities by, for example, conditioning approval on completion of a CBA, local governments can ensure that data center projects benefit the community and have buy-in from residents. When paired with broader safeguards, CBAs are one mechanism policymakers and communities may consider for increasing community participation in decisions about whether and how data centers are built.

Conclusion

Advances in AI technology and the expansion of big data in the modern digital economy have vastly increased the demand for large, hyperscale data centers over the past decade. In recent years, AI companies in particular have expanded investment, increasing the pace and scale of their push to construct AI data centers. The scale and intensity of resources needed to build and operate these AI data centers has shifted development to rural areas of the country, which have often been overlooked by other economic development projects.

However, current evidence suggests that the long-term economic impact of AI data centers is limited. Although they can provide much-needed support for the local tax base, AI data centers create very few jobs beyond the construction phase and impose a host of negative consequences on the surrounding environment with significant effects on public health and community life. As grassroots opposition grows, local officials are increasingly squeezed between representing the views of their constituents and protecting the long-term financial security of their communities.

The creation of Rural Opportunity Funds further complicates the picture by providing additional federal tax incentives for large, capital-intensive projects like AI data centers. That said, local and state governments representing rural communities that are designated as OZs can take actions that incentivize Rural Opportunity Fund investments to be used for more beneficial economic development projects than AI data centers.

Moreover, they can introduce formal processes and mechanisms for ensuring that AI data center projects are approved transparently with community input, align with broader community planning goals and remain accountable via community benefits over the entire course of the project. Communities that are successful at aligning economic development policy with planning goals co-created by residents and policymakers can ensure Rural Opportunity Funds are leveraged for meaningful, long-term community impact rather than as an accelerant for the AI data center buildout.

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Nashville Summit Series – Brief 5: Barriers & Solutions for Workforce Development https://ncrc.org/nashville-summit-series-brief-5-barriers-solutions-for-workforce-development/?utm_source=rss&utm_medium=rss&utm_campaign=nashville-summit-series-brief-5-barriers-solutions-for-workforce-development Mon, 03 Aug 2026 21:10:02 +0000 https://ncrc.org/?p=291048

Briefs 1 and 2 of this series established the methodology behind the Nashville Summit and the seven structural barriers that cut across the housing, workforce and small business development ecosystems. Briefs 3 and 4 instead focused on housing and small business respectively. This brief maintains the previous two briefs’ narrower focus but instead distills the conversations from the participants in the workforce development ecosystem. It documents the barriers raised by practitioners and funders during the workforce development dialogues and the solutions participants raised that would work with limited federal government support.

Devin Thompson, Director, Place-Based Strategies

Key Takeaways

1

Funding for workforce programs pays providers to reach certain placement numbers quickly, not to build long-term, livable-wage careers. Measuring success based on change in a participant’s long-term trajectory instead of 90 day placements will incentivize economic stability and mobility.

2

Training a diverse workforce means little when the best jobs are only accessible through informal networks and ineffective hiring mandates. Formal pipelines into skilled trades backed by enforceable commitments and accountability with teeth is the only way to ensure opportunity is equally accessible.

3

 The benefits cliff forces families to choose between a raise and the subsidies that keep them stable, leaving them financially vulnerable to disruptions. Bridging that gap with transitional benefits, accessible emergency support and financial coaching with integrated wraparound services is what allows training to grow into a career.

4

Policy choices and biases towards those with formal degrees are shrinking the labor pool at a moment when industries face critical shortages. Expanding who counts as employable and getting employers to treat talent development as an operating cost rather than a perk is central to a responsive workforce system that meets the needs of a growing local economy.

Specific Barriers in the Workforce Development Ecosystem

While the workforce development ecosystem shares many challenges with other sectors, the dialogues uncovered unique structural flaws that specifically penalize economic mobility and block access to high-quality careers. These barriers center on misaligned incentives, exclusionary practices and policy restrictions that shrink the labor pool.

1. Programmatic Focus on Short-Term Job Placement

Workforce organizations are trapped by funding metrics that prioritize the wrong outcome. Grants typically demand immediate job placement numbers, effectively ignoring whether that job actually leads to a livable wage or long-term stability. The consequences of this mismatch are felt most acutely in these ways:

  • The Warm Body Syndrome: Driven by the need to hit quarterly grant targets, providers are forced to place participants in lower-wage jobs just to count them as employed. This transactional approach satisfies the employer’s immediate need for a body but fails to produce a career for employees.
  • Incentive to “Cream”: The pressure for speed in job placements creates a perverse incentive to prioritize the easiest-to-place candidates while neglecting those with high barriers to employment, such as criminal records, lack of transportation or housing instability, who require more intensive support. As a result, the people who need the services the most are often the ones it is least designed to serve.

2. Institutional Barriers to Entry in Skilled Trades

Although the skilled trades are often the surest path to a middle-class income without a degree, access to these career pathways are often blocked by entrenched informal networks. Participants described the “FBI” (Friends, Brothers and In-laws) system, where hiring is driven by nepotism rather than merit or training. Practitioners highlighted two primary areas where this lack of access stalls progress:

  • The Closed Door: Even when local projects have Community Benefits Agreements (CBAs) mandating local hiring, contractors often bypass these rules by claiming qualified local workers don’t exist in the region. In reality, the jobs often go to those inside the social circle of existing union members or foremen. This reliance on personal networks specifically excludes women and people of color who historically lack these intergenerational connections. It thus renders training programs ineffective if the only way to get an apprenticeship is knowing the shop owner.
  • Lack of Political Will: The structure of local hiring mandates is often undermined by a lack of rigorous enforcement and minimal business commitments. In Detroit, for example, large commercial projects included a mandate to hire Detroit residents, but the penalty for failure was simply a fine. Developers frequently “baked the fine into their proforma” as a cost of doing business rather than actively recruiting local talent. An example another participant raised from DC described the developer meeting the “letter of the law” by hiring community residents at a minimum wage rate to hold signs at the project site and use water hoses to mitigate dust during demolition. This lack of enforcement will mean that even when the legal framework exists, the outcomes for the community will lag behind. When the jobs do not materialize for local residents, the community sees no return on the massive public investment, leading to displacement rather than development.

3. Policy Restrictions on Eligibility and Funding

Political shifts are leading to the reduction of the eligible labor pool while creating artificial barriers to employment. This acts as an economic self-injury, cutting off willing workers from industries desperate for talent. There were two themes that were discussed repeatedly:

  • Excluding Immigrant Talent: Changes in the interpretation of federal laws like the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) have restricted the use of funds for training undocumented immigrants or supporting mixed-status families. This cuts off a vital segment of the labor force, with devastating impacts on the construction and service industries, which are facing critical staffing shortages. Immigrant families, fearing government tracking and enforcement actions, are retreating from critical resources such as housing counseling and pre-purchase classes. This fear is hugely disruptive, pushing workers into the shadows and causing organizations to cancel planned training sessions.
  • Degree Inflation: Beyond immigration status, the system creates artificial barriers through degree inflation or credential creep. Employers frequently require bachelor’s degrees for entry-level roles like bank teller or administrative roles that could easily be performed by someone with skills-based training. This credential creep locks out capable workers and contributes to the sorting down phenomenon, where over-educated individuals take lower-skill jobs, displacing those without degrees entirely.

4. Lack of Critical Supportive Services

The lack of integrated support services is a fatal flaw in the current program design, creating scenarios where symptoms are often triaged by a programmatic intervention. Connection to additional services that would solve the underlying condition are missed. While the conversions each covered unique aspects, they shared a key central point:

  • Fragmentation Costs Us All: A job seeker cannot hold a job if they don’t have childcare or a way to get to work. Yet, workforce funding rarely covers these supportive services sufficiently. A participant might get free welding training and still discontinue the training because their car breaks down or they lose their housing. The system ignores the reality that for a person just beginning to stabilize a flat tire is a career-ending event – setting them up for failure rather than success.

Specific Solutions

Eliminate the Damaging Benefits Cliff

Policy advocates should push for changes that eliminate the benefits cliff to ensure a small wage increase does not result in the loss of subsidies. This would correct the misaligned economic incentives, ensuring workers are rewarded rather than penalized for increasing their income and working towards economic mobility. Participants identified several concrete ways to provide the support necessary to clear the cliff entirely:

  • Bridge the Gap with Transitional Benefits: Programs like the Tennessee Alliance for Economic Mobility use algorithms to calculate specific transitional benefits to offset lost SNAP or housing support. Nonprofits need unrestricted, gap-filler funds to cover the dangerous window between program participants losing a benefit and receiving their first higher paycheck. Emergency client assistance funds are also essential for addressing immediate crises, such as car repairs, that typically derail training.
  • Focus on Career Trajectories and Credential Stacking: We must pivot from immediate job placement to long-term career development that moves participants beyond the cliff to ongoing economic growth. This involves stacking credentials, such as moving a healthcare worker through from their initial CNA training to LPN certifications and eventually to RN credentials, ensuring wages rise progressively. Training should target creating thriving wages rather than maintaining low living wages that sit on the cliff’s edge. High-growth sectors, like mortgage lending, offer meaningful career pathways with accessible entry requirements.

Problem
Financial disincentives often stall economic mobility for low-wage workers. When the gap created when a pay or hours increase triggers a disproportionate loss in public assistance, the work is effectively penalized, which keeps talent trapped in lower-wage roles. When offered a raise or an opportunity to take on extra hours, workers must receive enough compensation to account for what they could lose in benefits at their new income level.

The difference between the increase in a person’s earned income and the dollar value of services and benefits lost is what’s known as the benefits cliff. Providing bridge financing to cover the value of lost benefits when workers move up the income ladder is very important. Filling this gap removes the financial disincentive to career advancement and promotes economic mobility.

Solution

While not as scalable as broader system reform, targeted bridge support provides the specific capital – such as grants, time-reduced subsidies or low-interest loans – needed to keep a worker’s net income stable through a transitional period, further incentivizing ongoing career advancement.

Bridge financing accepts the current structure and simply fills the gap at the critical moment when workers face the benefits cliff. The financing can come from various sources, including philanthropic funds, employer contributions, revolving loan funds or public-private partnerships.

Implementation
Multiple bridge funding pilot projects, such as Career MAP, have emerged that focus on providing direct cash assistance to offset benefits losses. While these programs show promise, they are difficult to scale and expensive to maintain. Well designed loans offered to workers facing benefits cliffs are scalable and offer some distinct benefits to cash transfers.

One example of this approach comes from Common Wealth Charlotte, an organization in North Carolina that offers “opportunity loans” of up to $1,000 and “credibility loans” up to $120 with 0% interest, no added fees and unlimited deferments on payments. While not solely intended to bridge the benefits cliff, accessing Common Wealth’s loans brings participants into the banking system, helping them build a credit history and receive financial counseling and education, all without being exposed to the risks of predatory lenders.

Impact
Since 2018, Common Wealth’s 0%-interest, no-fee loans have demonstrated that flexible, small-dollar credit is both a viable alternative to predatory lending and a lifeline for those facing the benefits cliff. It has helped more than 2,100 people by providing over $1.5 million in loans with a 93% repayment rate.

Lesson
To scale this model, mission-driven providers (CDFIs, banks, and credit unions) should consider two important factors: product development and client engagement.

For these products to appropriately incentivize further work, it is important to prioritize flexibility by structuring loans without fees, unlimited deferments, and 0% interest rates. The catalyst for a 93% repayment rate is also the support surrounding the capital, it is managed by a loan counselor who can offer trauma-informed financial coaching than a traditional loan officer.

Replication also hinges on the integration with the organizations that witness career-stagnation decisions firsthand and can tell when the loan is the right tool to reach for. Workforce development organizations and employers are often well-positioned to detect employees because they witness career stagnating decisions firsthand. Formal referral partnerships with them, and other local human service agencies, can proactively divert workers towards appropriate solutions as their eligibility changes.

Integrate Services for Holistic Support

Shift from siloed training models to a holistic, person-centric ecosystem that connects workforce activities with housing, healthcare, financial literacy and other services responsive to program participants’ needs. Building a truly integrated, no-wrong-door system requires comprehensive alignment of essential support services. When services are coordinated and interwoven, they provide the robust support necessary for families to achieve and maintain stability. Building a truly integrated ecosystem would require one or more of these support pillars:

  • Deploy Shared Referral Technology: Shared digital platforms, like Nashville’s Charity Tracker, enable warm handoffs where client data and history populate across agencies. This prevents the trauma of retelling stories and reduces the administrative burden on clients. Centralized resource hubs or marketplaces can further support this effort by housing standardized toolkits and research for smaller organizations.
  • Establish Backbone Teams and Intermediaries: Complex ecosystems need coordination between system actors to ensure they’re operating in ways that serve communities’ interests. Dedicated backbone teams are essential to knitting resources and providers together, ensuring navigators and coaches are relationally connected before a crisis hits. Intermediaries also provide uniquely informed perspectives when managing passthrough federal funds to smaller, specialized nonprofits, empowering grassroots work while tracking collective outcomes centrally.
  • Co-Locate Services to Reduce Friction: Physical integration of service providers reduces barriers to access and coordination. Co-locating multiple services allows organizations to catch clients who might otherwise fall through the cracks between appointments. This mini-hub model leverages existing assets to offer multi-faceted support in a single location.
  • Cross-Train Practitioners: Integration must happen at the personnel level. For example, health workers in Indiana are trained in housing navigation to provide immediate handoffs for patients. Similarly, shadow job coaches can bridge the transition gap from training to retention by supporting participants on their first days of employment.

Recalibrate Metrics for Long-Term Economic Mobility

We must transition from measuring the speed of reemployment to assessing the full career journey. This requires recalibrating our systemic metrics to prioritize long-term economic mobility and sustainable career growth over immediate job placement, which too often results in dead-end employment and ignores job quality. To align grant deliverables with actual mobility, practitioners suggested these shifts:

  • Redefine Success Through Longitudinal Tracking: High-volume, short-term placement numbers tell a shallow story. Practitioners should extend intensive retention support from the standard 90 days to at least 12 months, ensuring participants can navigate the critical first year of a new career successfully. Success should be measured over years, not months, to incentivize changing a participant’s trajectory.
  • Adopt an Outcome-Driven Narrative: Workforce development agencies’ logic models should guide the outcomes they center in their grants and their marketing. Reframing the narrative for funders requires moving away from mere outputs to measurable financial outcomes, indicating engagement with the mainstream financial sector.

Formalize Employer Co-Investment in Training and Advancement

Employers must move beyond only writing checks to actively integrating advancement into their operating models. This systemic shift formalizes the commitment between the business and its workers, breaking down entrenched “FBI” (Friends, Brothers, and In-laws) hiring barriers. The following strategies illustrate ways that summit attendees wanted to change partnerships with employers:

  • Integrate Learning into Paid Time: Bring community college courses directly to the worksite during compensated hours. To make this feasible in environments with razor-thin staffing margins, staffing substitute programs, a human resource mode where management covers frontline shifts for employees, allowing hourly staff to attend career development training. This keeps the business running and demonstrates deep leadership’s commitment to its employees.
  • Bake Talent Development into the Business Model: Employers should treat training budgets as essential operating costs rather than optional perks. This means funding degrees or certifications to ensure entry-level staff do not hit a career advancement ceiling. Programs like KeyBank’s Future Ready Workforce or Bank Works provide templates for preparing current employees for internal promotion.
  • Dismantle “FBI” Hiring with Formal Pipelines: Informal, who-you-know networks limit opportunities to insiders. To fix this, providers need to build formal, data-driven pipelines between candidates and employers. The Kentucky and Indiana Mills program demonstrates this success by brokering deals with organized labor. These partnerships allow participants to enter carpenter and IBEW (electrician) apprenticeships that guarantee wage increases and union-backed, high-paying trade positions. Additionally, organizations like RED Academy expose youth to careers in logistics or renewable energy that they would never encounter through traditional school paths.
  • Flip the Business Case: To increase the audiences open to our message, advocates must move away from purely social justice-oriented appeals and utilize the language of ROI. The cost of onboarding new staff is almost always higher than investing in the retention of current employees. When employers ask, “What if I train them and they leave?”, the answer is simple: Employees stay where they know their growth is a priority. Providing wraparound support and growth opportunities fosters the loyalty necessary for long-term retention.

We began this report with the hard truth that the “pipes” of community development are broken. For decades, we have relied on a top-down approach to directing capital into our communities. Now, those flows are drying up and the infrastructure is leaking.

Waiting passively for federal policy shifts or reauthorization of funding is not a viable, long-term strategy. The New Normal demands that we build a new distribution system that is led by the practitioners on the ground.

The solutions outlined in this report form the blueprint for this new architecture. When we consolidate back-office functions, we establish new operational efficiencies. When we integrate workforce data with housing intake processes, we eliminate the silos that are a disservice to community residents. When we replace predatory debt with patient capital, we will significantly increase the resources and availability of economic opportunity.

This is the shift from passive recipients of funding to active architects of our own ecosystem that is urgently needed at this moment. We are no longer just painting the walls of a cracking house. We are pouring a new foundation. The blueprints are in your hands. The work begins now.

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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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Black and Hispanic College Graduates Face a Tougher Job Market: July 2026 Race, Jobs and the Economy Update https://ncrc.org/black-and-hispanic-college-graduates-face-a-tougher-job-market-july-2026-race-jobs-and-the-economy-update/?utm_source=rss&utm_medium=rss&utm_campaign=black-and-hispanic-college-graduates-face-a-tougher-job-market-july-2026-race-jobs-and-the-economy-update Mon, 20 Jul 2026 14:00:17 +0000 https://ncrc.org/?p=290468 According to the Bureau of Labor Statistics’ (BLS) June jobs report, the national economy added 57,000 jobs, while the unemployment rate dropped slightly to 4.2%. The former was substantially below economists’ expectations of 115,000 jobs. Monthly job gains have trended downward since March, going from 214,000 to 57,000. 

The drop in the unemployment rate was not because more people found new employment but because over 200,000 unemployed people left the labor force last month and stopped looking for work.

The labor market remains lukewarm as job openings, layoffs and resignations remained largely unchanged in May according to BLS’ data. While the rate of unemployment remains low overall, the slow labor market is affecting one group in particular: new college graduates.

As college graduation season ends, many graduates are struggling to enter the workforce. Their topline unemployment rate, officially called the U-3 rate, rose to  5.3% in April, an increase from the January 2025 rate of  4.7%. The U-3 rate is the percentage of the labor force that is unemployed. 

The U-6 rate, commonly called the underemployment rate, includes unemployed workers plus involuntary part-time workers and discouraged workers. The U-6 rate for new college graduates has risen faster than their U-3 rate. Since January 2025, the U-6 rate increased from 8.2% to a high of 10% in April.

The chart below shows both the U-3 and U-6 rates by race:

The increase in the U-6 rate suggests that a portion of new college graduates are turning to part-time and gig work as suitable full-time work becomes harder to find. Fortune Magazine reported on new college graduates turning to gig and entrepreneurial work as entry-level job openings have declined while the number of applicants for the remaining jobs has increased. This has led some to pursue work outside of their formal areas of study. According to data from the Federal Reserve Bank of New York, 41.5% of recent college graduates work in a job that doesn’t require a college degree. 

Breaking down the data by race reveals a couple of interesting trends. First, both the U-3 and U-6 rates are higher for Black and Hispanic graduates compared to White graduates. The unemployment rate for Black graduates peaked at 12.3% in November of last year and then declined by over 5 percentage points (pp) to 6.9%, while the underemployment rate declined only 2 pp over the same period. Despite this decline, Black underemployment remains elevated compared to the beginning of 2025. Similarly, the U-6 rate for Hispanic college graduates has been steadily increasing since mid-2022.

A second important finding from the data is that not only are Black and Hispanic college graduates’ unemployment rates rising, but they are substantially higher relative to White graduates. The Black grads U-3 rate reached a low of 3.3% in March of 2024 and then experienced a spike to 6.9% in April, a 110% increase. For Hispanic grads, their U-3 rate increased by 80% from a low of 4.1% in January of 2025 to 7.3% in April. For White grads, their U-3 rate increased by only 36% from an October 2022 low of 3.18%.

While media attention has focused on unemployment among new college graduates, and rightfully so, it is more endemic for Black and Hispanic graduates. For college graduates overall, the reason for their employment woes has been broadly attributed to a combination of broader labor market weakness and AI changing the hiring decisions of companies. 

Firms facing higher costs, due in part to tariffs, are hiring fewer workers, including recent college graduates. Some of the layoffs result from poor management decisions in the past. For example, some companies over-hired in the post-pandemic boom and have now begun layoffs. These experienced unemployed workers are sometimes competing for jobs alongside new college graduates. These broader labor market trends are negatively impacting job hiring for all workers, including for recent college graduates.

While companies, particularly tech firms, have announced tens of thousands of layoffs this year, the biggest challenge for new entrants to the labor market is the drop in entry-level hiring. Firms are adopting a wait-and-see approach to AI by holding off on hiring junior workers until they better understand the capabilities of AI systems and who they can replace. Additionally, companies that are leaning into AI investments are letting workers go to free up capital for AI spending.

For recent Black and Hispanic college graduates, AI introduces another challenge – algorithmic discrimination. A study from Stanford University found that AI screening tools systematically discriminate against Black applicants. Research from the University of Washington has found that AI resume screening tools can show bias based on an applicant’s name. The tools they reviewed recommended applicants with White-associated names 85% of the time compared to only 9% for applicants with Black-associated names. 

When an AI underwriting algorithm is primarily trained on data from a pool of mostly White applicants, it can favor white candidates to the detriment of Black and Hispanic qualified applicants. A dataset of interactions between biased bank branch loan officers and applicants seeking a small business loan might produce an algorithm that reflects biases of the loan officers. Thus, AI can amplify existing systems of discrimination.

The labor market for recent college graduates is weak not only because of structural reasons like high costs and post-pandemic over-hiring but because of the AI shock. Declining entry-level job hiring is fueled by this dynamic. For non-White college graduates, potential discrimination from AI algorithms, in addition to the AI-related job hiring freezes, is directly affecting their ability to enter the workforce. The labor market is bad for recent college graduates. For Black and Hispanic grads, it’s even worse. 

 

Joseph Dean is the Racial Economic Research Specialist with NCRC’s Research team.

Photo credit: Safari Consoler via Pexels.

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Nashville Summit Series – Brief 4: Barriers & Solutions for Small Business https://ncrc.org/nashville-summit-series-brief-4-barriers-solutions-for-small-business/?utm_source=rss&utm_medium=rss&utm_campaign=nashville-summit-series-brief-4-barriers-solutions-for-small-business Thu, 16 Jul 2026 19:38:26 +0000 https://ncrc.org/?p=289566

Briefs 1 and 2 in this series established the methodology behind the Nashville Summit and the seven structural barriers that cut across the housing, workforce and small business development ecosystems. This fourth brief has a narrower focus that will be of interest to those working in the small business development ecosystem. It documents the barriers raised by practitioners and funders during the small business support dialogues and the solutions participants raised that would work with limited federal government support.

Devin Thompson, Director, Place-Based Strategies

Key Takeaways

1

A broken market where traditional lenders are too slow for entrepreneurs’ needs is driving viable businesses to Merchant Cash Advance lenders that are systematically extracting wealth from entrepreneurs. CDFIs need specialized debt consolidation and training tools to help stabilize entrepreneurs caught in the debt trap.

2

Most technical assistance programs are built to help a business survive the first year rather than build long-term, sustainable community wealth. The model has to shift toward building something an owner can sell, pass on or leverage for future generations.

3

Procurement systems lock many smaller entrepreneurs out because they were designed by and for large businesses. Thus, bonding requirements, reimbursable payment schedules and bundled contract packages all function as barriers to small and minority-owned firms regardless of their track record or quality of work.

Small Business Development & Financing Specific Barriers

In addition to the cross-cutting systemic failures, the small business dialogues identified specific barriers that are suffocating the ability for entrepreneurs from underinvested communities to grow to scale and gain value from their business as an asset:

1. Gaps in Early-Stage Capital and Equity

The market has significant funding gaps in higher-risk areas essential for new business development. While bank capital exists for established firms, there is a lack of risk tolerance for new ventures. This typically surfaces through these specific organizational hurdles:

  • The Pre-Seed Void: There is a critical shortage of pre-seed funding, character-based microloans and early-stage working capital avenues. Early-stage businesses often rely on CDFIs while lacking access to the broader traditional capital needed to survive the initial years. Small-dollar loans, typically under $100,000, are too costly to originate, with revenue failing to cover the costs of origination. This then leads CDFIs to seek subsidies to avoid rates that would be detrimental to the borrower’s business.
  • The Equity Gap: There is a profound void in the equity capital system for minority-owned businesses. Multiple participants raised the issue of venture capital firms often looking for reasons to say no to diverse founders, leaving them without the capital for growth needed to scale. Black, Brown and women entrepreneurs are more likely to be denied by traditional lenders regardless of income level, indicating systemic exclusion.
  • Unequal Cost of Capital: An inequitable structure exists where mission-driven lenders serving higher-risk, lower-wealth populations may pay a higher interest rate for their capital than traditional banks pay. This cost is then passed down, deterring further borrowing and limiting effective business scaling. In turn, many small business owners end up utilizing high-interest, personal credit cards rather than navigating the expensive and complex processes attached to loan products.

2. Harmful Merchant Loans and Debt Consolidation Needs

In the absence of accessible traditional financing, established small businesses are being driven toward failure by predatory financial products. The consequences of this market failure are felt most acutely in these critical areas:

  • The Rise of MCAs: High-interest, Merchant Cash Advances (MCAs) have become a scourge, offering quick cash at usurious rates that trap businesses in a cycle of debt. Entrepreneurs turn to these products because they need cash for emergency priorities and cannot wait for the lengthy underwriting of traditional loans. Many business owners do not understand the true cost of these products (i.e., APR vs. interest rate, etc.). This has created an urgent need for specialized debt consolidation services from CDFIs to rescue viable businesses that are technically profitable but drowning in predatory debt service payments.
  • A Symptom of Systemic Failure: The reliance on non-traditional financial products is not just a sign of a business’ shortcomings but of a broken lending market that is failing the entrepreneurs’ credit needs. Traditional lenders are often too slow for small businesses in distress, leaving predatory options as the only fast capital available. This reality is compounded by rising delinquency rates that mirror the Great Recession, forcing even mission-driven lenders to pull back, further widening the gap that MCAs fill.

3. Deficiencies in Business Fundamentals (TA Mismatch)

There is a mismatch between the technical assistance (TA) provided to small business owners and the actual needs of their business operations. This gap hinders growth and contributes to the loss of valuable community assets. This challenge exists as both a broad misalignment and specific missed opportunity:

  • Survival vs. Strategy: Technical assistance often concentrates on foundational business startup and survival skills, thus delaying, or entirely preventing, entrepreneurs from developing the strategic capabilities necessary for sustainable growth and accessing traditional financing. Many business owners possess excellent technical skills related to their trade but lack the essential habits of business ownership. TA providers frequently dedicate resources to teaching these basic survival skills, a necessity that consumes time and prevents focusing on growth planning with the entrepreneur towards a stage where paying for services would become viable.
  • The “Silver Tsunami’s” Particular Needs: The lack of specialized planning tools and succession models is contributing to the loss of established small businesses due to the aging of their owners, leading to a significant decline in community assets and stable jobs. A noteworthy number of long-term small businesses are closing because their owners are aging out and lack a formal succession plan. This indicates a systemic failure to facilitate the transition of these legacy businesses to new owners.

4. Exclusion from Market Access and Public Procurement

Small, diverse businesses are frequently locked out of the most lucrative opportunities in their own cities due to the dynamic of institutional procurement. This structural lockout is driven by several overlapping policy and administrative failures:

  • Structural Barriers: Some of the barriers have included overly complicated bidding processes and a failure by governments to break down large procurement packages into smaller, accessible contracts. Engaging with these complex government systems forces small businesses to divert precious resources away from revenue-generating work, acting as an implicit tax on participation.
  • Bonding as a Gatekeeper: Mandatory bonding requirements act as a strict gatekeeper, disqualifying smaller firms that lack the financial history to secure them regardless of their ability to do the work. Advocates argue that waiving bonding requirements for contracts under $1 million is essential to opening the market.
  • Market Access: Many small businesses simply do not have access to financial markets that allow them to scale sustainably. The system needs to shift from merely funding businesses to actively helping them build their customer base and their market share. A particularly telling example raised by a participant is that tribal members who wish to build businesses often face severe difficulties in finding commercial properties on tribal lands, forcing capital and talent to leave the reservation for border towns. This concentrates poverty on tribal lands and stifles internal economic development.
  • The Loss of Contracts: In the New Normal, MDIs and organizations serving targeted populations are losing contracts as programs supporting minority-serving institutions come under political attack. This shrinks the customer base for mission-driven lenders, creating a vicious cycle of disinvestment.

Small Business Development & Financing Specific Solutions

Focus TA on Asset Accumulation and Succession

The technical assistance (TA) model needs to be reformed in a way that focuses on feasibility and acquisition strategies. Too many owners treat their business as simply “buying a job” for themselves rather than building a sustainable and scalable entity. We must position the business as an asset that can be bought and sold to ensure generational wealth creation. The following strategic shifts could support generation of entrepreneurial wealth:

  • Mandate Exit Strategy Planning: TA providers should require exit planning from the beginning. This shift requires moving beyond developing a pre-revenue business plan to help someone follow their dream by providing critical analyses of pricing strategies, market feasibility and wealth generating exit strategies. Practitioners must ensure the business is profitable enough to attract future buyers.
  • Facilitate Entrepreneurship Through Acquisition: Address the “silver tsunami” of retiring owners by aligning technical assistance incentives and funding towards acquisition of existing sustainable businesses over seeding pre-revenue startups. Mature businesses with existent cashflow are derisked ventures when compared to start-ups, with significantly lower failure rates. Education on acquisitions and sourcing support are needed to connect emerging entrepreneurs with these opportunities. Models like New Majority Capital provide funds to cover equity, while Project Equity supports employee buyouts to transition workers into owners.
  • Prioritize Real Estate and Commercial CLTs: Owning the building and sharing in the asset’s appreciation is essential for moving up the economic ladder. TA programs must emphasize real estate acquisition. Commercial community land trusts (CLTs) offer a specific mechanism for this. They allow retiring owners to sell their property while ensuring the land remains under community control, preserving the neighborhood’s economic fabric.

Problem
In Miami-Dade County, the racial wealth gap is stark and driven by a lack of assets. For minority small business owners, this manifests as a cycle of perpetual renting, further transferring wealth from their businesses to their landlords. These entrepreneurs generate income, but have reduced opportunities to build their net worth. They remain vulnerable to displacement the moment a neighborhood gentrifies, unable to capture the value they helped create.

Solution
The Miami Foundation launched the Collective Real Estate Ownership (CREO) program to convert small business renters into property owners. The core financial tool is a $500,000 forgivable loan used as a commercial down payment. Unlike other programs, the Foundation required business owners to build joint ventures and operate as collectives to purchase a property together. This structure allows smaller operators to pool their purchasing power, unlocking larger, higher-quality commercial properties that would be out of reach for a single entity.

Implementation
Funded as part of a pandemic-era grant from Wells Fargo, the program functions as a subordinate lender. The $500,000 acts as equity towards securing a primary mortgage from a bank and is paired with additional supports and restrictions:

  • Leveraged Forgivable Loan: The loan is forgiven at a rate of 20% per year over five years. If the owners occupy the property and maintain their partnership for the full term, the loan converts entirely to a grant.
  • Collective Structure: Participants must navigate complex governance issues, such as operating agreements and equity splits. The Foundation found that purpose-built partnerships where businesses had existing relationships, such as a contractor and an architect buying an office together, were far more successful than attempting to match strangers.
  • Technical Assistance: Capital proved insufficient on its own. The program had to provide extensive legal and technical support to help owners structure these joint ventures and navigate the closing process.

Impact
The program deployed approximately $4 million in loans, which leveraged $22 million in real estate assets. Eleven transactions resulted in property ownership for nearly 30 entrepreneurs, demonstrating the efficiency of shared equity models. Participants reported that ownership has fundamentally changed their relationship with local government and their stability in the market.

Lesson
Commercial lenders were hesitant to underwrite owner-occupied collective models, viewing them as riskier than traditional investment properties. This was mitigated over time by engaging senior lenders to negotiate underwriting criteria for participating projects.

Entrepreneurship support needed to be tailored to meet the changing needs of the partnerships, teaching business owners how to manage a physical asset through the structuring of an equity sharing formula, ensuring the strength of the partnership long after the deal closed.

Implement Capital Plus Approaches with Flexible TA

The Capital Plus model integrates mandatory technical assistance directly into the lending process. It stabilizes small businesses and improves overall loan quality by ensuring entrepreneurs have the skills to manage the money they borrow. Operationalizing this more staffing intensive model would have its greatest impact if the following shifts were made:

  • Score Engagement as a Credit Enhancement: Write technical assistance into the loan contract with program participation becoming part of a “character score.” Consistent attendance and communication could serve as proxies for a borrower’s loan repayment reliability. Solution-oriented practitioners should deploy full-time officers to work with applicants for six weeks to three months before a loan is approved. This pre-loan work ensures the business model remains viable and significantly lowers delinquency rates.
  • Deliver Flexibility for Real Schedules: Entrepreneurs are rarely 9-to-5 people and service delivery must match their reality. Some organizations record sessions and create webinars that allow owners to learn during times that are most convenient for their schedules. Online modules allow for the mastering of basic skills at their own pace before moving onto expensive one-on-one coaching. Furthering this with live support to clarify curriculum points with a coach becomes necessary to ensure learning uptake and use.
  • Incentivize Training with Improved Loan Terms: Deep engagement requires more than a mandate: it requires a reward that compensates the entrepreneur for their time. Programs that offer a series of sessions on a variety of topics, such as cash flow planning and bookkeeping. Completing this bundle grants the borrower a tangible financial benefit, such as a meaningful reduction in their interest rate.
  • Target Specific Needs: Capital Plus and similar high-touch models need to be tailored to specific interventions. For example, Baltimore Community Lending explicitly uses different strategic interventions during real estate and small business loan originations. Kiva Access Managers also use similar models to help businesses raise early-stage capital via crowdfunding platforms.

Provide Specialized Debt Consolidation Services

Predatory high-interest debt needs to be convertible into patient capital that supports the entrepreneur’s long-term goals. This solution would extricate established businesses from debt traps caused by products like Merchant Cash Advances (MCAs), thus repositioning them for sustainable recovery rather than liquidation. Supporting businesses escape the predatory lending cycle requires a focused effort on these specific refinancing and intervention measures:

  • Refinance Predatory and High-Interest Debt: The goal is to move businesses from survival mode to financial stability. This involves refinancing predatory loans, which can carry interest rates as high as 80-90%, into sustainable loans with rates around 8-9%. Rather than using rigid traditional underwriting structures, practitioners must use cash flow-based loan structures to determine a business’s actual ability to pay, which creates the breathing room necessary for recovery.
  • Adopt a Foreclosure Prevention Counseling Model: Crises require direct intervention, not gentle coaching. Advisors need to adopt a style similar to foreclosure prevention support programs. This means telling business owners explicitly where they stand financially and what must change immediately to avoid closure. Financial literacy education is also important as it teaches borrowers the critical difference between annual percentage rate (APR) and simple interest, preventing them from falling back into the same traps.
  • Mobilize Patient and Equity-Like Capital: Funding loans for underrepresented entrepreneurs requires capital sources that can wait longer for their repayment. Organizations should utilize equity equivalent (EQ2) funding and other patient capital sources to provide the low-cost capital needed to buy down interest rates. Additionally, equity-like tools that offer deferred or convertible payments can help stabilize a business’s balance sheet by reducing immediate debt service obligations.

Develop High-Quality, Specialized TA

Entrepreneurs are often technically sound but lack the specific back-office capabilities required to navigate complex capital markets. We need professional-grade support in legal, financial and strategic domains. Participants raised a broad array of TA solutions that could be grouped into five paths outlined below:

  • Bridge the Professional Services Gap: Small businesses cannot afford high-end consultants. To fill this void, organizations should leverage skills-based volunteer programs. For instance, Regions Bank provides a model where attorneys and web designers are loaned out to nonprofits for limited engagements to review lease agreements or redesign websites. This also includes specific legal support for setting up Delaware corporations or navigating patent processes for minimum viable products as well.
  • Democratize Financial Language: Formal underwriting terms often alienate established owners. Practitioners must reform TA to use accessible language instead of industry jargon like “debt schedules.” The goal is to ensure a borrower’s verbal narrative supports their actual financials. This helps owners who have operated for years yet struggle to produce a formal balance sheet bridge the gap between their daily reality and banking standards.
  • Focus on Market Expansion: TA should build the entrepreneur’s market access, not just their internal capacity. Programs like Cultivate Small Business teach food entrepreneurs the storytelling skills needed to make their unique business stand out. Providers should also coach businesses on scope expansion, such as helping a janitorial company move from residential cleaning to lucrative commercial contracts.
  • Protect Vulnerable Entrepreneurs: In diverse business hubs like Detroit, TA has morphed into intensive “Know Your Rights” campaigns. These help business owners navigate the complex intersection of immigration status and the business space.
  • Formalize Navigator Networks: Cook County, Illinois developed a navigator program where business service organizations mapped exactly where they fall on the continuum of resource provision. This creates a formal referral network that moves entrepreneurs to the most specialized expert for their current stage rather than trapping them in a generalist loop.

Require Streamlined Procurement Access

Advocate for comprehensive policy reforms to lower the barrier to entry for government and institutional contracts. Small and diverse businesses often struggle to grow not because of their capabilities but because of administrative and financial requirements designed for large corporations. Addressing this structural lockout requires an overhaul of current contracting through these specific policy and accountability reforms:

  • Reform Legislative and Local Policy: Local governments must overhaul their current contracting structures to make them more accessible to a broader array of bidders. This includes waiving bonding requirements for contracts under $1 million and reimagining insurance requirements that exceed a small firm’s capacity. Cities should also move away from reimbursable contracts, which require deep cash reserves that small firms lack. Instead, local governments should directly partner with working capital lenders to provide loans, secured by the contract itself, to bridge the costs before the contractor can seek reimbursement. Large procurement packages should be broken down into smaller increments manageable for Minority and Women-Owned Business Enterprises (MWBEs). Furthermore, policies should require general contractors to demonstrate MWBE use on private projects as a condition for receiving city contracts and subsidies, ensuring that their funding is catalyzing systems change and not solely furthering contract-seeking behaviors.
  • Adjust Selection and Accountability: Selection committees should include local citizens without a financial or social interest in the contract to reduce bias and broaden decision-making power. Specific minority and small business targets should be a mandatory part of the initial contract formation process rather than an afterthought. Business Inclusion Advisory Councils, like the City of Charlotte, North Carolina’s, provide a model for holding local governments accountable to these goals. In tribal communities, internal preference policies should require a community-based procurement preference process before seeking outside corporate services.
  • Streamline Administration Processes: Operating a business isn’t easy, but many jurisdictions have found ways to make it simpler and less burdensome. States like Ohio offer 24-hour turnaround for business licensing. Cities can rezone for pop-up businesses and modular storefronts to provide physical footprints without long-term leases. For developers committed to community benefit agreements, cities should offer expedited review processes as long as businesses remain compliant with previous CBAs. City departments must adopt a business mentality, establishing firm timelines for reviews to reduce the uncertainty that kills momentum.
  • Build Market Connectivity: Business support organizations need to intentionally bridge the gap between entrepreneurs and large-scale buyers of goods and services. Ecosystem-focused organizations, like The Coalition in DC, are building detailed databases for institutional buyers like universities and hospitals to be able to search for diverse suppliers by specific criteria, such as crew size and certifications. In order to effectively address cash flow concerns, these systems should include payment processors for tracking invoices and ensuring timely payments. Physical and digital incubators, such as the Nashville Business Information Center or the Melannaire Marketplace in Louisville, create spaces where small firms build the track record needed to bid on larger contracts.

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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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New Data for Clearer Answers: Tracking Gentrification and Neighborhood Change Across US Cities (1970s – 2010s) https://ncrc.org/new-data-for-clearer-answers-tracking-gentrification-and-neighborhood-change-across-us-cities-1970s-2010s/?utm_source=rss&utm_medium=rss&utm_campaign=new-data-for-clearer-answers-tracking-gentrification-and-neighborhood-change-across-us-cities-1970s-2010s Tue, 07 Jul 2026 17:55:12 +0000 https://ncrc.org/?p=289877 NCRC is pleased to announce the release of a new longitudinal dataset designed to help communities, advocates and policymakers better understand how neighborhoods have changed over time and where gentrification pressures are most evident.

This dataset draws on US Census data spanning multiple decades (from the 1970s through 2010s) and covering thousands of neighborhoods tracking demographic, economic and housing trends at the neighborhood (census tract) level across metropolitan areas nationwide.

Why this matters

Gentrification is one of the most debated topics in the housing and community development fields. Depending on how it’s measured, the same neighborhood can look like a success story or a displacement crisis. This dataset was built to cut through that confusion. It applies five research-tested methods for identifying gentrification so users can see how conclusions shift depending on the approach — and which methods are best supported by real-world evidence.

NCRC’s own research, published in the Journal of Urban Affairs, found that the methods included in this dataset were among the most accurate at tracking actual patterns of class change, racial turnover and housing market pressure. Using these methods, we estimate that roughly 60,000 Black residents left gentrifying neighborhoods in Washington, DC between 1990 and 2020 alone.

This new dataset has provided researchers and advocates with a more transparent and evidence-based way to understand where and how gentrification is occurring.

What’s in the dataset

The dataset includes neighborhood-level indicators over time, such as:

  • Population and demographic change
  • Income and poverty levels
  • Housing values and market activity
  • Employment and occupational shifts
  • Gentrification indicators by decade

These indicators allow researchers to make consistent, decade-by-decade comparisons across thousands of neighborhoods in urban areas nationwide.

What we found

Using this dataset and our evaluation approach, we found that in Washington, DC – one of the most studied cases of gentrification – neighborhoods identified as gentrifying were also the primary sites of significant Black population loss between 1990 and 2020.

However, this does not mean every move was forced. But it does show that population changes were not random as they were concentrated in areas experiencing rapid economic and social transformation.

How this helps communities

This dataset is designed to support:

  • Better public understanding of neighborhood change;
  • More informed policy decisions, including tenant protections and anti-displacement strategies;
  • Targeted investment by focusing resources where pressures are greatest; and allows for more
  • Local analysis, allowing cities to apply consistent evaluation methods to their own communities.

A tool for action

By grounding the measurement of gentrification in real-world indicators, this dataset helps move the conversation beyond competing definitions and toward practical solutions.

When we can clearly identify where change is happening — and who is affected — we are better equipped to protect communities and promote equitable development.

To access the dataset and learn more about the evaluation methods, please see the following resources: 

Funding Sources 

National Institutes of Health’s National Institute on Aging (R01AG080401)

 

 

Bruce C. Mitchell with the Principal Researcher with NCRC’s Research team.

Photo credit: Erik McLean via Pexels.

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Racial Wealth Snapshot Series: Economic Outlook Overview for Native Americans https://ncrc.org/racial-wealth-snapshot-series-economic-outlook-overview-for-native-americans/?utm_source=rss&utm_medium=rss&utm_campaign=racial-wealth-snapshot-series-economic-outlook-overview-for-native-americans Thu, 25 Jun 2026 15:14:41 +0000 https://ncrc.org/?p=289475

Introduction

Native Americans, more formally known as American Indians and Alaska Natives, are people who are indigenous to the North American continent. They are sovereign tribal nations who have control over their land and its people, and whose authority predates the establishment of the United States.

We use the official term American Indian or Alaska Native (AIAN) in this snapshot. A person who identifies as AIAN is either categorized as such by blood or by way of a federally recognized tribe or village by the United States. However, in government surveys, people can choose to identify themselves as AIAN without satisfying either of these requirements.

The US Census has two broad definitions of race. Individuals can either identify exclusively as one race (“alone”) or alongside one or more races (“in combination”). When referencing race/ethnicity statistics in this snapshot, we will specify which definition is being used.

Demographics

In 2025, there were 575 federally recognized tribes, 325 American Indian reservations and 221 Alaska Native villages. However, accurate estimates of the total number of AIAN Americans vary widely. This is in part due to their low share of the total population, which translates into lower representation in surveys.

According to the 2020 US Census, 3.7 million Americans identified as AIAN alone while 9.7 million identified as AIAN alone or in combination with another race. In 2024, 4.3 million individuals identified as AIAN alone, while 7.1 million identified as AIAN alone or in combination with another race.

There has been a dramatic increase in the AIAN population in the last two decades. Because of the ability for respondents to write-in their race and ancestry, the number of people who identify as AIAN in combination with another race increased 160% between 2010 and 2020.

As shown in the chart below, the largest self-identified tribal affiliation is Cherokee, followed by Aztec, Navajo Nation and Maya.

A tribal area is land that is governed by a Native American tribe. They exercise sovereign authority over the laws and commerce on the land, which is typically held in a trust by the United States government. Most people who identify as AIAN alone live outside of a tribal area, with only 24% living on reservations or other tribal lands. For those who identify as AIAN in combination, 95% live outside of tribal lands.

Over half (50.9%) of the American Indian alone population live in five states, with Oklahoma having the largest American Indian alone population (14.2%), followed by Arizona (12.9%), California (9.9%), New Mexico (9.1%) and Texas (4.8%).

Wealth

Due to their small share of the population, those categorized as AIAN are typically excluded from surveys that measure wealth, such as the Survey of Consumer Finances. Because of this, the data on wealth held by AIAN individuals and tribes themselves is sparse. One report using the National Longitudinal Survey of Youth found that the wealth of Native American communities held at about 8.7% of the wealth of the median household ($5,700 for AIAN versus $65,500 for the median household).

Measuring the wealth of tribal nations themselves is also difficult, though some tribes have greater resources than others. For example, some tribal nations have benefited from the proliferation of casinos. About 523 tribal casinos, operated by 251 tribes, produce $39 billion in revenue annually, which constitutes 42% of all annual gaming revenue.

Tribal areas face challenges in accessing credit. While homeownership is the main method most Americans use to generate wealth, none of the three largest home lenders in the US issue federally-guaranteed mortgages for the construction of new permanent homes within tribal lands. Additionally, because of the small size of some tribal communities, certain lenders can dominate the market and establish monopoly power in lending.

Income and Poverty

In 2024, those categorized American Indian and Alaskan Natives alone had a median household income of $59,050. Persons who identified as AIAN who lived on native or tribal lands earned less than those who lived outside of native or tribal lands. The former earned about 66% of the median household income, while the latter earned a slightly higher percentage at 75%.

The chart below shows that the income level for AIAN individuals is similar to that of African Americans and among the lowest of all racial groups:

American Indian and Alaska Natives have the highest poverty rate of all racial groups in the United States. The family poverty rate for AIAN alone individuals is 17.7%. This aggregate figure masks the full extent to which AIAN families living on tribal lands are grappling with poverty. 22% of Native Americans living on reservations have incomes below the poverty line. In addition to differences between on and off-reservation poverty levels, disparities exist between Native tribal nations.

The Navajo Nation Reservation is by far the largest in the United States by land mass, while the Cherokee Nation is the largest reservation by population. The difference in poverty levels between these two nations illustrates the shortcomings of lumping all AIAN communities into one. According to the 2024 American Community Survey 5-year estimates, 32% of Navajo Nation families have incomes below the poverty level. For the Cherokee Nation, one of the wealthier Native nations, only 12% of families live in poverty. Other smaller nations have even higher levels of poverty. For example, 48% of families on the Pine Ridge Reservation in South Dakota live in poverty.

Work and Labor

American Indian and Alaska Natives work across a diverse range of occupations. While they are less likely to work in management/professional roles compared to the general population, they are more likely to work blue-collar jobs in industries such as natural resources, construction  logistics and service occupations. AIANs are distributed among industries similarly to the overall population, with healthcare and education (22.2%), retail trade (11.4%) and professional services (11%) industries comprising the largest employers.

The chart below shows the distribution of occupations and industries that individuals classified as AIAN alone and in combination are employed in:

One unique labor force characteristic of AIAN individuals is that they are substantially more likely to work in the public sector. Because tribal governments are sovereign entities, they can employ their own citizens to operate services. Additionally, some federal agencies have specific mandates to hire Native Americans. Because of these reasons, AIANs are more likely to work for a public sector employer than non-AIAN workers.

19% of AIANs work in federal, state, local or tribal governments compared to 15% of the overall population. AIANs who live in a tribal area are even more likely to work for the public sector, with 38% working for a governmental entity in some capacity.

Education Attainment

College enrollment among AIANs is significantly lower than in the overall population. In 2022, only 26% of the 18 to 24-year-old AIAN alone population was enrolled in college compared to 39% of the total population. Like most groups, the college enrollment rate has remained unchanged from 2012 to 2022.

Additionally, American Indians and Alaska Natives lag behind other Americans in college attainment as indicated in the chart below:

Among those 25 years and older who were categorized as AIAN alone, 16.4% held a bachelor’s degree compared to 35% of the overall population. For AIANs who live on reservations, the figure is even lower at 10.3%. While 10.3% is a low rate, it is a 125% increase since 1990, indicating substantial progress has been made for AIANs who live in tribal and native areas.

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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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Black Men Face a Worsening Jobs Market: May 2026 Race, Jobs and Economy Update https://ncrc.org/black-men-face-a-worsening-jobs-market-may-2026-race-jobs-and-economy-update/?utm_source=rss&utm_medium=rss&utm_campaign=black-men-face-a-worsening-jobs-market-may-2026-race-jobs-and-economy-update Thu, 21 May 2026 14:00:45 +0000 https://ncrc.org/?p=287097 As the economy roils from the shockwaves of the tariff/trade war of last year and the ongoing and intensifying energy shock from the Iran war, the unemployment rate remains low at 4.3%. 100,000 jobs were added in April, which was the first consecutive month of positive growth since April of 2025. 

Despite the positives in the April jobs report released by the Bureau of Labor Statistics (BLS), closer scrutiny of the data reveals ongoing weaknesses in the labor market. An examination of the employment situation facing Black men helps elucidate these negative trends, including their falling labor force participation rates, sluggish job growth and rising long-term unemployment. 

The BLS defines a worker as unemployed if they have actively looked for a job within the previous four weeks. A more expansive definition of unemployment includes part-time workers who seek but can’t find full-time work and those who want a job but have not actively looked for work because they believe no quality positions exist. The BLS also tracks this expanded definition of unemployment, formerly called the U-6 rate or underemployment rate. 

The chart below shows the underemployment rate by race and sex from 2022 to the present:

The underemployment rate increased throughout the first 3 quarters of 2025, then declined during the 4th quarter of 2025 and during the 1st quarter of 2026. One would assume that more people are moving from underemployment to employment. 

Unfortunately, this assumption is not true for Black men, with the labor force participation rate shown below explaining the reasons behind this trend:


While the number of unemployed Black men declined, so did the number of Black men in the labor force. We can see this in the chart above which shows that their labor force participation rate also declined over this same period. This suggests that, rather than more Black men finding employment, many are simply leaving the labor market entirely.

Given that these were working-age men, one could assume they are not leaving the labor force due to retirement but rather due to feelings of discouragement or an inability to find work. In fact, the number of employed Black men over 20 years old has declined by roughly 650,000 since November 2025.

This pattern of declining labor force participation and underemployment is unique among Black men. The labor force participation rate for all other groups held constant or increased, while the Black male labor force participation rate declined over 2025 and early 2026.

One explanation for why increasing numbers of working age Black men are leaving the labor force could be that their largest sectoral employer, logistics, is experiencing a multi-year slump. Due to changes in freight demand, tariffs and rising costs, the logistics sector has seen virtually no job growth since the summer of 2022. Furthermore, just one year since President Trump announced his tariff/trade war, the transportation and warehousing sector has lost almost 90,000 jobs, including 22,000 truck drivers and 50,000 warehouse positions.

These job losses will only worsen as the energy crunch from the Iran war continues to spike fuel prices globally. The jet fuel shortage has already led to the closure of Spirit Airlines. The transportation sector will experience more job losses and bankruptcies if the situation doesn’t change, with many of the losses impacting Black men. 

One area where these job losses are showing up is in the rise of the long-term unemployed as shown in the chart below: 

The share of the unemployed who have been jobless for longer than 27 weeks is now over 26% and continues to rise as illustrated by the chart above. This has pushed the average number of weeks people are unemployed to roughly 25 weeks. Among the number of unemployed Black men, 30% have been jobless for longer than 27 weeks, the highest of any racial/ethnic group.

The employment situation of Black men highlights several growing issues facing workers overall, such as rising long-term unemployment rates and heavy job losses across multiple sectors. While policies that uplift Black men specifically have become politically toxic, measures like ending the tariff/trade war and expanding unemployment benefits (which was done during the COVID-19 pandemic) can help all workers, including Black men.

 

Joseph Dean is the Racial Economic Research Specialist with NCRC’s Research team.

Photo credit: Mukhtar Stuaib Mukhtar via Pexels.

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After 15 years of bank closures, new branches are having a resurgence https://ncrc.org/after-15-years-of-bank-closures-new-branches-are-having-a-resurgence/?utm_source=rss&utm_medium=rss&utm_campaign=after-15-years-of-bank-closures-new-branches-are-having-a-resurgence https://ncrc.org/after-15-years-of-bank-closures-new-branches-are-having-a-resurgence/#comments Thu, 14 May 2026 15:13:40 +0000 https://ncrc.org/?p=286679 Bank branch changes, Q1 2026

The national bank branch network grew for the second consecutive quarter in the first three months of 2026, marking the first back-to-back expansion since 2010. 267 full-service branches were opened between January and March while 217 branches were closed, producing a net gain of 50 locations. This follows the fourth quarter trend that occurred in 2025 when the network grew by 71 branches, breaking a 15-year streak of uninterrupted contraction. In 65 quarters of data tracking going back to 2010, only four have been positive and only two have occurred consecutively.

The reversal is striking in the context of the industry’s recent history. In 2022, NCRC documented in its The Great Consolidation of Banks and Acceleration of Branch Closures Across America report the ways in which the pandemic had doubled the pace of branch closures, from roughly 99 per month in the decade before COVID-19 to more than 200 per month thereafter. That report also found that two-thirds of all banking institutions had disappeared since the early 1980s and that 9% of all branches closed between 2017 and 2021.

One in three of those closures was in a low- to moderate-income or majority-minority neighborhood. Four years later, the closure wave has subsided and the network is growing again. The growth is concentrated entirely in traditional standalone branches, while in-store retail locations are closing at three times the rate and virtually no new branches are opening in their place.

That growth, however, is not happening everywhere. 67 new branches were added in the Southern region of the US during this quarter, with Texas and Florida seeing the largest gains. The Midwest flipped from contraction to growth. But, the Northeast continued to lose branches, with the closures that did occur remaining heavily concentrated among a small number of large institutions. The geographic pattern of branch expansion closely tracks where the country’s population is growing, particularly in metros attracting younger and more diverse communities.

For a more detailed look at bank branch changes in your community, contact NCRC’s research team at research@ncrc.org.

Where branches opened and closed

The following map shows every full-service branch that opened or closed during the first quarter of 2026. Yellow markers indicate openings and red markers indicate closures. Click any marker for the bank name, branch name and address or use the dropdown to filter by bank name.

 

Bank branch openings and closures, Q1 2026

267 branches opened and 217 closed between January and March 2026. Click any marker for details.

The map reveals the geographic concentration of the quarter’s activity. Branch openings tend to cluster in the Sun Belt, particularly across Texas, Florida and the Southeast, while closures are more dispersed across the Northeast and California. Several of the largest closure clusters correspond to individual corporate decisions by TD Bank and Bank of America rather than a broad market retreat from those communities.

The national picture

The following chart compares branch openings and closures across the five most recent quarters, showing how the balance between the two has shifted from sustained contraction to consecutive growth:

 

While the chart tells the story of what happened, the why matters even more. The turnaround came almost entirely from the closure side: banks sharply reduced the number of branches they shut down, while the pace of new openings held roughly steady. That means the industry did not suddenly accelerate its expansion but in fact reduced closures. Whether this reflects a deliberate strategic shift or simply the lack of easy closure targets after years of aggressive consolidation is a question the coming quarters will help answer.

The growth is not evenly distributed across branch types. There are full service, brick and mortar locations, which often have full service features like drive through tellers, parking and ATMs. There are also in-store locations mostly in grocery stores or large retailers.

The following chart compares the quarterly closure rate for each branch type as a percentage of its baseline by putting the two on equal footing despite their very different network sizes:

 

The chart shows the gap clearly: banks are abandoning the in-store model. The branches inside grocery stores and retail locations that were prevalent in the 1990s and 2000s are being systematically wound down, while traditional standalone branches are the only bank type showing growth. For communities that relied on an in-store branch as their primary access point to banking services, this shift may effectively function as a closure even if the bank maintains a traditional location elsewhere in the metro area.

82 branches were relocated during the quarter. Most moved less than a quarter of a mile from its original location. However, relocations did not change the total number of branches and were excluded from the final opening and closing counts. The nation’s bank branch network currently stands at 74,511 full-service locations.

Where the banking industry is investing

The following chart shows the five metropolitan areas with the largest net branch gains during the first quarter alongside their performance in the same quarter one year ago:

 

Dallas-Fort Worth, Texas saw the highest net gain out of all of the metros during the first quarter with six branches, representing the biggest year-over-year increase for any market in the country at +15. One year ago, Dallas-Fort Worth lost nine branches. Nashville, Tennessee added five net branches, with Pittsburgh, Pennsylvania gaining four with zero closures after posting losses in the prior quarter.

Out of the five metros with biggest net gain in branches two are in Texas and two are in the Southeast region. Four of the five are among the fastest-growing metropolitan areas in the country by population. Pittsburgh is the exception, posting branch gains despite a flat regional population, suggesting bank investment there is driven by market repositioning rather than demographic growth. St. Louis and Seattle both went from negative losses to positive growth year-over-year. Texas accounted for three metros that ranked in the national top 15 for branch growth.

Where branch networks are contracting

The following chart shows the five metropolitan areas with the largest net branch losses during the first quarter alongside their performance in the same quarter one year ago:

 

No metropolitan area lost more than six branches during the first quarter. This represents a significant improvement from one year ago, when several major metros posted double-digit losses. New York remains the market with the largest net contraction, though its losses improved from nine to six year-over-year. San Francisco showed the most dramatic improvement of any major metro nationally, going from 12 net closures in the first quarter of 2025 to just three in the first quarter of 2026.

Chicago also improved substantially, from 10 closures a year ago to four. Washington, DC and Minneapolis were the only major metros with the steepest net declines that performed worse than one year ago. California continues to have multiple metros experiencing contraction, with Los Angeles, San Francisco and Sacramento, CA all posting net losses.

Regional patterns

The following chart compares each census region’s net branch change in the first quarter of 2026 to changes shown in the same quarter one year ago, showing where the reversal is concentrated:

 

The South is driving the national growth story. The states gaining branches are the same states gaining population, particularly through the growth of Hispanic, Black and Asian communities. The Census Bureau estimates show that Texas, Florida, North Carolina, Georgia and Arizona attracted the most immigrant populations between 2020 and 2023, with branch expansion  following those same migration patterns. However, reversals in immigration and the threat of an executive order targeting banks that serve immigrant depositors threaten to reverse this trend.

The Midwest posted the biggest regional reversal, shifting from a net loss of 46 branches in the first quarter of 2025 to a gain of nine in 2026. The Western region of the country improved substantially, though California’s ongoing consolidation kept the region in negative territory. The Northeast was the only region that showed no improvement, reflecting both its population decline and the concentrated closures by TD Bank and other large institutions headquartered in the corridor.

California and New Jersey continue to lead when it comes to state-level contraction. New Jersey’s persistent presence at the top of that list reflects structural consolidation in a mature, densely branched market rather than a sudden retreat.

Which banks are driving the changes

More than 200 banks had at least one branch opening or closing during the first quarter. But, the activity is not evenly distributed, with the pattern differing sharply between openings and closures.

Branch closures are heavily concentrated among a small number of large institutions. Three banks (TD Bank, Bank of America and JPMorgan Chase) accounted for nearly half of all closures during the quarter. TD Bank was responsible for nearly a quarter of all closures nationwide, shuttering 51 branches with zero openings in the Northeast region. Without TD Bank’s closures, the national net gain would have been 101 branches.

The following chart shows the 10 banks with the most branch closures during the quarter:

 

Branch openings are far less concentrated. JPMorgan Chase leads with 36, followed by Fifth Third Bank with 19 and Bank of America with 16. However, 26 different banks account for half of all openings. By contrast, just three banks account for nearly half of all closures. In other words, while some banks are still closing large numbers of their branches, many more banks are seeing a gradual expansion of their networks.

The following chart shows the 10 banks with the most branch openings during the quarter:

 

Community and regional banks are a significant part of the story. Of the 208 banks with any branch activity during the quarter, 164 had exactly one opening or one closing. These single-event institutions represent nearly 80% of all active banks and collectively account for a third of all branch activity nationwide.

Fifth Third Bank had the largest single-quarter net gain of any institution, adding 18 net branches on 19 openings with just one closure. Wells Fargo opened seven branches and closed none, its first positive quarter after five consecutive quarters of contraction. Whether this signals a strategic shift remains to be seen. JPMorgan Chase remains the dominant force when it comes to expansion, with a cumulative net gain of 128 branches over five quarters.

Counties at risk

Despite the overall positive trend, 209 counties nationwide currently have just one full-service bank branch. Texas has 22 single-branch counties, Montana has 15, Georgia has 14 and Colorado has 11. When a county’s last branch closes, residents must travel to a neighboring county for basic banking services, a round trip that can exceed 30 miles in rural areas.

What this means for communities

The geographic alignment between branch network changes and population trends is consistent and persistent. Branches are opening where people are moving and where Hispanic, Asian and Black communities are growing. They are closing where populations are aging and shrinking. The Census Bureau population estimates show that communities of color drove essentially all of the nation’s population growth between 2020 and 2023, with the nation’s population under age 18 already being majority-minority. The banking industry’s physical infrastructure is following these demographic currents.

The metros gaining the most branches are also among those most dependent on immigration-driven population growth. The Census Bureau projections indicate that without sustained immigration, the nation’s working-age population would begin to decline within the next two decades. Significant reductions in immigration levels could slow population growth in the Sun Belt metros where branch expansion is concentrated, potentially undermining the economic conditions that are attracting bank investment in the first place. For communities that have only recently gained banking access as their populations grew, that reversal would compound an already fragile situation.

This raises questions that the branch counts alone cannot answer. Are new branches in growing metros reaching the low- and moderate-income neighborhoods and majority-minority census tracts where population growth is concentrated or are they clustering in higher-income corridors? Under the 1995 Community Reinvestment Act (CRA) rules, which remain in effect after the withdrawal of the 2023 CRA modernization rule, a bank’s community development obligations are tied to the geographic areas where it operates physical branches. As the branch network shifts, so do the areas where regulators evaluate whether banks are meeting community needs.

Community organizations and regulators should examine whether branch openings in high-growth metros are serving the communities responsible for that growth. NCRC members can access this data by contacting the NCRC research team.

Methodology

This analysis uses data from the Federal Deposit Insurance Corporation (FDIC) BankFind Suite, which tracks individual branch openings and closures as they are filed. Branch openings are identified by FDIC change code 711 and closures by change code 721. Only full-service branches are included, which would be classified as either service type 11 (brick-and-mortar) and service type 12 (retail). Quarters are assigned by the FDIC processing date. Branch relocations, mergers and acquisitions are excluded from opening and closing counts to avoid double-counting.

The FDIC provides two separate datasets for tracking bank branch networks. The BankFind Suite tracks individual branch openings and closures as they are filed, making it the preferred source for quarterly trend analyses. The Summary of Deposits provides an annual snapshot of all branches as of June 30 of each year, including deposit volumes and census tract mappings. Branch counts may differ between the two datasets due to different inclusion criteria and reporting timelines.

Regional classifications follow the US Census Bureau definitions. Metropolitan area definitions follow the Office of Management and Budget’s Core Based Statistical Area (CBSA) boundaries. This report uses common metropolitan names in tables and text. Full CBSA definitions with component counties are listed below.

The population and demographic data cited in this report are drawn from the US Census Bureau population estimates covering April 2020 through July 2023. The data is current through March 31, 2026.

Metropolitan area definitions

Atlanta — Barrow, Bartow, Butts, Carroll, Cherokee, Clayton, Cobb, Coweta, Dawson, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Haralson, Heard, Henry, Jasper, Lamar, Meriwether, Morgan, Newton, Paulding, Pickens, Pike, Rockdale, Spalding and Walton counties in Georgia.

Austin — Bastrop, Caldwell, Hays, Travis and Williamson counties in Texas.

Boston — Essex, Middlesex, Norfolk, Plymouth and Suffolk counties in Massachusetts; Rockingham and Strafford counties in New Hampshire.

Chicago — Cook, DeKalb, DuPage, Grundy, Kane, Kendall, Lake, McHenry and Will counties in Illinois; Jasper, Lake, Newton and Porter counties in Indiana; Kenosha County in Wisconsin.

Dallas-Fort Worth — Collin, Dallas, Denton, Ellis, Hunt, Johnson, Kaufman, Parker, Rockwall, Tarrant and Wise counties in Texas.

Los Angeles — Los Angeles and Orange counties in California.

Minneapolis — Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Le Sueur, Mille Lacs, Ramsey, Scott, Sherburne, Washington and Wright counties in Minnesota; Pierce and St. Croix counties in Wisconsin.

Nashville — Cannon, Cheatham, Davidson, Dickson, Macon, Maury, Robertson, Rutherford, Smith, Sumner, Trousdale, Williamson and Wilson counties in Tennessee.

New York — Bergen, Essex, Hudson, Hunterdon, Middlesex, Monmouth, Morris, Ocean, Passaic, Somerset, Sussex and Union counties in New Jersey; Bronx, Kings, Nassau, New York, Putnam, Queens, Richmond, Rockland, Suffolk and Westchester counties in New York; Pike County in Pennsylvania.

Pittsburgh — Allegheny, Armstrong, Beaver, Butler, Fayette, Washington and Westmoreland counties in Pennsylvania.

San Diego — San Diego County in California.

San Francisco — Alameda, Contra Costa, Marin, San Francisco and San Mateo counties in California.

Washington, DC — District of Columbia; Calvert, Charles, Frederick, Montgomery and Prince George’s counties in Maryland; Arlington, Clarke, Culpeper, Fairfax, Fauquier, Loudoun, Madison, Prince William, Rappahannock, Spotsylvania, Stafford and Warren counties and the independent cities of Alexandria, Fairfax, Falls Church, Fredericksburg, Manassas and Manassas Park in Virginia; Jefferson County in West Virginia.

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Nashville Summit Series – Brief 3: Barriers & Solutions for Affordable Housing https://ncrc.org/nashville-summit-series-brief-3-barriers-solutions-for-affordable-housing/?utm_source=rss&utm_medium=rss&utm_campaign=nashville-summit-series-brief-3-barriers-solutions-for-affordable-housing Tue, 12 May 2026 13:15:28 +0000 https://ncrc.org/?p=286634

Briefs 1 and 2 established the methodology behind the Nashville Summit and the seven structural barriers that cut across the housing, workforce and small business development ecosystems. This brief narrows the focus to those items that are specifically of interest for advocates of affordable housing, the barriers that surfaced specifically in the affordable housing dialogues and the solutions participants identified as most likely to move the needle.

Devin Thompson, Director, Health Equity and Impact

Key Takeaways

1

The affordable housing stock we already have is being lost faster than new units can replace it, which makes preservation as urgent as production. A strategy focused solely on new construction is guaranteed to not keep pace.

2

Local restrictions and organized neighborhood opposition do more to block affordable housing than any single funding shortfall. The path to overcoming these structural barriers require significant political will to reform zoning codes, provide incentives and redefine state vs local authority.

3

 Lenders and regulators treat affordable housing’s credit risks with a similar lens as luxury apartments, which results in a mismatch that increases the cost of capital. Updating underwriting logic and building enterprise-level pre-development funds would expand the field without requiring new subsidy dollars.

Affordable Housing Specific Barriers

In addition to the cross-sector systemic failures, the housing dialogues identified specific barriers that are suffocating the production and preservation of affordable units:

1. Restrictive Local Regulations

Participants identified that local land use regulations are frequently weaponized to block affordable development. This goes beyond standard administrative bureaucracy and has resulted in the active restriction on the types of housing that can be built. The three major local regulatory barriers that surfaced in the dialogue groups were:

  • Prohibition of Diversity: The dominance of restrictive single-family zoning is a persistent barrier, severely limiting the ability to create necessary density in the areas that need it most. This focus on single-family homes comes at the expense of diverse housing types like duplexes and multi-family units, which are often the most affordable options and allow for development without displacement. While some states like Oregon have moved to reform these codes, the legacy of restrictive zoning continues to hinder progress in most regions.
  • The “Tunnel” Problem: Even when diverse housing types like Accessory Dwelling Units (ADUs) are technically allowed, specific (often nonsensical) rules are used to obstruct them. One participant recounted being forced to build a non-essential, enclosed breezeway to attach an ADU to a main house simply to meet a rigid definition of attachment in the local code. This regulatory hostility discourages flexible, multi-generational housing solutions.
  • Resistance to Modern Methods: Policy resistance often prevents the adoption of cost-effective techniques, like modular housing, which offers a 20% cost savings over traditional construction. Antiquated views associating modular homes with manufactured housing (i.e., mobile homes) lead to a refusal to adopt model codes, effectively banning high-efficiency building types that could rapidly increase supply.

2. High Development Costs and Fees

Project viability is being crushed by exorbitant infrastructure and operational costs that extend far beyond the price of lumber. Some other costly expenditures that surfaced via the dialogue groups were as follows:

  • Exorbitant Municipal Fees: High development costs are often a direct result of governmental policy and underinvestment. Utility activation fees, particularly for water and electricity, have become a massive burden. In Detroit, utility activation fees for a single infill house were cited as running between $60,000 and $70,000, a cost that developers argue makes scaling on vacant lots financially impossible. In Nashville, connecting a house to the water system rose from $8,000 to $20,000. These fees are layered on top of substantial pre-development costs, which creates a hurdle that is insurmountable for smaller developers in an unstable funding environment.
  • Crushing Operational Costs: Existing affordable housing stock is under threat from drastic spikes in ongoing expenses. Insurance premiums have become a deal killer, with multiple participants citing increases in excess of $50,000 in a single year for their multi-family properties. In some Florida jurisdictions, homeowners’ insurance has doubled over the last four years. This is compounded by increasing property taxes, with Nashville participants having seen property taxes increase by 50% in four years due to rising appraisals. For low-income homeowners, this combination can push monthly payments from $800 to $1,400, creating a financial nightmare that puts them at risk of foreclosure.
  • The Maintenance Crisis: Rising costs leave no room for reinvestment. Owners struggling with insurance and tax hikes and tenants struggling to pay rent cannot afford maintenance, leading to a cycle of disrepair. In Minnesota, one participant’s request for $250,000 to upgrade fire safety in a 35-year-old building was denied, with the government ultimately spending $300,000 to demolish the property instead.

3. Local Political Veto Power (NIMBYism)

Affordable housing projects are frequently blocked by intense local political opposition that leverages structural power to bypass broader planning and community goals. This veto power manifests through specific, often hyper-local mechanisms that prioritize individual neighbor resistance over neighborhood needs. This structural lockout is driven by several overlapping dynamics:

  • Councilmanic Prerogative: In cities like Philadelphia, the local government structure grants individual council members “councilmanic prerogative,” effectively allowing them to act as a mini-mayor in their district. This unwritten but powerful rule allows a single politician to unilaterally veto affordable housing developments that do not align with their personal or political interests, bypassing broader city planning objectives. This power is so entrenched that when the mayoral administration attempted to pass an $800 million housing bond that included limits on the council’s say over development, the City Council refused to even entertain the conversation. This troubling dynamic plays out in many other jurisdictions as well. Participants from across the country cited instances where a council person stymied their affordable housing development. In one instance, a project was canceled simply because they disliked a consultant on the project.
  • Political Gridlock: Infighting within the board of aldermen can create immense legislative gridlock, often falling along geographic and racial divides. Opposition is frequently raised based on perceived turf wars or the feeling that a neighborhood “got skipped [over],” making it challenging to advance any cohesive housing strategy.
  • “Squeaky Wheel” Opposition and Negative Advocacy: Local opposition frequently mobilizes at the town hall level, where the loudest voice can often dominate. Developers report that too often only negative opposition shows up to planning meetings, while the beneficiaries of the project are often absent. This negative input is highly influential in overturning decisions made by planning commissions.
  • Weaponized NIMBYism: NIMBY (Not In My Backyard) tactics often center on preserving “character” or greenspace over community needs. In a Denver redevelopment case involving a golf course, opposition focused on preserving acres of greenspace, though advocates were eventually able to shift the conversation toward affordable housing benefits. However, in other instances, opposition proves fatal. Despite a for-profit developer agreeing to a robust Community Benefits Agreement, including covering property tax increases for eight years, the plan was voted down in a city-wide ballot initiative in a campaign powered by NIMBYism and parochial concerns. Even when non-profits secure donated land, they face aggressive resistance when attempting to change zoning to allow for workforce housing.
  • Secondary Consequences: This political hostility introduces paralysis and inflated costs. The environment of significant unease slows down project planning as political will evaporates. Successfully navigating zoning battles adds massive pre-development costs, severely impacting financial viability. Furthermore, local officials often engage in performative actions using language that frames housing beneficiaries as unworthy, which kills the political capital needed to move forward.

4. Institutional Knowledge and Complexity

Knowledge gaps are creating programmatic dead ends, particularly in communities that have been historically excluded from the financial system. Broadly, these barriers appear at the local level in a couple of ways:

  • Gaps in Financial Fluency: Across historically disinvested communities, a lack of technical finance literacy among local leadership acts as a severe impediment to development. Because these communities have been systematically excluded from traditional capital markets, leaders often lack the procedural memory of complex housing or economic development finance. This creates a reliance on outside consultants and slows the decision-making process. Multiple participants mentioned that this dynamic is particularly acute in Native American communities, where leaders often operate under the assumption that housing is the sole domain of authorities rather than private markets. This is exacerbated by high turnover through term limits, meaning that once a leader is brought up to speed on financial concepts they leave office, forcing partners to restart the education process. Similarly, small nonprofits and faith-based groups often own land but lack the tools to monetize it, leaving valuable community assets underutilized.
  • Tangled Title and Heir’s Property: In both urban centers and the rural Southeast, the Tangled Title/Heir’s Property dynamic (real assets with multiple owners through inheritance) is an insidious, invisible barrier wiping out generational wealth. Because legal ownership cannot be confirmed, families cannot access home equity loans and other tools to provide the necessary capital to pay for maintenance. This creates a cycle of disrepair, leading to the loss of their equity. This crisis is fueled by a profound lack of consumer education on how to legally protect property, turning what should be an asset into a liability that is eventually lost or demolished.

5. Inflexible Unit Targeting

The current subsidy models are creating a paradox where units sit empty despite high demand. Participants criticized the rigid use of Area Median Income (AMI) targets, noting that they often exclude the most vulnerable populations (those at 30% AMI and below) in favor of the “missing middle” (those that make 80% to 120% of their area’s AMI). We heard participants break this challenge down into two broad categories:

  • The Vacancy Paradox: The misalignment between Coordinated Entry Systems and specific unit eligibility rules results in a logistical failure where vacant affordable units remain unoccupied because the applicant at the top of the waitlist does not match the precise funding criteria assigned to that unit. This issue is an unintended consequence of overlapping policy decisions, with the result being providers that are punished financially for having empty units, which in turn can make the government reluctant to provide further support.
  • The Compliance Dilemma: This rigidity extends to tenant stability as well. One example involving the Neighborhood Stabilization Program (NSP) was raised in relation to an organization that faced a crisis when two tenants received raises that pushed their income just 6% over the limit. The organization was forced into an impossible choice: fall out of compliance and risk their funding or evict stable, paying tenants from their housing. This demonstrates how unforgiving policy mandates can actively disrupt household stability, punishing tenants for the very economic success the system claims to want.

6. Lack of Specialized Pre-Development Capital

The riskiest money is unsurprisingly the hardest to find. Developers struggle to access pre-development financing, the very capital needed to get a project going. Without consistent, large-scale, enterprise-level funding to mitigate this early-stage risk, many potential projects die before they ever reach the permit office. These gaps limit nonprofit developers in the following ways:

  • The Cost of Entry: Pre-development costs can escalate quickly, potentially reaching millions of dollars before a developer even breaks ground. These are soft costs like initial architectural and engineering plans, permitting fees and professional costs/legal fees tied to environmental impact assessments that must be paid upfront. If a deal falls through due to rising costs or political shifts, this money is often lost entirely, making potential investors extremely hesitant to commit early and leaving many nonprofit developers one failed development away from insolvency.
  • The Funding Gap: There is a critical shortage of the soft monies needed to make projects viable. In Louisville, for example, funding requests to the government for this specific stage totaled over $70 million, while only $12.5 million was available. This massive gap acts as a gatekeeping mechanism, ensuring that only the most well-capitalized developers can afford to play, while smaller, community-based nonprofits can be effectively locked out of leading development in their own neighborhoods.
  • The Scale Problem: Small organizations are often trapped by their own size. Built for incremental change, they lack the upfront capital required to hire the specialized staff needed to secure larger, complex financing. This creates a vicious cycle where they cannot grow because they cannot access capital and they cannot access capital because they haven’t grown. Furthermore, money is often more expensive for these organizations, with one participant noting that funds given to a CDFI for pre-development work often come with higher costs than if secured elsewhere, penalizing the very institutions designed to help solve this gap in service to the market.

Affordable Housing Specific Solutions

Develop Permanent Affordability Models

Innovative tenure models and financial structures are needed to allow residents to build equity while ensuring properties remain affordable for future generations, effectively decoupling housing from the speculative market. Participants identified several distinct pathways to ensure properties remain affordable for generations:

  • Establish Community Land Trusts (CLTs) and Land Bank Partnerships: Nonprofits acquire land and hold it in a trust by using 99-year ground leases to keep the property affordable in perpetuity. This separates the cost of the land from the building. Partnering these trusts with land banks allows for the efficient transfer of property. One innovative approach involves homeowners deeding their land to the trust in exchange for funds to make repairs, allowing them to stay in their homes while the trust provides long-term housing affordability.
  • Scale Shared Equity and Cooperative Ownership Programs: Traditional subsidized homeownership can’t be the only model of wealth building. In shared equity programs, a homebuyer might take a reduced mortgage (i.e., 74% loan-to-value) while a fund covers the rest. When they sell the property, they split the appreciation with the fund. This puts cash in the seller’s pocket and recycles money back into the program.
  • Launch Renter Equity Pathways: Not everyone can buy a home, which unnecessarily locks many communities out of wealth creation. Rent-to-own structures and programs take a portion of on-time rent payments and put it into a savings account for the tenant, sometimes even offering equity in the building’s future sale. Organizations should also engage large rental portfolio owners about their exit strategies to encourage them to transfer assets into non-speculative, affordable ownership rather than using market-rate conversion tactics.
  • Prioritize Economic Viability: We cannot rely solely on complex, expensive subsidies like the Low-Income Housing Tax Credit (LIHTC). Models should aim for a mixed city approach where fees on market-rate units cross-subsidize affordable ones. This creates resilience against economic downturns.

Reform Zoning and Land Use Regulations

Advocate for legislative and policy reforms to increase housing supply and unlock development potential by removing artificial legal barriers that restrict housing density and types. Increasing housing diversity at the local level could be impacted by implementing any of these reforms:

  • Advocate for State-Level Intervention and Incentives: Local resistance often stalls progress but provides an opportunity for  state governments to show leadership in support of the common good. States should have the authority to approve projects that meet specific parameters even if local boards object. Federal and state governments should also use financial incentives to encourage cities to update their zoning laws voluntarily.
  • Implement Form-Based Zoning and Density Bonuses: Cities should shift from unit-based zoning to form-based zoning. This allows developers to place multiple units, such as three townhomes, on a land footprint that used to hold a single house. These density bonuses should be tied to affordability requirements to ensure the new supply serves the entire community.
  • Legalize Diverse Housing Types: Outdated ordinances block essential housing options. Codes must be streamlined to allow for the creation of more Accessory Dwelling Units (ADUs) and multigenerational housing developments. Legislation could allow property owners to sell ADUs separately from the main house to create individual wealth and increase tax revenue. Cities should also identify micro-plots eligible for tiny homes. However, design standards should remain in place to prevent the construction of low-quality structures that reduce the perceived value of a neighborhood.
  • Leverage Community Benefits Agreements (CBAs): Zoning flexibility creates value for developers. Given this, the community should also be able to share in those financial returns. Formalize the use of Community Benefits Agreements (CBAs) where zoning changes for large developments are exchanged for binding commitments to build affordable units and hire local workers.

Problem

The primary barrier to affordable housing in many high-opportunity communities is often of a regulatory nature rather than a financial one. Local zoning codes create ecosystems where fully funded projects fail during permitting.

Voluntary compliance with state mandates resulted in plans that satisfied administrative requirements but, without firm consequences for failure to implement the plans, did not lead to actual production. Developers lacked recourse when viable projects were denied based on local character or density preferences.

Solution

State-level zoning preemption, often called the Builder’s Remedy, shifts the approval authority from local to state government under specific conditions. The state establishes an objective housing target and, if a municipality fails to meet that target, it loses the ability to enforce its zoning codes against qualifying affordable housing projects.

This flips the burden from developer to municipality, making the default stance to build the needed housing. Instead of a developer requesting a variance, the municipality needs to prove that a project presents a specific, quantifiable health or safety risk. Without that proof, the project proceeds “by right.”

Implementation

In all cases, implementation relies on a “trigger” mechanism that activates the remedy when a town falls out of compliance.

In California, the Housing Accountability Act states that if a city fails to get its eight-year Housing Element plan certified by the state on time, the Builder’s Remedy activates. Developers can file preliminary applications for projects of roughly any density, provided 20% of their units are classifiable as affordable.

Under Massachusetts’ Chapter 40B, developers apply for a single “Comprehensive Permit” that overrides local zoning in towns where less than 10% of housing is affordable. If the local board denies the permit, the developer appeals to a specific State Housing Appeals Committee, which historically rules in favor of housing production.

Impact

The impact appears in both direct unit production and the behavioral modification of local governments. Some examples of Builder’s Remedy’s quantitative impact include:

  • In Massachusetts, Chapter 40B is linked to the production of approximately 77,000 housing units that likely would not have been built under standard zoning.
  • In California, the prospect of the Builder’s Remedy drives compliance, with the risk of losing control over local development leading to hundreds of jurisdictions accelerating their re-zoning efforts. Santa Monica processed more units in a single year than in the prior decade.
  • In New Jersey, the judicial version of this remedy (the Mount Laurel doctrine) required over 340 municipalities to adopt fair share plans, integrating low-income families into high-opportunity school districts.

Lessons

Success depends on enforcement mechanisms rather than voluntary targets. Different states have chosen different frameworks of enforcement that fit their broader regulatory schema.

Illinois passed a similar law, the Affordable Housing Planning and Appeal Act (AHPAA), but included few penalties for non-compliance and no streamlined appeals process. Consequently, developers rarely use the tool, with exclusionary suburbs having little incentive to change behavior. In contrast, California’s law allows developers to “freeze” their zoning rights upon filing a preliminary application, creating an immediate incentive for towns to remain compliant.

Success in Massachusetts and Connecticut relies on the clear 10% affordable threshold. This  standard reduces debate about whether the remedy applies and gives developers the confidence to invest in pre-development.

While these laws trigger political opposition, they often turn towns into rational actors. When faced with the loss of control, municipalities frequently rezone voluntarily to meet targets.

Proactively Resolve Tangled Title Issues

Implement policy and provide legal aid to address and resolve complex tangled title issues that wipe out generational wealth and prevent the deterioration of existing housing stock. Preventing the loss of existing housing stock requires a focused effort on these legal and protective measures:

  • Establish Legal Aid and Estate Planning Infrastructure: Tangled titles often stem from a lack of clear ownership succession plans. Cities should pair tax sale interventions with mandatory estate planning support to resolve ambiguous ownership issues and keep them from recurring. Nonprofits could run legal aid clinics to help families navigate these complex legal waters. Additionally, organizations should develop processes to inform buyers of their legal options at the time of closing to prevent future title issues.
  • Implement Circuit Breaker Tax Programs: Tax-related foreclosures are a primary driver of lost generational wealth. States should implement circuit breaker programs that tie property taxes to income once a homeowner meets a certain threshold. Maryland provides a successful model for this through the use of tax policy as a direct mechanism for housing preservation.
  • Build Real Estate Infrastructure in Tribal Communities: In many parts of Indian Country, basic real estate statutes do not exist. Solving this conundrum requires building an entire housing industry system from scratch, including creating policies for quick, accurate appraisals to bypass the Bureau of Indian Affairs’ administrative bottlenecks. It also requires intensive education for tribal leaders and members on the fundamentals of mortgages and debt leverage.
  • Revitalize Rehabilitation Financing: Tangled titles frequently lead to physical deterioration of properties because owners cannot access capital for repairs. Solutions must include breathing new life into rehabilitation loan products like Section 203(k) or Title I programs. These tools are essential for acquiring and stabilizing distressed properties once title issues are resolved.

Expedite Approvals and Slash Soft Costs

Soft costs and bureaucratic delays pile up and can eventually kill project viability. Because there are many smaller items that compound, fixing this problem will need to be multi-faceted, combining fee reductions with process speed improvements to drastically lower the barrier to entry for mission-driven developments. Reducing execution risks for mission-driven projects involves these specific administrative shifts:

  • Establish a Dedicated Affordable Housing Track: Create a separate lane for mission-driven projects. Local housing authorities should manage this track, prioritizing affordable deals over market-rate ones. This incentivizes developers to build affordable units because the path is clearer and faster.
  • Mandate Expedited Approvals: Housing developers live by the adage, “Time is money,” which is true when every delay leads to another month of loan payments without rental income coming in. During a recent DC-based development, a $50 million project stalled for 12 months and incurred $1.5 million in additional interest payments, necessitating an additional grant from the local housing finance authority to keep the project alive. To mitigate this, cities should enforce a 30-day rule for taking action on planning permits as has been implemented in multiple jurisdictions across the country. Some cities use a priority letter from the local Housing Authority to trigger this fast lane, while others put all affordable housing in this expedited queue. This would slash holding costs that otherwise bleed development budgets and lead to additional gap financing needs.
  • Impose Fee Caps and Reductions: Development fees are often arbitrary and exorbitant. For instance, in Nashville, a utility hookup can cost $20,000. In Detroit, it can run upwards of $40,000. These costs kill project viability before construction even starts. Cities must enforce reasonable caps on these expenses or waive them entirely for affordable housing projects to ensure they get built.
  • Absorb Infrastructure Costs: Cities frequently demand affordable housing but refuse to pay for the infrastructure it requires. Instead of passing the burden of futureproofing utilities to nonprofit developers, municipalities should absorb, or significantly subsidize, these costs. This recognizes that the developer is delivering a public benefit and should not be penalized for municipal underinvestment.
  • Implement Master Blueprints: For housing types like ADUs or tiny homes, cities should pre-approve design standards. If a developer uses a master blueprint, they should be able to skip the lengthy design review.
  • Advocate for Public Good Pricing: Advocates must use data to show that excessive fees prohibit infill development and worsen the affordability crisis. The argument is simple: the city should not overcharge developers who are solving the city’s housing problem.

Create State and Local Funding Mechanisms

Promote local policies that support the creation of new financial tools to diversify the funding base and reduce development costs. This will reduce dependency on volatile federal grants and provide a predictable, locally sourced funding stream. To diversify the capital stack, advocates pointed to these state and neighborhood-level mechanisms:

  • Mobilize Local Capital: Cities and counties should utilize municipal bonding, or sales taxes, to create dedicated Local Housing Trust Funds. Minnesota, for example, implemented a metro sales tax where 75% of the proceeds go to preservation and development programs. Communities should also explore creating Public Community Development Banks (PCDBs). These institutions can fill gaps that government agencies cannot by administering Social Impact Investment Funds dedicated to pre-development and infrastructure efforts.
  • Establish Agile Acquisition Funds: Nonprofit developers need liquidity to move as fast as private equity. We must create agile acquisition funds capitalized through local resources, banks and social impact investors. This allows nonprofits to acquire properties before they are lost to the speculative market.
  • Innovate State Tax Credits and Revenue Streams: States should create their own cash tax credits to establish diverse funding streams. For example, the Oregon Affordable Housing Tax Credit allows banks to reduce the interest rate of a loan by 3-4%, passing the savings to residents as lower rents. Advocates should also push to redirect specific revenue streams, such as tourism dollars or real estate documentary taxes, directly into housing trust funds rather than letting them be swept into a municipality’s general funds.
  • Engage Community Investors: Move away from reliance on external subsidies by generating capital directly from neighbors. Community Investment Trusts and crowdfunding models allow residents to invest small amounts (e.g., $10-$150) in local assets. This fosters local ownership and offers a meaningful return to shareholders. Nonprofits can also restructure debt by allowing individuals to lend funds at low interest rates instead of asking for donations, appealing to high net-worth individuals seeking to make real social impact.
  • Develop Secondary Markets: CDFI’s scale, margins and impact rely on their liquidity. Developing a secondary market for locally originated micro-business loans allows CDFIs to sell these loans and free up capital to lend again. This reduces the pressure of holding every loan on the balance sheet and speeds up the velocity of money in the community.

Utilize Modular/Manufactured Housing and Vertical Integration

Developers can make strategic procurement choices to reduce their developmental costs, such as making use of modern construction techniques and internalizing broadly applicable cost centers that are currently contracted. These solutions would reduce construction time and costs, making projects feasible without the need for subsidies. To lower the cost per square foot, organizations should consider these strategies:

  • Apply Factory Principles to Construction: Nonprofits and developers must embrace modular and manufactured housing to dramatically lower costs and speed up production. This approach would offer significant savings over stick-built homes and can cut construction time by half (e.g., assembling a home on-site in two weeks versus months). It requires actively countering the stigma associated with manufactured housing by emphasizing that modern units are anchored to foundations and indistinguishable from traditional builds. Innovations like 3D printing and container homes should also be leveraged for their energy and construction efficiency.
  • Vertical Integration for Cost Control: Organizations should consider qualifying as their own general contractor. This allows nonprofits to control pricing and avoid bidding out contracts, further reducing delays and increasing cost certainty, which is crucial when federal funding is involved. Nonprofits can also achieve efficiency by bringing consultant functions, such as property management and architectural services, in-house once production volume justifies the investment.
  • Integrate Workforce Development: This model pairs well with workforce development programs. Organizations can better support community members to build houses in their own neighborhoods by training them to become future skilled tradespeople, effectively recirculating wealth locally. A powerful example comes from tribal communities using their own “force accounts” (internal workforce), which allowed them to drop building costs from $350 per square foot to $185 per square foot.
  • Leverage Academic Partnerships: Nonprofits can reduce preliminary soft costs by engaging university partners to supply students for cost estimation and feasibility studies.

Problem

Despite the success of the 9% federal Low-Income Housing Tax Credit (LIHTC) in providing equity, developers in Oregon consistently faced a funding gap. High construction costs and local market rents meant that projects could not support the level of permanent debt that could be repaid through the apartments’ operations, even with the LIHTC subsidy. This left many viable affordable housing projects unable to move forward.

Solution

The Oregon Affordable Housing Tax Credit (OAHTC) is a state-level tax credit that functions as a powerful cost-of-debt reduction tool. It allows a conventional lender to provide a permanent loan at a significantly below-market interest rate (e.g., 2.5% instead of 6.5%). In exchange, the state gives the bank a tax credit for every dollar of interest income they give up. The bank loses nothing, but the housing project acquires a much cheaper loan. The program requires that 100% of the interest savings is passed on to the project, allowing for deeper rent reductions and long-term viability.

Implementation

The program integrates with equity subsidies like LIHTC to right size the debt payment so it can be serviced out of the project’s rental cash flow. OAHTC’s application is also integrated as one of the multiple options available to developers in the state’s Oregon Centralized Application (ORCA) system, reducing the burden of seeking it alongside other state support.

Impact

Since 1989, this tool has helped finance over 15,000 affordable homes and has been shown to be particularly effective in rural areas. For every $1 million in tax credits the state issues, it triggers roughly $25 million in private lending. For the families living in these homes, the interest savings often translate to rents that are $100 to $200 lower than the market rate.

Lessons

The OAHTC demonstrates that state-level interventions are most powerful when they are designed not to replace federal tools, but to amplify them. The key success factor is its alignment of incentives for lenders and developers. Its replicability is high for any state with a state income tax, offering a scalable model to address the debt gap that plagues affordable housing development nationwide.

Convert Underutilized Community Assets

Strategically identify and convert underutilized community assets, such as vacant schools, empty offices or defunct shopping centers, into new housing units. This would bypass costly land acquisition and lengthy greenfield development processes, rapidly increasing the housing supply. These solutions focus on transforming underused property into high-quality, in-community housing:

  • Identify and Acquire Stranded Assets: As many cities have seen shifting land use strategies, new opportunities for housing development have been created in commercial and industrial neighborhoods. The strategy must go beyond big buildings towards including micro-plots for tiny homes and strategic site assembly in transitioning neighborhoods. Finding and rezoning adjacent, tax-delinquent properties would also allow developers to create more viable sites.
  • Innovate the Capital Stack for Conversions: Converting a mall isn’t like building a house as the risks are different. Local leaders must structure funding in a way that derisks these complex projects. Nonprofits also need to consider repositioning their own underutilized offices to generate rental income, creating the internal liquidity needed to buy new property or pay down debt.
  • Navigate Historic and Zoning Hurdles: While older buildings have character, historic designations often pile on costs that kill affordable projects. To mitigate this, advocates must also fight for zoning shifts that allow for residential growth. This often faces aggressive resistance, but it is the best way to unlock this underutilized supply. It would also allow for future commercial revitalization efforts to succeed due to the presence of in-community consumers.

Redefine Risk Logic in Financial Models

Financial models must recognize the lower risk associated with mission-driven affordable housing due to guaranteed demand and waiting lists. If the risks were more accurately modeled, it would make mission-driven projects economically viable with reduced subsidies. Participants identified solutions that broadly fell into three groups:

  • Challenge Arbitrary Risk Classification: Regulators and banks currently treat affordable housing with the same skepticism applied to volatile commercial ventures. For instance, a speculative condo in Miami often carries the same risk profile as a Low-Income Housing Tax Credit (LIHTC) project in Buffalo. Equal risk logic limits the equity banks can commit due to “safety and soundness” concerns even when the commercial market is the actual source of instability.
  • Recognize the Myth of Lease-Up Risk: Unlike a new shopping mall or luxury apartment block, affordable housing projects often come with a mile-long waiting list. The risk of the unit sitting empty is nearly non-existent. This guaranteed demand should logically translate into a significantly lower risk profile for lenders, allowing for better terms.
  • Advocate for Regulatory Distinction: The industry needs a formal regulatory distinction that separates affordable housing construction financing from speculative commercial projects. Regulators should also acknowledge that investing in affordable housing creates stable, long-term returns that satisfy community reinvestment requirements rather than adding to a portfolio’s volatility.

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Redlined Then, Burdened Now: New Research on the Connections Between Land Use and Mental Health https://ncrc.org/redlined-then-burdened-now-new-research-on-the-connections-between-land-use-and-mental-health/?utm_source=rss&utm_medium=rss&utm_campaign=redlined-then-burdened-now-new-research-on-the-connections-between-land-use-and-mental-health Wed, 06 May 2026 14:00:51 +0000 https://ncrc.org/?p=286156 “LULUs” sounds like a funny word, but the health burdens tied to LULUs are no laughing matter. Locally unwanted land uses (LULUs) – industrial sites, highways, power plants and waste facilities – are essential to how cities function. However, living close to them can also mean greater exposure to pollution, excessive noise and other environmental stressors.

A large body of research links these kinds of exposures to a wide range of health concerns. Air pollution is associated with millions of premature deaths globally each year alone and is tied to heart and lung disease, especially in communities located near industrial activity and heavy traffic. Researchers are also increasingly documenting links between environmental conditions and mental health. 

Long-term exposure to air pollution has been associated with depression and anxiety, while environmental noise from traffic and industrial infrastructure have been linked to stress and anxiety symptoms. More broadly, environmental pollution is now understood to affect a person’s physical and mental well-being, with evidence linking it to cognitive decline, psychological distress and worsening mental health over time.

The health burdens of LULUs are not distributed evenly. Decades of environmental justice research have shown that those patterns reflect long-standing inequalities in political power, land use decision-making and access to resources.

One of the clearest historical frameworks for understanding these patterns is residential segregation and its relationship to redlining. From the 1930s until the 1960s, the federal government graded neighborhoods based in part on race and ethnicity, with many Black and immigrant communities being redlined – or labeled as high-risk for investment. Redlining did not create segregation on its own, but it formalized and reinforced patterns of disinvestment that shaped neighborhoods.

A growing body of research finds that neighborhoods with a history of redlining also tend to have higher concentrations of environmental burdens, including industrial land uses, heavily trafficked transportation arteries and other LULUs. These same neighborhoods often continue to face socioeconomic disadvantages and elevated exposure to environmental stressors. A recent study conducted by researchers at the University of Michigan, the Ohio State University and the National Community Reinvestment Coalition (NCRC) reflects these broader patterns in Chicago. 

Chicago is the largest hub in the railroad industry. Six of the seven Class I railroads meet in Chicago, with the exception being the Kansas City Southern Railway. As of 2002, severe freight train congestion caused trains to take as long to get through the Chicago region as it took to get there from the West Coast of the country (about 2 days). About one-third of the country’s freight trains pass through the city, making it a major national bottleneck. (Photo courtesy of Wikipedia Commons.)

“We found that neighborhoods with higher levels of historical redlining also tended to have greater concentrations of certain LULUs, especially industrial land uses, vacant land or construction sites,” said University of Michigan lead researcher Dr. Liang Chen.

These neighborhoods also tended to report higher levels of self-rated poor mental health. In our analysis, industrial land, construction sites and vacant land were especially important in understanding how redlining, neighborhood conditions and mental health are patterned together across the city.

Chicago Housing Authority’s 1938 copy of the Federal Housing Administration’s Neighborhood Ratings of Chicago, IL. (Image via University of Chicago Map Collections; https://www.federalreservehistory.org/essays/redlining.)

These findings suggest that the geography of LULUs today overlaps closely with the geography of historical housing discrimination defined by redlining. In Chicago, as in many US cities, neighborhoods that suffered decades of disinvestment continue to bear heavier environmental burdens and worse health outcomes. This illustrates how the legacies of segregation and land use continue to shape mental health outcomes today.

Addressing these patterns requires intentional policy action. Tools such as the Community Reinvestment Act (CRA) can help by encouraging investment in historically underserved neighborhoods, supporting affordable housing, community facilities and redevelopment efforts that improve neighborhood conditions and expand access to resources that promote community health.

 

Bruce C. Mitchell, PhD. is the Principal Researcher with NCRC’s Research team.

Photo credit: Chait Goli via Pexels.

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Racial Wealth Snapshot Series: Overview of Latino American Economic Outlook https://ncrc.org/racial-wealth-snapshot-series-overview-of-latino-american-economic-outlook/?utm_source=rss&utm_medium=rss&utm_campaign=racial-wealth-snapshot-series-overview-of-latino-american-economic-outlook Thu, 30 Apr 2026 13:47:21 +0000 https://ncrc.org/?p=286250

Definitions of Terms

While Latino and Hispanic are frequently used interchangeably, they can convey different meanings. Latino, short for Latinoamerican, refers to people of Latin American origin. Latin America includes all of the countries in the Western Hemisphere that speak a Romance Language (more specifically, Spanish and Portuguese).

The term Hispanic is representative of a slightly different group that includes only people who are from Spanish-speaking countries, including Spain. Because of this and our focus on people of South and Central American origins in this analysis, we will use the term Latino for continuity. Lastly, the terms Latino and Hispanic refer only to ancestry, with individuals identifying as either or both categories being from a variety of racial and ethnic groups.

Demographics

Latinos are the fastest-growing demographic group in the United States. In the first two decades of the 21st century, the majority of growth in the Latino population came from births rather than immigration. However, this trend saw a reversal in the 2020s as immigration rates overtook new births as the primary driver of Latino population growth.

Latinos are diverse racially, with about 12% identifying as being of Afro-Latino origin. Latinos of Mexican origin comprise the majority (57%), with Puerto Ricans representing 9% of the total US Latino population, Cubans at 4.34% and Dominicans at 3.63%. California and Texas have the largest Latino populations in the country with 16.1 million and 12.6 million, respectively. However, New Mexico contains the largest share of Latinos relative to its total population (47%).

Wealth Accumulation

Latino household wealth has grown over time but remains far below the wealth of non-Latino White households. In 2022, the median Latino household had a net worth of $62,120 compared to $284,310 for White households. Up until 2016, the gap between the two groups was steady at about 12%, meaning the median Latino household had 1 dollar for every 8 dollars that a median White household had. However, between 2016 and 2022, the gap narrowed from 8 to 1 to about 5 to 1.

Similar to Black households, Latinos are more dependent on home equity to build wealth than White households. From 2013 to 2022, over half of Latino wealth gains came from home equity, while only 20% of the wealth gains came from home equity for White households. This has been accompanied by an increase in Latino homeowners, pushing their homeownership rate from 45% in 2023 up to 51% in 2023. For the first time since the steady increase in lending to Latino borrowers began in 2018, the Latino population share of the home purchase mortgage market(17.7%) exceeded their share of the total population (16.8%) in 2025. This is due to the increased financial clout of moderate and higher-income Latinos.

Furthermore, the median value of Latino home equity increased 22% to $135,000 between 2019 and 2022. While increases in homeownership are a net positive, the increased dependence on home equity makes Latino communities vulnerable to economic shocks, such as in the Great Financial Crash of 2008.

Stock ownership among Latinos has significantly increased over the past decade. In 2013, around 2.5% of all Latino households reported owning some sort of stock share. By 2022, 8% of Latino households reported direct stock ownership, with a median holding value of $10,000.

While Latino homeownership and stockownership rates are improving, access to liquid assets (namely bank deposits) remains a challenge. About two-thirds of Latino households are liquid asset poor, meaning they don’t have enough savings they can quickly use to cover basic needs for three months if they lose their main income. About 14.8% of Latino adults are unbanked compared to the national average of 4.2%, highlighting the need for increasing access to financial services for Latino Americans.

Income and Poverty

The US Latino population’s median household income growth has surpassed that of other racial/ethnic groups, peaking at $70,950 in 2024. From 2014 to 2024, the average Latino household income increased by almost 30%, 8% higher than the national average.

Interestingly, income and poverty levels differ greatly among Latino subgroups. Among the groups with a population of at least 1 million, Ecuadorians and Colombians have the highest median household income. On the flip side, Hondurans and Guatemalans have the highest poverty levels. Differences in educational attainment, legal status and the particularities of their journey to the United States are partly why some Latino subgroups have higher income and lower poverty rates than others. 

Work and Labor

Latinos feature prominently in the US economy. One long-running characteristic of Latino workers is their high labor force participation rate. 67.1% of Latinos are in the labor force compared to 62.4% for the overall population. The median age of Latino Americans is 31, compared to the median age of non-Latino Americans being 41 years old. This contributes to their higher labor force participation rates because of the higher share of Latinos in their prime working years.

While Latinos can be found throughout the labor force, they are over-concentrated in some sectors, such as the construction and hospitality industries. The share of Latino construction workers increased from 20% to 30% from 2003 to 2020. Within construction, Latinos are concentrated in the core construction jobs, such as day laborers, rather than in management roles.

Other jobs where Latino men are more likely to work are in agriculture and maintenance occupations. Latina workers are concentrated in the leisure/hospitality, healthcare and other service industries and are disproportionately found in lower-wage, “segregated” occupations.

Education Attainment

Latinos have been making large strides in education. In 2023, 21% of Latinos had a bachelor’s degree or higher compared to 14% in 2013. While some of this increase comes from the migration of educated Latinos to the US, much of it comes from increases in college enrollment. From 2012 to 2022, undergraduate and graduate enrollment for this demographic group increased by 23% and 69%, respectively. Over half of Latinos enrolled in college attend a Hispanic-Serving Institution, colleges where Hispanic/Latinos comprise at least 25% of the undergraduate population.

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