Assignment:
Objectives
• Understand the strengths and weaknesses of the CRA
• Articulate the importance of CRA to community development practice
• Understand how points of view vary across different political ideologies and organizations
• Build planning and advocacy skills by submitting a federal comment letter that uses evidence to support a point of view
As we discussed in class, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation are taking comments on their proposal to reform CRA. Comments are due to the regulators April 8, 2020. Providing feedback is critically important to ensure that the reforms enacted strengthen rather than weaken CRA. However, there is honest debate about how to do that. There is no right answer to what you will write in this letter – it is your opinion, supported by evidence presented in class or that you find through research, that we will be looking for.
Requirements
Your comment letter should be between 800 and 1,200 words, single spaced, 12 pt font, and include your signature. (A letter template is provided with this assignment.)
A good comment letter:
• Begins by articulating who you are and why you care about the issue.
• Focuses on the parts of the regulatory revisions that most concern you and/or that you understand the best. You do not need tocomment on every aspect of the proposed rule. We are expecting that you comment on 2 aspects of the proposed changes.
• Is clear about which parts of the rule you support and which you disagree with.
• Supports your point of view with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment. By supporting your arguments you are more likely to influence agency decision making.
• If you disagree with a proposed action, suggest an alternative and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective
These letters should be written by you, and include citations for materials that you take from other reports or websites. We will be using TurnItIn for this assignment. Organizations often encourage their members to submit form letters -you will find examples of this online. DO
NOT TURN IN A FORM LETTER. Many in the public mistakenly believe that their submitted form letter constitutes a "vote" regarding the issues but this is not true. A single, well-supported comment carries more weight thana thousand form letters.
Resources:
The full proposed rule in the Federal Register (take a look to see how it is formatted, but we are not expecting you to read or comment on the entire thing). The summary-which you are expected to read-of the main revisions to the rule can be found here.
OCC Materials about the Proposed Rule
A video about the benefits of modernizing the CRA
OCC Fact Sheet
The Podcast developed by the American Bankers Association on the modernization
Critiques of CRA
American Enterprise Institute
Heritage Foundation
Advocates for CRA
National Community Reinvestment Coalition TreasureCRA
Helpful articles that articulate various arguments for and against the reforms in CRA from different viewpoints. (Please remember that we will be using TurnItIn so don't plagiarize from these sites.)
Novogradac - helps CD with tax credit financing, and this article is good too
The Hill - progressive political commentary
A paper I wrote on the danger of setting a single metric for CRA
Attachment:- Resources.rar