Deep Dive Episode 110 – Community Reinvestment Act: Remedy or Relic?

Regulatory Transparency Project Teleforum

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Congress passed the Community Reinvestment Act in 1977, intending to encourage depository institutions to help meet the credit needs of the communities in which they operate, including low- and moderate-income neighborhoods, consistent with safe and sound banking operations. The Act seeks to achieve this goal through federal examinations and ratings of banks’ performance toward this objective, often driving significant national changes in lending activity. In the intervening time, the nature of banking has substantially changed to encompass online and mobile banking—many Americans do not rely on physical depository institutions in their neighborhood at all—and yet the Community Reinvestment Act has not been amended. Regulations and enforcement priorities under the Act, however, have also shifted with presidential administrations. This episode discusses newly proposed reforms by the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation that would shift toward a metric-based, less malleable set of criteria for how banks’ and other institutions’ performance is rated under the Community Reinvestment, as well as how those changes will affect the banking system and low- and moderate-income communities.


  • Mehrsa Baradaran, Professor of Law, UC Irvine School of Law
  • Diego ZuluagaAssociate Director of Financial Regulation Studies, Center for Monetary and Financial Alternatives, Cato Institute
  • [Moderator] Elliot Gaiser, Associate, Boyden Gray & Associates

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