Commentary: The Community Reinvestment Act Must Be All About Public Participation, but It Still Doesn’t Feel That Way

Josh Silver
National Community Reinvestment Coalition

Under the Community Reinvestment Act (CRA)1 of 1977, banks have an affirmative and continuing obligation to serve the convenience and needs of the communities in which they are chartered to do business.2 The best way to determine if banks are serving the credit and deposit needs of the communities is to listen to the residents assess the banks’ records of doing so. As Marijoan Bull’s article in this symposium shows, however, the public input mechanisms established by the federal bank agencies remain incomplete and, in many instances, are difficult to use (Bull, 2017). Thus, the full potential of CRA is frustrated in terms of increasing responsible lending, investing, and bank services in low- and moderate-income communities.