Americans for Financial Reform Education Fund (AFREF) and partners submitted comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation on their proposed revision to the regulations that implement the Community Reinvestment Act. AFREF urged regulators to ensure enhanced access to funds for climate resilience, as well as greater attention to climate change-related risks facilitated by bank financing of fossil fuel-related activities, to encourage banks to increase community engagement, and to explicitly include race as a metric to target investment effectively.

Key policy recommendations include:

• Expanding the list of climate-related eligible activities under the CRA regulations to include activities such as electrification and water efficiency measures for residential homes, including multifamily properties;
• Explicitly using race as a metric to ensure that historically and current redlined communities receive improved access to credit and services, including investments in community-based climate resilience;
• Encouraging banks to increase community engagement and relationship building with climate and environmental justice organizations, including through the use of Community Benefits Agreements; and
• Examining the role bank financing activities play in climate change, especially those that disproportionately impair access to credit for Black communities.

A joint comment letter signed by 93 organizations and individuals can be found here.

A petition signed by 10, 364 advocates can be found here.

Americans for Financial Reform Education Fund, The Greenlining Institute, and Public Citizen also submitted a longer climate-focused letter with technical implementation recommendations for the CRA, which can be found here.