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Prosperity Indiana comments on the Fed's Advance Notice of Proposed Rulemaking on the Community Reinvestment Act

16 Feb 2021 2:18 PM | Anonymous member (Administrator)

Prosperity Indiana submitted comments regarding the Federal Reserve Board’s (Fed) Advance Notice of Proposed Rulemaking (ANPR) on the Community Reinvestment Act (CRA). We believe the Fed’s approach is a good first step to improve upon the current CRA exam, in contrast to the Office of Comptroller’s final rule. However, we join our state and national partners in calling for more rigor in performance measures in order to ensure that CRA ratings will not be as inflated as they are today. More rigor is key to ensuring that CRA exams leverage more lending, investing and services for communities of color and low- and moderate-income (LMI) communities.

Prosperity Indiana is a network of nearly 200 organizations and individuals committed to advancing community economic development statewide. The focus of our efforts is to ensure everyone can enjoy equal economic and social opportunities and live in thriving communities. In carrying out this work, we know how critical CRA is to ensuring that areas and/or projects that would not otherwise receive investment can secure critical capital from banks through loans and investments for affordable housing and economic development. These investments and credit services spark neighborhood revitalization and help more Hoosiers achieve and maintain economic success.

Increased intentionality around meeting the purposes of CRA is critical, in light of the disproportionate impact COVID-19 has had on people on color and LMI households and those that serve them. Prosperity Indiana offers these comments as the cross-sector intermediary for organizations dedicated to community economic development, which means our members are the people and organizations on the front lines fighting COVID-19. Our members and the populations and communities they serve statewide have borne the brunt of the pandemic, resulting in stresses on capacity and finances. Three-quarters of our members report having six months or less cash reserve on hand; and the great majority have been forced to cancel programs or events and experienced disrupted services, even while seeing an increased demand for services and assistance. In May 2020, 82% anticipated a future decrease in revenue, and 94% anticipated a moderate to high impact on their programs, services, and general operation.

And while many of our nearly 200 members are deeply engaged in the community economic development work affected by the CRA and the proposed changes in the ANPR, few have the capacity during the ongoing emergency of COVID-19 to respond to the 99 questions involved. In order for our members to continue to respond, recover, and rebuild from COVID-19, they need a robust CRA that does not hinder services to communities of color and low- and moderate-income communities.

What’s at stake in Indiana?

Every community has a stake in strengthening the CRA, from Indiana’s small towns to growing suburban areas to the core urban areas. This is true from Angola, which saw $130.3 million in mortgages or loans to LMI borrowers or neighborhoods from 2009 through 2018, $0 in business loans to LMI neighborhoods, and $97.2 million in loans to small businesses, to Warsaw with $277 million in mortgages to LMI borrowers or neighborhoods, $36.1 million in business loans to LMI neighborhoods, and $271.4 million in loans to small businesses. And in our state’s largest metro area of Indianapolis-Carmel-Anderson, which itself spans a large city, a wealthy suburb, and a former industrial center now facing challenges, mortgages to LMI borrowers or neighborhoods totaled $14.2 billion from 2009 through 2018, with $3.9 billion in business loans to LMI neighborhoods, and nearly $4 billion in loans to small business. Indiana’s communities from smallest to largest can’t risk a weakening of the CRA that would allow an increase in discrimination in lending.

Strengthening CRA is a critical component of a just recovery

Indiana communities who have been hardest-hit and are still battling the public health, economic, and housing impacts of COVID-19 are the same who carry the scars of redlining. The National Community Reinvestment Coalition (NCRC) recently released a major report finding significant correlations between redlining and susceptibility to COVID, including Evansville, Fort Wayne, Indianapolis, Gary and Lake County, Muncie, South Bend, and Terre Haute. In the 1930s, the Home Owners Loan Corporation (HOLC) commissioned the production of maps that rated neighborhoods based on the risk of lending in them. Working class and minority neighborhoods usually received the riskiest designation of hazardous. The designations subsequently facilitated redlining and discrimination against these neighborhoods, which remain starved of credit and are predominantly lower-income and minority. These neighborhoods also have the highest incidence of health conditions such as asthma, diabetes, kidney disease and stroke, which make residents more susceptible to COVID-19. Life expectancy is almost four years lower in the redlined communities than the neighborhoods not designated as hazardous by HOLC.

In Indiana, the pandemic has disproportionately affected communities of color in additional ways. For example, according to the Federal Reserve Bank of Atlanta’s Unemployment Claims Monitor, Black Hoosiers have filed one in five unemployment insurance claims throughout the pandemic, although they make up only 9.4% of the labor force, according to 2019 data.

While we have not seen state-level data about Indiana’s Black-owned businesses, reports from the experiences of our members throughout the state align with nationwide trends showing a disproportionate impact on these businesses. Since the start of the pandemic, more than 440,000 African American businesses (41%) have been closed nationwide, compared to just 17% of White-owned small businesses. Discrimination in lending contributes significantly to racial disparities in small business survival rates. An NCRC investigation found that African American testers applying for Paycheck Protection Program (PPP) loans for their small businesses during the pandemic were likely to receive less information or encouragement to apply than White testers. We do not need state-level data to confirm the impact, and we cannot afford to see the CRA watered down in the meantime. CRA must be strengthened considerably in order to combat discrimination and help our communities recover from the pandemic.

Read Prosperity Indiana's full comments to the Fed's ANPR on the CRA.

Prosperity Indiana
1099 N. Meridian Street, Suite 170
Indianapolis, IN 46204 
Phone // 317.222.1221 
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