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Community Development - Comments

Advocates praised CFPB for user-friendly Home Mortgage Disclosure Act data page...
...And made suggestions for improvements. Empire Justice and other consumer advocates from across the country also urged the Consumer Financial Protection Bureau to quickly update the rules pertaining to HMDA. Read More

Empire Justice Comments to Regulators: Make Needed Comprehensive Changes to CRA Rules
Empire Justice's response to proposed changes to the Interagency Question and Answer (Q&A) document. Read More

Empire Justice and Organizations Want Consumers Protected When Shopping for a Mortgage
Empire Justice Center was one of several organizations that sent a letter to the Consumer Financial Protection Bureau last month urging the CFPB to strengthen its proposed regulations around mortgage pricing and real estate closings so that consumers are better informed. Read More

Empire Justice Center and Other NY Groups Say Wells Fargo Should "Fail" Its CRA Exam
In their comment letter to the Office of the Comptroller of the Currency, Empire Justice Center and other New York organizations cite Wells Fargo's foreclosure practices and discriminatory mortgage lending patterns and urge the OCC to give Wells Fargo a "Substantial Noncompliance" on its Community Reinvestment Act (CRA) Exam. Read More

GRCRC and other NCRC members urge federal regulators to strengthen CRA exams
The Greater Rochester Community Reinvestment Coalition, convened by Empire Justice Center, and dozens of other members of the National Community Reinvestment Coalition, signed onto a letter asking the four federal agencies that examine banks to assure they are meeting their Community Reinvestment Act obligations to improve and strengthen these exams. Read More

NYRL Members Urge NY Courts to Go Further to Protect Homeowners in Foreclosure
In their comments on the Office of Court Administration's (OCA) amendment addressing problems with the current foreclosure process, members of New Yorkers for Responsible Lending ask the OCA to take additional steps to give homeowners a fair chance in the foreclosure process. Read More

GRCRC Comments on First Niagara's Application to Purchase HSBC's Upstate New York Branches
HSBC is moving out of retail banking in upstate New York and First Niagara is seeking approval from federal regulators to purchase most of its branches. GRCRC met with First Niagara and submitted comments urging First Niagara to be a good steward in the Rochester community. Read More

GRCRC Comments on Canandaigua National Bank's CRA Performance
The Greater Rochester Community Reinvestment Coalition sent these comments to federal regulators about Canandaigua National Bank's community reinvestment performance in the Rochester, NY area. Read More

GRCRC Comments on JPMorgan Chase's CRA Performance
The Greater Rochester Community Reinvestment Coalition sent these comments to federal regulators about JPMorgan Chase's community reinvestment performance in the Rochester NY area. Read More

GRCRC Wants Stronger CRA Regulations
The Greater Rochester Community Reinvestment Coalition, convened by Empire Justice Center, urges federal agencies to strengthen and expand regulations governing the Community Reinvestment Act. Read More

GRCRC comments on proposed change to CRA
The Greater Rochester Community Reinvestment Coalition (convened by the Empire Justice Center) commented to federal regulators in support of their proposed change to the Community Reinvestment Act regulations to allow CRA credit for support of Neighborhood Stabilization Program (NSP) activities. Read More

GRCRC comments on RBS Citizens Bank's CRA performance
In June, the Greater Rochester Community Reinvestment Coalition, convened by the Empire Justice Center, submitted comments (and a follow-up letter) to the OCC on RBS Citizens' mortgage lending and community development performance for its CRA exam. Read More

GRCRC Comments on HSBC's CRA Performance
The Greater Rochester Community Reinvestment Coalition, and its convener, Empire Justice Center, submitted a letter to federal regulators on HSBC's performance in meeting the credit needs of the Rochester community. Read More

GRCRC Comments on Oversight of Financial Sector Acquisitions
Our country is now being over-whelmed by a financial disaster created by a culture of greed in the financial services industry and ignored until too late by the federal financial regulators. GRCRC is extraordinarily concerned that these same regulatory agencies are making decisions that are reshaping our financial sector without public comment or full oversight. Read More

GRCRC Comments on KeyBank's 2008 CRA Exam
This comment letter will focus mainly on mortgage and small business lending with a small section on community development activities. Read More

GRCRC Comments on M & T Bank's 2008 CRA Exam
These comments focus M&T Bank’s HMDA lending, small business and SBA lending, and its response to community investment and service needs. Read More

Empire Justice Comments on Proposed Changes to the Real Estate Procedures Act
This letter commends HUD for its efforts to simplify and improve the process of obtaining mortgages and to reduce settlement costs to consumers through proposed changes to the Real Estate Procedures Act (RESPA), and offers suggestions to improve the proposed changes. Read More

GRCRC Comments on Canandaigua National Bank & Trust CRA Exam
Greater Rochester Community Reinvestment Coalition comments regarding Canandaigua National Bank & Trust’s CRA Exam conducted by the Office of the Comptroller of the Currency. Read More

GRCRC Comments on Citizen Bank's CRA Exam
Citizens Bank is important to the Rochester metropolitan area. It is the fourth largest depository institution serving the area. As of June 20, 2007, Citizens had $1.65 billion in deposits at its 38 offices in the Rochester MSA and 13 percent of the market. Read More

GRCRC Comments on Bank of America's Application to Acquire Countrywide Financial Corp.
If the Federal Reserve attaches certain specific conditions to Bank of America’s acquisition of Countrywide Financial, as outlined in our testimony and detailed in this letter, the Greater Rochester Community Reinvestment Coalition would not oppose the acquisition. Read More

Empire Justice Comments on the Implementation of the Truth in Lending Act
It is our position that the proposals should be strengthened to make sure that consumers are adequately protected from the abuses that have led to the current crisis in the subprime mortgage lending industry and to ensure compliance. Read More