Joint letter: A strengthened Community Reinvestment Act must advance digital equity

Our response to the Notice of Proposed Rulemaking to modernize the CRA

Joint letter: A strengthened Community Reinvestment Act must advance digital equity

The Community Reinvestment Act (CRA) was enacted in 1977 to set standards for financial institutions to meet the banking and credit needs of their underserved local communities and to help build individual and community assets. The CRA guides and supports the field of community development and is a powerful way to unlock funds for infrastructure, affordable housing, healthcare, education, workforce development, micro and small business, and financial education — improving life opportunities for people in low- and moderate-income (LMI) neighborhoods and rural areas. 

Since the last significant overhaul of the CRA in 1995, digitalization has driven profound changes in the economy and labor market. Access to the internet and digital tools and skills training are essential in today’s world — yet communities across the country are without access and are missing out on the benefits of digital technologies. These communities are disproportionately LMI neighborhoods, rural areas, and Black, Indigenous, and people of color (BIPOC) — communities the CRA is designed to serve. 

People need reliable, affordable high-speed internet access at home for participation in basic social and economic activities such as working remotely, running a business, accessing government services, telehealth, online banking, and access to education and workforce opportunities. As such, the CRA must be updated and modernized to recognize and address the critical importance of digital equity for creating opportunities for upward mobility in these communities — and encourage investments that will bridge the gap between digital haves and have nots. 

We welcome a recent joint proposal to modernize and strengthen CRA regulations issued by the bank regulatory agencies in the US — the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency. In the spirit of collaboration and in response to the agencies’ request for comments, we — a group of organizations and individuals committed to digital equity — have submitted recommendations to further strengthen the CRA so it encourages investment in digital equity and more effectively serves its purpose of strengthening communities and improving lives.


With thanks to this group of signatories who represent what is emerging in this country: the joining together of the fields of community development and broadband and digital inclusion — breaking down silos to meet the moment and create an inclusive digital economy. 

Jordana Barton-Garcia, Senior Policy Fellow
Connect Humanity

Amira Dhalla, Director
Consumer Reports

Amy Sample Ward, CEO

Angela Siefer, Executive Director

Brian Donoghue, Deputy Director
Next Century Cities

Brian Snider, CEO
Lit Communities Broadband, Inc. 

Catherine Crago, Head of Strategic Initiatives
Housing Authority of the City of Austin

Celina Moreno, J.D., President & CEO
Intercultural Development Research Association (IDRA)

Chantal E. Forster, Executive Director
Technology Association of Grantmakers

Christopher Mitchell, Director of Community Broadband Networks
Institute for Local Self-Reliance

Colby Hall, Executive Director
Shaping Our Appalachian Region

Danielle Chin, CEO
Seaded Consulting Firm

Debra Socia, President and CEO
The Enterprise Center, Chattanooga, TN

Dianne Connery, Director
Pottsboro Library

Edwin Mitchell, Executive Director
The Arch Group, Inc., Vicksburg, Mississippi

Gabriel Garcia, J.D., Vice-President
Texas Association of Telecommunications Officers & Advisors (TATOA)

Gabriella Rowe, CEO
Grow Associates, LLC

Gene Logan, Jr., CEO
R.A. Government Services, LLC

India P. Still, JD, LLM, Deputy Executive Director, AC Initiatives Project Office
New Jersey Department of Community Affairs

Jason Dixon, CEO
Strategic Alliance Community Development Corporation

Jason Foster, President & COO
Destination Crenshaw

Dr. Jeanine Abrams McLean, President
Fair Count

Jennifer Regnier, CEO 
Jewish Family Service San Antonio

Jerry Mixon, CEO
South East Sector Community Development Corporation 

Jesse R. Bradley IV, Program Director
Right Here, Right Now Project

Joseph J. Ceasar, Founder and Executive Director
Legacy Institute For Financial Education

Joshua Williams, Executive Fellow/Digital Inclusion Lead
FUSE Corps

Judy Quisenberry, Executive Director
Valley Baptist Legacy Foundation

Kelty Garbee, Executive Director
Texas Rural Funders

Kevin W. Alexander, MPA, President & CEO
Rockaway Development & Revitalization Corporation

Kevin Stein, Chief of Legal and Strategy
California Reinvestment Coalition

Kim Alexander, CEO
Collegiate Edu-Nation

Lazone Grays, President/CEO
IBSA, Inc.

Mark Walker
Director, The Jessie & Senior Program Officer at The Jessie Ball duPont Fund & Board President, Technology Association of Grantmakers

Michael Potter, Co-founder
N50, Geeks Without Frontiers

Michele Connelly, Executive Director, 
United Way of West Central MS

Monica Sanders, J.D., LL.M, Founder
The Undivide Project

Nishal Mohan, PhD, Founder & CEO

Robert McLaughlin, Executive Director
National Collaborative for Digital Equity 

Samantha Schartman, President and CEO
The Marconi Society

Scot Henley, Executive Director

Teresa Burnett, Executive Director
Monahans Chamber of Commerce

Tiffany Patterson, President & CEO
United Ways of Texas

William E. Harrison, CEO
Omni Sourcing

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