Fair, inclusive lending & investment for all Illinois communities

The Illinois CRA Coalition is a group of organizations dedicated to protecting and strengthening the federal and the Illinois Community Reinvestment Acts as tools for building more equitable communities and addressing the racial wealth gap.

We can build a fair, inclusive system of lending and investment that meets the needs of lower-income Illinoisans and residents of color by ensuring that banks and other financial institutions invest and conduct business in our communities in a just, equitable manner.

Latest News

To ensure that there is an equity focus to the IL CRA – the key issue raised by community groups across the state – the IL CRA Coalition worked for passage of SB3235, which requires the Commission on Equity and Inclusion (CEI) to conduct one or more studies to identify and define places in Illinois exhibiting disparities with respect to access to financial products and services, as well as lending and investments by covered financial institutions. SB3235 passed both chambers of the Illinois legislature and was signed into law by the Governor in August. The bill and its accompanying fact sheet can be found here:

SB3235
SB3235 Fact Sheet

New Final Rules were recently issued for both the Illinois and the Federal CRAs. The Final Rules can be found here:

IL CRA Bank Rules 
IL CRA Credit Union Rules
IL CRA Mortgage Lender Rules
Federal CRA Rules

See the IL CRA and Federal CRA sections below for more information.

About the Illinois CRA

The Illinois Community Reinvestment Act (IL CRA)

compliments the federal CRA by providing oversight for state-regulated financial institutions. It was signed into law by Governor Pritzker on March 23, 2021, in a historic victory for low-income communities and communities of color in Illinois. With this legislation, Illinois became the second state with an oversight system to ensure that residents are equitably served by all three major segments of the mortgage lending market: state-chartered banks, state-chartered credit unions, and state-licensed mortgage companies.

Governor Pritzker at the signing of the IL CRA on March 23, 2021

Enforcement

To enforce the IL CRA, IDFPR assesses how well each regulated entity –  banks, credit unions, and mortgage lenders – fulfills its obligation to provide accessible and responsible financial products and services to the communities they are chartered to serve, not excluding low- and moderate-income communities and individuals. IDFPR assign the entity a rating that is used to evaluate applications for future approval of bank relocations, mergers, consolidations, acquisitions, and assumption of liabilities..

 

Why It’s Important

The broader coverage of the IL CRA—oversight for credit unions and mortgage companies as well as banks—is key. National research by the federal Consumer Financial Protection Bureau shows that a majority of mortgages (an estimated 60 to 70 percent) are originated by residential mortgage brokers and credit unions. Now that SB3235 has been signed into law, the IL CRA is also the first state CRA to have an express equity tool in the form of a disparity study.

 

Status Updates

The Illinois Department of Financial and Professional Regulation (IDFPR) issued a preliminary proposed rule to implement the IL CRA in 2021, and the IL CRA Coalition worked to educate community members and to organize comments on this new Illinois law. 

On December 16, 2022, IDFPR released proposed rules for the implementation of the IL CRA. The IL CRA Coalition organized supporters from across the state to submit comments, and shared recommendations to ensure that the implementing rules for the IL CRA create an effective, strong tool for furthering equitable access to capital and financial inclusion.

The rules as proposed in December of 2022 were not implemented and a new set of proposed rules was released on January 5, 2024. The IL CRA Coalition submitted comments in response to the 2024 proposed rules, and shared recommendations with IDFPR.

On May 1, 2024, IDFPR adopted final rules for the implementation of the IL CRA. We are currently reviewing the final rules and will be creating community resources for understanding and taking advantage of the IL CRA in the coming months.

About the Federal CRA

The Federal Community Reinvestment Act (CRA)

makes wealth-building more accessible for low- and moderate-income communities through the provision of basic banking services, responsible homeownership opportunities, and capital for small businesses; investment into the development of affordable multi-family housing; and support for neighborhood revitalization, stabilization, and community services, such as child care and educational, health, or social services.

Enforcement

To enforce the CRA, three federal regulatory agencies⁠—the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and the Federal Reserve System⁠—assess how well each regulated bank fulfills its obligation to provide accessible and responsible financial products and services to the communities they are chartered to serve, not excluding low- and moderate-income communities and individuals. The regulators assign the bank a rating that is used to evaluate applications for future approval of bank mergers, charters, acquisitions, branch openings, and deposit facilities.

 

Why It’s Important

The federal CRA’s importance has become even more clear as COVID-19 lays bare the inequities that already existed in urban, suburban, and rural communities, with higher infection rates and occurrences of other health issues in historically redlined neighborhoods. After George Floyd’s murder and the resultant social justice protests, the IL CRA Coalition brought together a group of 39 partners and allies to send a letter urging federal banking regulators to use the CRA to address structural racism embedded in the financial system.

 

Status Updates

In May 2020, the OCC proposed a harmful rule that would have shifted billions of dollars away from communities that already struggle with disinvestment, racism, and economic disruption. The OCC adopted this rule on its own, without the sign-on of the Federal Reserve and the FDIC, and despite widespread criticism. The IL CRA Coalition organized supporters across our state and joined others nationally to speak up against the 2020 rule.

In 2021, the Federal Reserve Bank released a preliminary proposal to update the rules by which they hold banks accountable. The IL CRA Coalition again organized supporters to submit comments, and shared recommendations in a joint letter, calling for the CRA evaluation process to include an explicit focus on promoting racial equity, among other items.

In December 2021, the OCC fully rescinded its controversial rule and signaled an intent to work jointly with the other banking regulators to adopt a clear, strong, and consistent update to the CRA.

On May 5, 2022, the three federal regulators released a proposed joint rule. The IL CRA Coalition again organized supporters to submit comments, and shared recommendations in a joint letter with the federal regulators.

On October 24, 2023, the three federal regulators released updates to the federal CRA rules, which were published in the Federal Register on February 1, 2024.

In response to a lawsuit filed by the American Bankers Association, the U.S. Chamber of Commerce, and others, a U.S. District Court for Northern District of Texas halted implementation of the new rules pending a legal review. That case is on-going on. See Texas Bankers Association, et. al., v. Office of the Comptroller, 2:24-CV-025-Z-BR (N.D. TX).

We continue to monitor the situation and are preparing preliminary community resources for understanding and taking advantage of the federal CRA.

 

About the IL CRA Coalition

Who We Are

The IL CRA Coalition is co-facilitated by Housing Action Illinois and the Woodstock Institute, with a Steering Committee that currently includes the Chicago Community Loan Fund, Chicago Community Trust, Chicago Lawyers Committee for Civil Rights, Chicago Rehab Network, Chicago Urban League, NHS of Chicago, The Resurrection Project, and the Small Business Majority.

Our coalition works in partnership with a wide range of organizations across Illinois including, but not limited to non-profit housing organizations, community development financial institutions (CDFIs), small businesses, and philanthropic organizations. In addition to our co-leaders and Steering Committee members, organizations who have supported this initiative include:

Access Living
Alliance to End Homelessness in Suburban Cook County
BEDS Plus Care, Inc.
BPI
Center for Changing Lives
Center for Neighborhood Technology
Chicago Area Fair Housing Alliance
Chicago Coalition for the Homeless
Chicago Community Land Trust
Chicago Community Loan Fund *
Chicago Community Trust *
Chicago Jobs Council
Chicago Lawyers Committee for Civil Rights *
Chicago Rehab Network *
Chicago Urban League *
Chicago Westside NAACP
Coalition for Equitable Community Development
Cobblestone Bakery and Caterer, LLC
Corporation for Supportive Housing
East Side Heart & Home Family Center
Economic Awareness Council
Economic Security for Illinois
Elevate
Fair Housing Legal Support Center, UIC John Marshall Law School
Faith Community Homes, Arlington Heights, IL
Habitat for Humanity of Champaign County
Hawk-Attollo
Heartland Alliance for Human Needs & Human Rights
Housing Action Illinois *
Housing Choice Partners
Housing Opportunities and Maintenance for the Elderly (H.O.M.E)
Human Resources Development Institute
IFF
Illinois Asset Building Group
Institute for Cultural Affairs
Lawyers’ Committee for Better Housing
Legal Action Chicago
League of Women Voters of Illinois
Madison County Urban League Inc
Menard County Housing Authority
National Coalition for Latinxs with Disabilities
New Covenant CDC
NHS of Chicago *
Northwest Side Housing Center
NW HomeStart, Inc.
Oak Park Regional Housing Center
Preservation of Affordable Housing, Inc. (POAH)
Resistance Legal Clinic
Respond Now
Revolution Workshop
Small Business Majority *
South Suburban Housing Center
Spanish Coalition for Housing (SCH)
The Resurrection Project *
The Statewide Independent Living Council of Illinois
Two Rivers Headstart CSBG Program
Universal Housing Solutions CDC
Women Employed
Women’s Business Development Center
Woodstock Institute *

* Steering Committee Member

Our Mission

The Illinois CRA Coalition is a group of organizations dedicated to protecting and strengthening the federal and the Illinois Community Reinvestment Acts as tools for building more equitable communities and addressing the racial wealth gap. Our coalition successfully advocated for the passage of the IL CRA in 2021. We continue to advocate for strong implementation of the new state law and positive reform of the federal CRA.

Get Involved.

Interested in joining our coalition? Send us a message.

Resources & Past Initiatives