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 Illinoisans of color and low-income Illinois by ensuring that banks and other financial institutions invest and conduct business in our communities in a just, equitable manner.
On May 5, the Federal Deposit Insurance Corporation, in cooperation with the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency, announced the release of a Notice of Proposed Rulemaking proposing regulatory amendments for the implementation of the Community Reinvestment Act. Comments responding to the proposed rule are due by August 5, 2022.
The IL CRA Coalition has reviewed the proposed rule and drafted a comment letter for submission to the regulatory agencies.
Add Your Voice
Today is the last day to speak up and influence changes that the three federal regulatory agencies make to the federal CRA rules. Individuals can use our letter as a template and submit comments via our easy-to-use portal.
This is a key opportunity that may not occur again in the foreseeable future.
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.
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.
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. This presents a once in a generation opportunity to modernize the CRA, and the IL CRA Coalition is again working to organize comments from across the state to ensure that whatever is adopted reflects the needs of low- and moderate-income communities and communities of color.
About the Illinois CRA
The Illinois Community Reinvestment Act (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
The Illinois Department of Financial and Professional Regulation (IDFPR) is still determining how to implement the IL CRA. See the current status section below for more information.
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.
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. IDFPR is currently reviewing all of the comments it received and will be releasing a proposed final rule, likely sometime in 2022. When this happens, the IL CRA Coalition will again advocate and organize stakeholders to ensure that the implementing rules for the IL CRA create an effective, strong tool for furthering equitable access to capital and financial inclusion.
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:
Alliance to End Homelessness in Suburban Cook County
BEDS Plus Care, Inc.
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
Fair Housing Legal Support Center, UIC John Marshall Law School
Faith Community Homes, Arlington Heights, IL
Habitat for Humanity of Champaign County
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
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
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’s Business Development Center
Woodstock Institute *
* Steering Committee Member
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.
Interested in joining our coalition? Send us a message.
Resources & Past Initiatives
IL CRA Coalition Statements
Federal CRA Letters
- IL CRA Coalition letter to the Federal Reserve Board of Governors, 2/16/21
- IL CRA Coalition letter to the federal banking agencies, 6/5/20
- Housing Action Illinois letter to the Office of the Comptroller of the Currency and the FDIC, 1/28/20
State CRA Letters
- IL CRA Coalition letter to IDFPR, 12/28/21
- IL CRA Coalition written comments to IDFPR, 10/15/21
- IL CRA Coalition letter to Rep. Lamont J. Robinson, Jr., 3/15/21
- IL CRA Coalition letter to Gov. JB Pritzker, 2/16/21
- New State Community Reinvestment Law Takes Aim at Lending Disparities, 3/4/21
- Illinois Community Reinvestment Act Passed by General Assembly as Part of Black Caucus’ Economic Equity Pillar, 1/13/21
- Letter to Banking Regulators: Use CRA to Address Racism, 6/5/20
- Mayor Lightfoot, Chicago Advocates Decry Plan to Weaken Anti-Redlining Rules, 5/22/20
IL CRA Coalition Webinars
Federal CRA Reform Updates
Federal CRA Regulators
- Federal Reserve Bank
- Office of the Comptroller of the Currency
- Federal Deposit Insurance Corporation
Illinois CRA Rulemaking
Coalition Partner Resources