CRA Publications

  • Beware the Fed’s heavy hand in proposed CRA reforms,” May 18, 2022
  • If the fair-lending vigilantes catch you, it’s your own fault,” April 11, 2022
  • “Carpetbagger” banks are draining my city of loanable funds, December 8, 2021
  • Redlining settlement with Trustmark came much too late, November 1, 2021
  • Community banks are getting too little credit for PPP loans, September 17, 2021
  • Fintechs shouldn’t be granted easy outs on CRA, January 4, 2021
  • Fed’s CRA plan does too much, too little,” October 30, 2020
  • “Pandemic makes CRA reform more urgent, not less,” May 13, 2020
  • “Give CRA reform credit where its due,” December 19, 2019
  • “The Fed’s remarkable turnaround on CRA,” July 15, 2019
  • “Don’t overhaul CRA just for the sake of it,” May 9, 2019
  • “Dear regulators: Don’t take CRA’s revamp too far,” November 1, 2018
  • “Is the OCC becoming a ‘lone wolf’ on bank policy?” September 5, 2018
  • “Why fintechs should be held to CRA standards,” August 24, 2018
  • “Grading Treasury’s CRA reform memo: ‘Incomplete’,” April 30, 2018
  • “Banks Need to Know: How Much CRA Activity is Enough?” November 30, 2017
  • “Keep CRA for Fintech, but Lose its Geographic Boundaries,” August 22, 2017
  • “Banks Learn the Price of ‘Satisfactory’ CRA Grades,” September 13, 2016
  • Regulators Need to Hold Community Groups Accountable,” August 6, 2015
  • “A Simple CRA is an Effective CRA,” October 21, 2014
  • “Comptroller Curry: How About Some Real CRA Reform,” April 9, 2014
  • “CRA Due Diligence More Critical than Ever,” December 19, 2008
  • “For Clear Picture, Add Risk to HMDA Data,” October 14, 2005
  • “Time for a Compromise on Small-Bank Exams,” November 12, 2004
  • “The CRA Should Be Reformed – But Leave it Race-Blind,” September 11, 2003
  • “CRA at 25: Reforming an Almost Perfect Law,” December 12, 2002
  • “Hawke’s Revival of Shared Branch Idea Is Welcome,” December 17, 1999
  • “Rising above CRA noncompliance,” November 6, 1991
  • CRA Grade Inflation, Working Paper No. 313 (The Levy Economics Institute of Bard College, Annandale-On-Hudson, NY, September 2000)
  • CRA’s 25th Anniversary: The Past, Present, and Future, Working Paper No. 346 (The Levy Economics Institute of Bard College, Annandale-On-Hudson, NY, June 2002)
  • Optimal CRA Reform: Balancing Government Regulation and Market Forces, Public Policy Brief No. 68 (The Levy Economics Institute of Bard College, Annandale-On-Hudson, NY, 2002)

CRA Reform Input

Documented commentary and thought leadership on CRA Reform, from public commentary to the OCC's Final Rule and the May 5, 2022 Joint NPR.

OCC Advance Notice of Public Rulemaking (Public Comments)

OCC FDIC Joint Notice of Public Rulemaking (Public Comments)

Leadership from the ground up

Dr. Thomas’ work on CRA reform has been widely adapted and supported by regulators and legislators. His book Community Reinvestment Performance was the only endorsement that Senator Proxmire gave amongst all CRA publications. Senator Proxmire was the Chairman of the Senate Banking Committee and is widely considered as the “Father of CRA”.

Contact Us
  • March 1995
  • Dr. Kenneth H. Thomas and
  • Senator William Proxmire
  • McGraw Hill
  • New York, 1998
  • Probus Publishing
  • Chicago, 1993