CRA Publications
- “For bankers facing the new CRA rule, it’s time to “Fight the Fed”: March 11, 2024
- “Banks are under extreme regulatory assault; it’s time to act like it,” January 8, 2024
- “Forget redlining. Branchless banks are now ‘weblining’ our communities,” December 11, 2023
- “Channeling Twisted Sister, more bankers are taking regulators to court,” October 12, 2023
- “There’s a surprising risk lurking in the details of bank mergers,” January 30, 2023
- “Bankers must challenge the overly complex, Fed-driven CRA overhaul,” October 17, 2022
- “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 Proposed Rulemaking (Public Comments)
OCC FDIC Joint Notice of Proposed Rulemaking (Public Comments)
FED, FDIC and OCC Joint Notice of Proposed Rulemaking (Public Comments)
- SUMMARY Kenneth H. Thomas, Ph.D. EXECUTIVE SUMMARY OF SIX NPR COMMENTS ON WHY THE NPR SHOULD BE DISCARDED August 5, 2022 11
- 1 Kenneth H. Thomas Ph.D. FIRST NPR COMMENT ON The NPR’s Comment Period Should Have Been Extended AUGUST 5, 2022 16
- 2 Kenneth H. Thomas Ph.D. SECOND NPR COMMENT ON The Fed’s Heavy Hand in this NPR AUGUST 5 2022 18
- 3 Kenneth H. Thomas Ph.D. THIRD NPR COMMENT ON The Fed’s Mission Creep and Overreach on CRA Reform AUGUST 5, 2022 18
- 4 Kenneth H. Thomas Ph.D. FOURTH NPR COMMENT ON The NPR Must Have the 5% Deposit Reinvestment Rule AUGUST 5, 2022 11
- 5 Kenneth H. Thomas Ph.D. FIFTH NPR COMMENT ON The NPR’s Major Errors of Commission and Omission AUGUST 5, 2022 23
- 6 Kenneth H. Thomas Ph.D. SIXTH NPR COMMENT ON Why Community Groups, Banks and Examiners Should Oppose the NPR AUGUST 5, 2022 18
CRA Reform Podcasts and Webinars
- What CRA Means To Your Bank, April18, 2019
- CRA Reform: How Did We Get Here and Where Are We Going? May 14, 2020
- The OCC’s final CRA rule: what changed from the agency’s proposed rule? June 15, 2020
- CRA Modernization and COVID Recovery Efforts Collide, May 26, 2020
- OCC’S FINAL CRA RULE – WHAT IT MEANS FOR YOUR BANK, June 24, 2020
- Barret School of Banking, June 25, 2020
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