PHADA to Submit Comments; Members Encouraged to Comment by October 13
In July 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) proposed a new Community Reinvestment Act (CRA) rule. The proposed rule could threaten billions in equity investments in Low-Income Housing Tax Credit (LIHTC) deals. A 2025 study estimates that 80 percent of equity investments in the LIHTC come from CRA-motivated bank investors.
The CRA incentivizes banks to lend and invest in low- and moderate-income neighborhoods by requiring banks to assess and report on how they are meeting the credit needs of the entire community. A strong CRA rating helps banks to secure approval for mergers, acquisitions, branch openings, and relocations from federal regulators.
PHADA has signed onto a coalition letter led by the National Association of Affordable Housing Lenders (NAAHL). The Association encourages interested members to sign onto this letter by October 6 and to submit comments on the proposed rule, particularly if your agency has LIHTC properties in its portfolio
Members may also submit any questions or provide feedback on the proposal to Malcolm Guy at: mguy@phada.org.
PHADA also previously submitted comments on the 2020 proposed CRA rule. More details on the CRA will be in the upcoming issue of the Advocate.