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Strengthening the Community Reinvestment Act : a critical strategy for population health

Written by Douglas P. Jutte, MD, MPH, and Ruth Thomas-Squance, PhD, MPH on August 8, 2022

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Meeting the Aug 5th, 2022 deadline, Build Healthy Places Network (BHPN) submitted comments to the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) in relation to a proposed rulemaking around the Community Reinvestment Act (CRA).

The CRA is important anti-redlining legislation that has been in place since 1979 that requires for-profit banks to invest in low-income neighborhoods from where they take deposits. The resulting CRA-motivated banks provide the bulk of the critical community development investments going into low-income neighborhoods, to the tune of over $300 billion annually. The Federal Reserve, FDIC, and OCC are the national regulators which ensure that the country’s for-profit banks meet their CRA requirements.

BHPN welcomes the notice of proposed rulemaking that represents an opportunity to help to clarify and enhance investment to improve intergenerational health, equity and well-being in our communities. We also thank the leadership of the National Community Reinvestment Coalition (NCRC) for doing the hard work of summarizing the complex proposed rule changes and providing a letter template, which served as the basis of our comment submission.

Our comments are summarized below:

Expanding Definitions Strengthens Healthcare Partnerships

We applaud the proposed expansion of the definition of ‘community development’ ”, that helps to clarify that banks can – and should – make investments with hospital systems to support community development. Two of the definitional categories, community supportive services and essential community facilities, now name health services explicitly.

Improved Data Collection Paints a Better Picture of Impact

We urge the agencies to improve data collection for the impact review section of the community development finance test.  Healthcare and public health entities are critical partners in obtaining the most relevant evidence and statistics to demonstrate impact on health, such as number of health visits or beds in healthcare facilities or how many housing units had lead paint abatement.  This data will enhance capacity to capture the

Addressing Root Causes that Drive Poor Health Outcomes

Within the impact assessment it is critically important to recognize that clinical care and personal behavior are not the only factors that contribute to health outcomes. 

Most health outcomes, both good and bad, are due to social determinants such as affordable and stable housing, income, job opportunities, access to healthy foods, and more. In order to best promote healthier outcomes, we need affordable housing, steady job growth, thriving schools, and recreation and green spaces in our communities.

Strengthening the CRA is needed to encourage banks to make the crucial loans and investments impacting social determinants of health to support positive health outcomes and thriving communities.

Establish Accountability to Address Racial Inequity

The current proposed changes do not go far enough with consideration to addressing racial inequality. Persistent racial disparities in lending should compel the agencies to incorporate race and ethnicity into CRA exams. 

A recent national level analysis showed continuing disparities in loan denials by race, and when people of color receive home loans, their equity accumulation was less. We appreciate the consideration of the health of our underserved communities as a critical part of CRA. We strongly support the commitment to measuring lending by race but urge the agencies to go further and establish accountability by explicitly incorporating race/ethnicity into CRA exams.

Placing Community Input – Front and Center

The increased emphasis on efforts to obtain broad public input is much appreciated and we further urge the agencies involved to be transparent in reporting the input of community members, particularly in regard to whether community needs are being met. We also urge you to establish a public directory listing the community members contacted.

BHPN was excited to partner with NCRC in their work to raise awareness around the submitting comments during this period.

Building on the good start established by the current proposed rule changes, the agencies have an opportunity to further codify the consideration of the health of our underserved communities as a critical part of CRA.

BHPN is committed to continuing the support of this work as we transform the way organizations work together across the health, community development and finance sectors to more effectively reduce poverty, advance racial equity, and improve health in neighborhoods across the United States.

About the Authors


Douglas P. Jutte, MD, MPH

Executive Director, Build Healthy Places Network

Douglas Jutte, MD, MPH is Executive Director of the Build Healthy Places Network, a national organization with the mission to transform the way organizations work together across the health, community development, and finance sectors to more effectively reduce poverty, advance racial equity, and improve health in neighborhoods across the United States. Dr. Jutte sits on the Board of Trustees for Mercy Housing, a national non-profit affordable housing developer, and is a member of the health advisory committee for Enterprise Community Partners, one of the country’s largest community development financial institutions (CDFIs). He is also a member of CommonSpirit Health’s Community Economic Initiatives committee and Trinity Health’s Socially Responsible Investment Advisory Group. He has been a leader in the Federal Reserve Bank and RWJ Foundation’s Healthy Communities Initiative, which has convened over 40 cross-sector gatherings throughout the country since 2010.

About the Authors


Ruth Thomas-Squance, PhD, MPH

Senior Director of Field Building, Build Healthy Places Network

Ruth Thomas-Squance, PhD, MPH, is Senior Director of Field Building at the Build Healthy Places Network where she ensures delivery of high quality activities and content in line with the organization’s national Field Building Strategy.  Dr. Thomas-Squance advances engagement with state and national initiatives, curates resources and identifies promising practices that build high level support for effective collaborations at the intersection of community development, public health and healthcare sectors.

Dr. Thomas-Squance’s passion for contributing to the promotion of health and social equity has taken her from a successful career in biomedical research to management in the non-profit and public sectors.  She brings over 10 years of experience working in multi-sector collaborations with diverse partners.  She served as executive director of a Bay Area non-profit providing training in emotional intelligence skills development to low income and minority populations and organizations that work with them. Before joining the Network she worked at San Francisco Department of Public Health in Whole Person Care, a Medi-Cal waiver program strategizing approaches to improve outcomes for adults experiencing homelessness and high users of urgent emergent healthcare services.

Dr. Thomas-Squance earned her doctorate from Imperial College of Science, Technology and Medicine, London, UK and her Master of Public Health from UC Berkeley.  She lives in San Francisco with her family.