The CRA and How it Works
The federal Community Reinvestment Act (CRA) creates an affirmative obligation for banks to meet the credit needs of the communities in which they are chartered to do business, particularly low-moderate income (LMI) communities. Passed in 1977 to address redlining and disinvestment in our cities, the CRA has encouraged banks to increase their lending, investments, and services in many communities.
Coalitions Related to Our Work
GRCRC—The Greater Rochester Community Reinvestment Coalition (GRCRC) was launched in 1993 to generate and continue discussions about disparate lending patterns in Rochester NY. Convened by Empire Justice Center, GRCRC is a coalition of over 35 organizations that meets with banks and state and federal regulators during CRA exams and mergers and submits data-driven comments about the performance of Rochester’s largest banks in serving low-moderate income communities and Black and brown communities. GRCRC, Empire Justice Center, and its predecessor organization, the Public Interest Law Office of Rochester, have released seventeen analyses of home mortgage lending, small business lending, and access to credit since 1993. These data driven analyses help us identify strengths and weaknesses in lending patterns and to generate discussions with the area’s top banks.[1] In September 2018 Empire Justice Center released, “Too Big to Fail…Too Poor to Bank: How Mainstream Financial Services Can Help Low-Income Working Families Succeed,” a review of traditional bank products and services, as well as those provided by alternative financial services, like check cashers. The report found that while banks in the Rochester NY area do offer checking and transaction accounts with affordable, consumer-friendly features, they are often not well-marketed, so consumers do not know about them.
NCRC—Formed in 1990, the National Community Reinvestment Coalition works to increase the flow of private capital into traditionally underserved communities. Its 600 community- based organizations promote access to basic banking services, affordable housing, entrepreneurship, job creation and vibrant communities for America’s working families. Click here to learn more.
NYRL—New Yorkers for Responsible Lending is a coalition of more than 160 organizations from all corners of New York State that promotes economic justice as a matter of racial and community equity through legislative and policy advocacy, popular education, media advocacy, and organizing campaigns. Click here to learn more.
NYS Community Equity Agenda is a broad-based coalition of community, labor, civil rights, and legal services groups, cooperative organizations, and community development financial institutions with an affirmative, solutions-oriented platform, focusing on concrete legislative and regulatory changes in NYS that put racial and economic justice front and center and addresses long-standing inequities that play out at neighborhood and regional levels. Click here to learn more.
Community Reinvestment Team
Ruhi and Barb have been working together since 2001 to increase bank investments in formerly redlined communities, to improve access to responsible mortgages and other financial products and services, and to increase equitable access to housing throughout our communities.
Resources
OUR REPORTS THAT INFORM OUR COMMUNITY REINVESTMENT ADVOCACY
They include analyzing financial institutions’ provision of responsible mortgage and small business credit and other financial products to BIPOC and LMI communities and how these communities are impacted by economic downturns.
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Empire Justice comments on the Public Review Draft of Plan Forward – A Comprehensive Plan for Monroe County. Our comments mainly focus on the goals and strategies to increase access to a variety of housing that meets the needs of workers and families at different stages of life and is more affordable. Read the letter […]
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The Inclusive Housing Coalition and its six organizational members provided joint comments on the final draft of the City of Rochester’s new zoning code. While the coalition is pleased with many of its changes from the 2023 draft, it asks the City Planning Commission to recommend that the final draft incorporate its suggestions before it […]
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Greater Rochester Community Reinvestment Coalition (GRCRC) submit comments regarding Five Star Bank’s (Five Star) CRA Exam conducted by the Federal Reserve Bank of NY (FRBNY) and the NY Department of Financial Services and covering 2022-2024. These comments focus on four areas: Read the letter HERE.
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Greater Rochester Community Reinvestment Coalition (GRCRC) submit comments regarding Canandaigua National Bank’s (CNB) CRA Exam conducted by the Office of the Comptroller of the Currency (OCC) and covering 2021-2023. Read the letter HERE.
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Empire Justice Center provides comments supporting Monroe County’s County-Wide Climate Action Plan. Our comments mainly focus on the strategies that reduce greenhouse gas (GHG) emissions via housing or residential energy use. A PDF version of our comments is available to view.
Training Videos
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Empire Justice Center is excited to announce our third training under our Building Equity Initiative, a new component of our Homeowner Protection Program (HOPP) The Building Equity Initiative focuses on...

Greater Rochester Community Reinvestment Coalition (GRCRC) Submits Comments on M & T Bank’s CRA Exam
Greater Rochester Community Reinvestment Coalition (GRCRC) submit comments regarding M&T Bank’s (M&T) CRA Exam conducted by the Federal Reserve Bank of NY (FRBNY) for January 1, 2022 – December 31, 2025 and the NYS Department of Financial Services (DFS) for April 23, 2023 – December 31, 2025. Our tables andanalyses will go through 2025 when […]