Josh Silver

Josh Silver
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Josh B. Silver is a senior advisor with the National Community Reinvestment Coalition (NCRC), where he produces white papers on the Community Reinvestment Act and fair lending policy and issues.
The spires and statue atop an old bank building.

Warren Housing Bill Presents a Clear Choice on CRA

Senator Elizabeth Warren and the Office of the Comptroller of the Currency have offered contrasting visions for the future of CRA. How do they differ, and what would the implications for historically disinvested communities be?
memorial

An Old American Struggle, Always New

Color and Character is an introduction to the seminal and unresolved struggle over integration and racial equality in America.
Rubin cover, Advocacy for Social Change

Advocacy for Social Change: Coalitions and the Organizations that Lead Them

Many books discuss the corrosive effect of money in politics and lobbying organizations, but few are devoted to how those representing the have-nots organize on a national level to fight for laws and regulations that seek to empower communities.
computer keyboard

Data Drives the Movement for Economic Justice

A government report concludes that residents of low- and moderate-income Census tracts have as much access to bank branches as residents in middle- and upper-income tracts in rural areas and large metropolitan areas. Yet access to bank services for low- and moderate-income consumers is still being lost. Why is that?
red herring

The Big Red Herring: The Home Mortgage Disclosure Act (HMDA) Will Help Predators Identify...

HMDA is the key to preventing predatory behavior, not the cause of it, so how can an economics professor from George Washington University claim that HMDA can facilitate large-scale identity theft?
Display of Jim Crow-era signs

Integration as a Means of Combating Inequality

A review of books that delve into the harmful and far-reaching effects of racial segregation and solutions that integration measures can provide.
The spires and statue atop an old bank building.

Would Trump’s CRA Reform Really “Do No Harm?”

NCRC examined every single Community Reinvestment Act evaluation for mid-size banks conducted during 2016.
Cover of book

Meltdown: The Financial Crisis, Consumer Protection, and the Road Forward

In 2010, the scattered enforcement of consumer protection and fair lending laws across several agencies would end. The CFPB would have broad oversight over banks and non-banks, and though not perfect, this model has produced some impressive results.
The spires and statue atop an old bank building.

The Community Reinvestment Act at 40: A Careful Review of the Reviews

A review of HUD's Cityscape issue, which is devoted to reviews and studies of the Community Reinvestment Act at its 40th anniversary.
Black computer enter key

SoFi, Not So Good: Is This Virtual Redlining?

SoFi is practicing product segregation. It wants to serve affluent people with its best products and shunt low- and moderate-income borrowers into inferior products that do not meaningfully serve credit needs.
Red road sign that says "Wrong Way"

Under Trump, Treasury Goes Backward on Community Protections

A recent Treasury Department report on bank regulation and policy promotes changes that would move us backward when it comes to building a financial system that is equitable, efficient, and protects consumers and communities from abusive practices.
Neon sign in window reads "Real Estate Home Loans."

Despite What Bankers Say, Data Is Indispensable

The American Bankers Association (ABA) issued a white paper maintaining that the CFPB exceeded its mandate under Dodd-Frank. Full of rhetoric, the white paper makes a number of unfounded allegations about HMDA data and the CFPB final rule.

CRA Should be Becoming Less Partisan. Instead, It’s More.

The Community Reinvestment Act (CRA) is a law that requires banks to serve the credit needs, consistent with safety and soundness, of all...

How Data Disclosure Will Help Prevent the Next Financial Crisis

It seems like an overstatement, but data disclosure can help prevent the next financial crisis. ...

OCC Moving Steadily Forward on Fintechs–Is This a Good Thing?

The Office of the Comptroller of the Currency (OCC) appears to be plowing ahead with its proposal to allow...

How CRA Can Promote Integration in Gentrifying Neighborhoods

Gentrification—the process of neighborhood demographic and economic change in which middle- and upper-income people move into lower-income neighborhoods, increasing...

An Opportunity to Shed Sunlight on Lender Legal Compliance is Missed

Bank regulatory agencies including the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and others...

A Strong Rule and Reforms Are Needed to Combat Payday Loans

Something astonishing happened when the Consumer Financial Protection Bureau (CFPB) asked the public for comments on its proposed rule to curb high-cost and abusive...

Tweaks to CRA Q&A Document Miss the Larger Picture

During the dog days of summer this July, the federal bank agencies decided to quietly bunt instead of swing...

Why Are Biased Banks Getting High CRA Marks from Regulators?

The Community Reinvestment Act (CRA) statute has a statement of purpose affirming that banks “are required by law to...

The Romance and Reality of the New Financial Technology (Fintech) Companies

Technology is enticing. It's fun. It can make life easier. With a click of a button, consumers can purchase...

Imagine if Banks Had a Rating Showing Compliance with Consumer Law?

When consumers shop for new cars or other major products, they often like to consult with Consumer Reports or...

CRA on a State Level Makes Sense

When practitioners in the affordable housing and community development field think about the Community Reinvestment Act (CRA), they think...

How the Community Reinvestment Act Can Help Flint

The audacious and callous decisions leading to the tragedy in Flint, Michigan are cruel and beyond comprehension. What is needed is an all-out effort...

CRA Exams Aren’t Cutting It For Communities in Need

In 1977, Congress passed the Community Reinvestment Act (CRA) and required the federal banking agencies to assess a bank’s record of helping to meet...

Public Benefits and Bank Mergers

Community organizations are generally aware that when a bank wants to acquire another bank, it must submit a merger...

Strengthening the CRA

In 1995, the last time federal banking agencies revised the rules of the Community Reinvestment Act (CRA), they promised to conduct a follow-up review...