Josh Silver

Josh Silver
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Josh B. Silver is a senior adviser with the National Community Reinvestment Coalition, where he produces white papers on the Community Reinvestment Act and fair lending policy and issues.

Why the Community Reinvestment Act Must Be Expanded Broadly Throughout the Financial Industry

The financial industry has been one of the main perpetrators of racial discrimination. It should be obligated to serve all communities, particularly communities of color.

Banks Can Earn CRA Credit for COVID Response—But Who’s Benefiting?

All banking activities, regardless of whether they benefit middle- and upper-income or low- and moderate-income people and communities, could count in the next round of CRA exams. This would further disadvantage communities that are already disproportionately impacted by the pandemic.

Could Lack of Impact Assessment in OCC and FDIC Proposal Break CRA?

Proposed changes to CRA by the Office of the Comptroller of the Currency and the FDIC conflict with the best practices of community development.
bank brach counters

New Writings Suggest Incremental Change Is Best Path for CRA Reform

These writings suggest that careful reform of CRA regulations can build upon the progress in lending and investing if the reforms are incremental instead of “transformational." 
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Don’t Diminish the Importance of Homeownership in CRA Reform

A significant reduction in attention paid to home mortgage lending on CRA exams would be neither economically efficient nor equitable.
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The CFPB Needs Sunlight: Keep Easy Access to HMDA Data

The Consumer Financial Protection Bureau's reassurances on continued public access to Home Mortgage Disclosure Act data are not very reassuring.
facing segregation book cover

Facing Down Segregation—Half-heartedly or With Steely Determination?

A new book explores the history, impact, and policy solutions to racial segregation.
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Where Banks and the Public Agree on CRA . . . and Disagree

Despite a CRA exam pass rate of 98 percent, the major thrust of bank comments is that they want easier exams with fewer moving parts and less uncertainty.
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.