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.
CRA

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 communities,...

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.   In the run-up to the Great Recession, subprime and other...

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 non-bank financial technology companies, known...

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 items instantaneously and have them...

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...