Josh Silver

35 Posts

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.
Housing Advocacy

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 missed a critically important action to encourage lenders’ compliance with consumer […]

Organizing

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 payday loans: the CFPB received 1 […]

Housing Advocacy

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 for the fences when it came to the Community Reinvestment Act […]

Financial System

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 demonstrate that their deposit facilities serve the convenience and needs of […]

Organizing

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 delivered within hours to their doorstep. […]

Housing Advocacy

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 some other resource that rates companies selling the products. Imagine if […]

Housing Advocacy

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 about the federal CRA, and for good reason; the federal CRA […]

Health

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 by all sectors of society–not only […]

Housing Advocacy

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 the credit needs of the local […]

Financial System

Public Benefits and Bank Mergers

Community organizations are generally aware that when a bank wants to acquire another bank, it must submit a merger application to a federal agency. But many community organizations may not […]

Financial System

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 in 2002. Now that 2002 is […]