This week, The Real Estate Roundtable (RER) urged all three federal banking agencies to adopt clear, harmonized Community Reinvestment Act (CRA) rules to reduce compliance costs and support capital investment in affordable housing and underserved communities. (Letter, Oct. 13)

CRA Rulemaking

• In the Oct. 13 letter, RER called for the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and Federal Reserve to adopt clear, harmonized CRA rules. The OCC and FDIC have jointly proposed changes without parallel Federal Reserve action. (Letter, Oct. 13)

• Enacted in 1977 to combat redlining, the CRA encourages banks to meet the credit needs of their entire communities, including low- and moderate-income neighborhoods.

• RER supports continued efforts to modernize CRA rules but cautioned that finalizing changes without parallel Federal Reserve action could replace the historically uniform interagency framework with materially different regulatory regimes. (Letter, Oct. 13)

Why It Matters

• Affordable housing and community development projects frequently rely on multiple banks providing construction loans, permanent financing, tax credit investments, and other forms of capital.

• A divided CRA regime could make identical loans receive different treatment, weaken investment incentives for some lenders, complicate mergers and syndicated transactions, and make the flow of capital into underserved markets less predictable.

• RER also raised concerns about a potential 1.25% of Tier 1 capital benchmark for wholesale and limited-purpose banks, which would need to be met within their assessment areas before qualifying activities elsewhere could receive CRA consideration. (Letter, Oct. 13)

• The benchmark could concentrate investment in heavily banked markets while disadvantaging strong projects in smaller metropolitan and rural communities.

• RER recommended uniform rules, coordinated implementation and consistent treatment of multibank transactions. (Letter, Oct. 13)

RER Advocacy

• RER urged the agencies to coordinate transition schedules, examinations and interpretive guidance, and apply consistent standards to multibank housing and community development transactions. (Letter, Oct. 13)

• Existing requirements should remain in place until all three agencies jointly propose and finalize a harmonized framework.

Manufactured Housing

• HUD released its Next Generation Manufactured Housing Action Plan last week, outlining seven actions to modernize the HUD code and implement the 21st Century ROAD to Housing Act’s removal of the permanent chassis requirement. (HUD Press Release, Oct. 7 | HousingWire, Oct. 8)

• The plan calls for updated energy efficiency standards, design and installation rules for chassis-free homes, and a performance-based code for larger factory-built residential structures. HUD will also develop guidance and resources addressing zoning, appraisal, lending, and insurance. (HUD, Oct. 7)
  

• The ROAD Act eliminates the requirement that manufactured homes be built and remain on a permanent steel transport frame—a relic of the mobile home era. The change could reduce construction costs by $5,000–$10,000 per home, by some estimates, allow more flexible designs, and reduce local zoning barriers. (RER’s Housing Fact Sheet, July 2026)

RER will continue working with banking agencies and stakeholders to advance rules that support community investment and provide certainty for real estate financing.