Advocacy

CDBA's advocacy efforts are conducted through correspondence, testimony, and other formal communications with federal policymakers. Below are examples of our past, present, and ongoing advocacy efforts.

2023

CDBA Comment Letter to CDFI Fund on Capital Magnet Fund - September 5, 2023
CDBA Comment Letter to FDIC on Special Assessments Pursuant to Systemic Risk Determination - July 20, 2023
CDBA Comment Letter to Treasury on CDFI and NACA Programs - May 12, 2023
CDBA and NBA Joint Comment Letter to EPA on the Greenhouse Gas Reduction Fund - May 9, 2023
Comment Letter to Treasury on ECIP Initial Supplemental Report and Quarterly Supplemental Report - April 26, 2023
CDBA Comment Letter to CDFI Fund on NMTC Transaction Level Report - April 5, 2023
National Banking Trades Letter to Congressional Leadership of the Appropriations Subcommittee for Financial Services and General Government - March 24, 2023
National Banking Trades Letter to Congressional Leadership of the Full Appropriations Committee - March 24, 2023
CDBA Letter to Congressional Leadership of the Full Appropriations Committee about CDFI Fund and BEA Appropriations - March 24, 2023
CDBA Letter to Congressional Leadership of the Congressional Appropriations Subcommittee for Financial Services and General Government about CDFI Fund and BEA Appropriations - March 24, 2023
Multi-participant securitization for unguaranteed portions of SBA 7(a) loans - March 13, 2023
CDBA Comment Letter to Treasury on CDFI ACR and TLR - Jan 27, 2023

2022

CDBA Comment Letter to Treasury on Federal Community Investment Programs - Dec 19, 2022
CDBA Comment Letter to CDFI Fund on Target Markets - Dec 16, 2022
CDBA and NBA Letter to Treasury on CDFI Certification Application Requirements - Dec 5, 2022
CDBA Comment Letter to EPA on the Greenhouse Gas Reduction Fund - Dec 2, 2022
CDBA Comment Letter to Treasury on the Bank Enterprise Award Program Application - Nov 28, 2022
CDBA Comment Letter to Treasury on Minority Lending Institution Designation Criteria - Nov 25, 2022
Joint Trades Comment Letter to Treasury on CDFI Fund Report Forms - Nov 25. 2022
Comment Letter for RFI on Opportunities and Challenges in Federal Community Investment Programs - Nov 10, 2022
CDBA and NBA Letter to Senate on Regulation of Interchange - Oct 31, 2022
CDBA Letter to Treasury on State Small Business Credit Initiative (SSBCI) - October 20, 2022
CDBA Comment Letter to FASB on Accounting for Government Grants by Business Entities - September 12, 2022
CDBA ECIP QSR Letter to Treasury - August 29, 2022
CDBA and NBA Letter to FDIC on Revised Deposit Insurance Assessment Rates - August 18, 2022
CDBA Letter to Treasury on Risks and Opportunities Presented by Digital Assets - August 8, 2022
CDBA NPR CRA Comment Letter - Aug 5, 2022
CRA Comment Period Extension Request Banking Trades Joint Letter - May 31, 2022
CDBA Letter to Full Appropriations Committee FY2023 - April 27, 2022
CDBA Letter to Appropriations Committees FY2023 - April 26, 2022
National Banking Trades Letter to Appropriations Committees on FY2023 - April 26, 2022
Joint Trades on ECIP Closing for Sub S Banks - April 15, 2022
Joint Trades Response to CFPB Fees - April 11, 2022
CDBA ECIP Legal and Baseline Comments to Treasury - March 1, 2022
CDBA Letter to Treasury on ECIP Baseline Reporting - February 28, 2022
CDBA and NBA ECIP Legal and Baseline Comment Period - February 15, 2022
National Banking Trades Letter to Appropriations Committees on FY 2022 - February 10, 2022
CDBA Comment Letter to CFPB on Section 1071 Small Business Lending Data Collection - January 6, 2022

2021

Joint Trades Letter on ECIP and Sub S and Mutuals - December 29, 2021
CDBA Comment Letter to CDFI Fund on SDLP Application - December 3, 2021
CDBA-NBA Letter to House and Senate Small Business Committees on Build Back Better Act - December 2, 2021
CDBA-NBA Letter to SBA on Build Back Better Direct Lending - November 16, 2021
Joint Trades Letter to OCC on CRA - October 29, 2021
Joint Trades Letter on Treasury Account Reporting Proposal - July 28, 2021
CDBA Comment Letter to FDIC on Proposed False Advertising Rule - July 7, 2021
Joint Banking Trades Letter on Account Flow Reporting Requirements - June 10, 2021
CDBA Letter on reporting Loan Participations and Loan Purchases - June 1, 2021
CDBA ECIP Comments to OCC - May 20, 2021
CDBA ECIP Comments to FDIC - May 20, 2021
CDBA ECIP Comments to FRB - May 20, 2021
CDBA ECIP Comments to Federal Reserve - May 14, 2021
CDBA ECIP Comments to Treasury - May 14, 2021
CDBA Letter to Appropriations Committees FY 2022 - FSGG - May 5, 2021
Joint Trades Request to Withdraw or Delay CRA Rule - May 3, 2021
CDBA Comment Letter on M&T-People's United Merger - April 27, 2021
CDBA Comments to Treasury on ECIP - April 7, 2021
Joint Trades Letter to Treasury on ECIP Deadline - March 25, 2021
Joint Trades Letter to Small Business Committees on PPP Extension - March 5, 2021
CDBA Comment Letter - NMTC Allocation Application-FY 2021 to 2024 - March 1, 2021
CDBA Comment Letter - CMF Application and Reporting - March 1, 2021
Joint Trades Letter Supporting the Protection of Recovery Rebates from Assignment or Garnishment - February 23, 2021
CDBA Comment Letter on Huntington/TCF Proposed Merger - February 18, 2021
CDBA Comment Letter on Federal Reserve CRA ANPR - February 16, 2021
CDBA Comment Letter on First Citizens/CIT Proposed Merger - February 3, 2021
CDBA Comment Letter on PNC/BBVA Proposed Merger - January 29, 2021
CDBA Comment Letter on Draft ECIP Application - January 22, 2021
Joint Trades Letter on OCC CRA Benchmarking Data - January 11, 2021
CDBA Recommendations to Treasury on Emergency Capital Investment Fund Criteria – January 6, 2021

2020

CDBA and NBA Recommendations to Treasury on CDFI and MDI Community Investment Program - December 29, 2020
CDBA Comment Letter to CFPB on Dodd-Frank Section 1071 Rule Proposals - December 14, 2020
CDBA and NBA Letter Supporting $12 billion for CDFIs and MDIs in COVID Emergency Relief - December 5, 2020
CDBA Comment Letter to CFPB on ECOA and Reg B Opportunities - December 1, 2020
Joint Borrower & Lender Trade Association Letters Regarding PPP Loan Necessity Questionnaire - November 17, 2020
CDBA Comment Letter on Proposed CDFI Annual Reporting CTLR - November 5, 2020
CDBA Comment Letter on Proposed CDFI Certification Requirements - November 5, 2020
CDFI Trade Association Letter on CDFI Certification - November 4, 2020
Joint Trades Letter EIDL Advances and PPP Forgiveness - October 19, 2020
Follow-Up CDFI Trades Letter Regarding Target Market Designation for PPP Loans - October 14, 2020
Joint Financial Trades Letter on PPP funding and forgiveness - September 29, 2020
CDBA Comment Letter on CDFI Fund Small Dollar Loan Program - September 10, 2020
Joint Trades Letter on Rescinding Section 1112 Payments - September 9, 2020
CDFI Trades Letter Regarding Target Market Designation for PPP Loans - August 21, 2020
CDBA PPP and Recovery Recommendations to Senate Small Business Committee - July 31, 2020
Joint Trades Letter Supporting the Protection of Recovery Rebates from Assignment or Garnishment - July 31, 2020
Letter Opposing Postal Banking Amendment to FSGG Approps - July 30, 2020
Letter Supporting Jobs and Neighborhood Investment Act - July 29, 2020
CDFI Trades Letter to CDFI Fund Requesting Deadline Extension for Public Comment on the CDFI Application - July 8, 2020
CDBA Letter to CDFI Fund on Equity Investment Policy - July 7, 2020
CDBA Letter to the Federal Reserve on Main Street Lending Facilities and Nonprofits - June 22, 2020
Alabama CDFIs' Letter to Sen. Richard Shelby on Economic Stimulus for CDFIs - June 19, 2020
CDBA and NBA Letter to Federal Reserve Bank of NY on Morgan Stanley Acquisition of E*Trade - June 5, 2020
CDBA and Inclusiv Letter to Congressional Leadership on Paycheck Protection Program Reform - June 1, 2020
CDBA Letter to SBA and Treasury on PPP Eligibility for CDFIs - May 14, 2020
CDFI Coalition Letter to Congressional Leadership on Economic Stimulus for CDFIs - May 5, 2020
Joint Trades Letter to Administrator Carranza on E-tran Access Issues - April 29, 2020
Center for Responsible Lending Coalition Letter to Treasury on Community Financial Institutions Funding in Paycheck Protection Program Expansion - April 27, 2020
CDBA Letter to CDFI Fund on Certification Eligibility and the Paycheck Protection Program - April 23, 2020
CDBA Letter to Fed on Liquidity Facility Term Sheets - April 16, 2020
Joint Trades Letter to House Leadership on Economic Stimulus for CDFIs - April 7, 2020
Joint Trades Letter to Appropriations Committees on Economic Stimulus for CDFIs - April 7, 2020
Joint Trades Letter to Financial Services and General Government Subcommittees on Economic Stimulus for CDFIs - April 7, 2020
Joint Trades Letter to Authorizing Committees on Economic Stimulus for CDFIs - April 7, 2020
Joint Trades Letter to Senate Leadership on Economic Stimulus for CDFIs - April 7, 2020
CDBA Letter to House Financial Services Committee on Economic Recovery Package - April 7, 2020
CDBA Letter to House Small Business Committee on Economic Recovery Package - April 7, 2020
CDBA Letter to Department of the Treasury on Paycheck Protection Program Liquidity - April 3, 2020
CDBA Comment Letter on CRA Proposed Rulemaking - April 1, 2020
FY21 CDBA Letter to Appropriations Subcommittees on Financial Services and General Government - March 31, 2020
FY21 CDBA Letter to House and Senate Appropriations Committees - March 31, 2020
CDBA Letter to Appropriations Committees FY 2021 FSGG - March 30, 2020
CDBA Letter to CDFI Fund Requesting Extensions and Program Adjustments in Response to COVID-19 Crisis - March 30, 2020
Joint Trades Letter to Administrator Carranza - March 25, 2020
Lending Coalition Letter to Congress on CARES Act and SBA 7(a) Provisions - March 23, 2020
National Banking Trades Letter to the Appropriations Committee FY21 - March 11, 2020
National Banking Trades Letter to FSGG Subcommittee FY 21 - March 11, 2020
National Banking Trades Letter FY2021 FSGG - March 11, 2020
National Banking Trades Letter Regarding CRA Comment Deadline - January 14, 2020

2019

CDBA Comment Letter on Bank Enterprise Award (BEA) Application - December 31, 2019
Statement of Jeannine Jacokes at FHFA Duty to Serve Listening Session - December 11, 2019
CDBA Comment Letter on BB&T-Suntrust Merger - May 6, 2019

2018

CDBA-NBA Comment Letter to OCC on CRA - November 16, 2018
Banking Trades Rescission Package Letter to Senate - June 18, 2018
CDBA Comment Letter to FHFA on AHP - June 12, 2018
Banking Trades Rescissions Package Letter to Leadership - May 10, 2018
Banking Trades Rescissions Package Letter to Appropriators - May 10, 2018
National Banking Trades Letter on FY2019 Federal Appropriations - April 20, 2018
National Banking Trades Letter on FY2019 Federal Appropriations to Financial Services & General Government Subcommittee - April 20, 2018
FY18 and FY19 CDBA Letter to Appropriations Subcommittee on Financial Services & General Government

2017

CDBA Comment Letter on Tax Cuts and Jobs Act to the Senate Finance Committee - November 3, 2017
CDBA Comment Letter on Tax Cuts and Jobs Act to House Ways and Means Committee - November 3, 2017
CDBA Letter to Treasury on CRA - October 23, 2017
CDBA Letter to Consumer Financial Protection Bureau on Small Business Lending Market - September 12, 2017
CDBA Comment Letter on Freddie Mac & Fannie Mae proposed Duty to Serve Plans - July 10, 2017
Bank & Credit Union Trade Associations Joint Letter on CDFI Fund - June 26, 2017
CDBA-NBA Letter to Treasury on Regulatory Relief - May 4, 2017
CDBA Letter to Senate Banking Committee - April 14 2017
CDBA Statement on FY 2017 Trump Proposal to Slash Job Creation Program - March 28, 2017
CDBA Statement on 2018 Trump Budget - March 16, 2017
National Banking Trades Letter on FY2017 & FY2018 Federal Appropriations - March 14, 2017
CDBA Comment Letter on FY 2018 Appropriations to the Senate Subcommittee on Financial Services - March 9, 2017
CDBA Comment Letter on CDFI Certification Requirements - March 9, 2017
CDBA Comment Letter on FY 2017 Appropriations to the Senate Subcommittee on Financial Services - February 7, 2017

2016

CDBA Comment Letter on Payday, Vehicle Title, and Certain High‐Cost Installment Loans - October 6, 2016
CDBA Comment Letter on BEA Application Proposed Changes - September 26, 2016
CDBA Comment Letter on CDFI Program Proposed Application - September 9, 2016
CDBA Comment Letter to the CDFI Fund on the Capital Magnet Fund - July 29, 2016
CDBA Letter to Chair of the Federal Reserve Janet Yellen - June 22, 2016
CDBA Letter on FY 2017 Appropriations - March 16, 2016
CDBA Comment Letter on CDFI Certification Standards - February 5, 2016

2015

CDBA Letter to House Financial Services Committee on Reciprocal Deposits - November 30, 2015
CDBA Comment Letter to the CDFI Fund on CDFI Program Interim Rule Revisions - October 30, 2015
CDBA Letter to FDIC on Small Bank Assessment - August 28, 2015
CDFI Fund BEA Program Evaluation Comment Letter - May 15, 2015
CDBA Letter on FY 2015 Appropriations March 10, 2015
CDBA Comment Letter on FY 2015 CDFI Fund BEA Application - January 29, 2015

2014

CDBA Comment Letter on CDFI Capacity Building Initiative October 24, 2014
CDBA Comment Letter on Annual Data Collection September 8, 2014
CDBA Letter on FY 2015 Appropriations June 6, 2014
CDBA Comment Letter on CDFI Fund's FA Application May 6, 2014
National Banking Trade Associations Letter on FY 2015 Appropriations March 13,2014
CDBA Comment Letter from the National Banking Trades Association FY 2014 March 13, 2014

2013

CDBA Comment Letter on Proposed Changes to the BEA Program December 30, 2013
CDBA Comment Letter on Proposed Amendments to CRA Q&As - May 16, 2013
CDBA Senate Appropriations Request Letter - FY 2014 CDFI Fund and BEA Program April 26, 2013
CDBA House Appropriations Request Letter - FY 2014 CDFI Fund and BEA Program April 26, 2013
National Banking Trade Associations Senate Appropriations Request Letter April 24, 2013
National Banking Trade Associations House Appropriations Request Letter April 24, 2013
CDBA Comment letter on CDFI Bond Guarantee Program - April 8, 2013
CDBA Comment Letter on Ability to Repay Standards Under the Truth in Lending Act - March 19, 2013

2012

CDBA Comment Letter Regarding Basel III Standardized Approach - September 10, 2012
CDBA Letter to Treasury on Community Development Bond Guarantee Program - July 19, 2012
CDBA Letter to CDFI Fund on the CDFI Financial Assistance (FA) Program Application - May 17, 2012

2011

CDBA Letter to CDFI Fund on the CDFI Bond Guarantee Program - August 12, 2011
CDBA Letter to FDIC on Brokered Deposits Study - July 6, 2011
2011 Financial Innovations Roundtable Bond Guarantee Work Group Recommendations - July 1, 2011
CDBA Statement for the Record, Senate Subcommittee on FY 2012 Appropriations - May 25, 2011
CDBA Letter to National Banking Trades Regarding FY 2011 Continuing Resolution - February 27, 2011

2010

CDBA CEO Jeannine Jacokes' written testimony submitted to the FFEIC Council on proposed revisions to the Community Reinvestment Act - July 19, 2010
Letter to CDFI Fund Director on Notice of Request for Comment on the Bank Enterprise Post-Award Reporting Form - March 17, 2010
Letter to U.S. House of Representatives on CDFI Fund and BEA Appropriations in FY 2011 - March 11, 2010
CDBA Letter to U.S. Senate on CDFI Fund and BEA Appropriations in FY 2011 - March 11, 2010

2009

CDBA to U.S. Treasury Secretary Geithner and SBA Administrator Mills on Small Business Lending - November 24, 2009
Letter to Obama Administration Regarding CDFI Bank Capital Purchase Program - November 1, 2009
CDBA to FDIC Secretary Robert E. Feldman Regarding the Legacy Loan Program - April 10, 2009