Americans for the Arts has filed comments in support of arts-based community development, or creative placemaking, as the Community Reinvestment Act (CRA) is considered for regulatory changes. The Office of the Comptroller of the Currency (OCC), one of the federal agencies regulating the CRA, is considering changes to “bring clarity, transparency, and less burden for regulated financial institutions and consumers, while providing flexibility to these institutions in meeting the banking needs of the communities that they serve” and is seeking public input. For arts stakeholders, it’s a keen opportunity to put forward a request for the CRA to increase its support of arts-based community development and creative placemaking. These investment approaches are eligible under the CRA currently, but Americans for the Arts is seeking changes in four areas: 

  1. Expand qualifying activities to formally include creative placemaking;
  2. Concern about “One Ratio” being set to assess private investments;
  3. Suggesting new metrics on community support
  4. Commit to low- and moderate-income neighborhoods

The comment was crafted with input and guidance from the National Alliance of Community Economic Development Associations (NACEDA), ArtPlace America, Local Initiatives Support Corporation (LISC), Upstart Co-Lab, Woodforest National Bank and New Jersey Community Capital. The comment as filed is available online here.