The case for a credit union Community Reinvestment Act

Under the Community Reinvestment Act of 1977, banks are required to ascertain the credit needs of the people that reside in their communities, and to take affirmative steps to meet those credit needs. Credit unions were not included in the Act because is was felt that they lacked the ability and/or the incentive to neglect their "communities" of members: They were not-for-profit, relatively small in size, and limited to serving people who shared a single "common bond". In the last two decades, the definition of what constitutes a "common bond" has expanded dramatically. This Note argues that, as a result of the changes that the redefinition of the "common bond" requirement has produced, credit unions now have the ability and the incentive to engage in the same types of lending discrimination that led Congress to impose the Community Rein-vestment Act upon banks. Thus, this Note contends, credit unions should be subject to a community reinvestment law of their own.